ML021760436
| ML021760436 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Watts Bar, Sequoyah  |
| Issue date: | 01/29/1998 |
| From: | Ravi Grover Tennessee Valley Authority |
| To: | Office of Nuclear Reactor Regulation, US Dept of Labor (DOL) |
| References | |
| -RFPFR, 50-259-CIVP, 50-260-CIVP, 50-296-CIVP, 50-327-CIVP, 50-328-CIVP, 50-390-CIVP, 97-ERA-59, ASLBP 01-791-01-CIVP, EA-99-234, RAS 3933 | |
| Download: ML021760436 (57) | |
Text
r In The Matter Of:
In the matter of Gary L. Fiser Tennessee Valley Authority V.
Ronald 0. Grover January 29, 1998 Hall & Associates 104 Tremont Street Chattanooga, TN 37405 (423) 267-4328 Original File grover29.asc, 123 Pages Mmn-U-Script@ File 1.: 1867117625 Word Index included with this Min-U-Scripts CDOOO'61
Tenessee
-V e
Au thor V.
Tennessee Valley Authority itozlaia U. (irove.
Týi"r1111a,,v "*
11004 T~ni~v 9 10I I
P]
212 f33
[4)
BEFORE THE OFFICE OF ADMINISTRATIVE LAW JUDGES UNITED STATES OF AMERICA DEPARTMENT OF LABOR Page 1 M53 IN THE MATTER OF GARY L FISER,
[6]!
- 17) 183 fill Compi.ant, Va.
- NO. 97-ERA-59 TENNESSEE VALLEY AUTHORITY.
Respondent.
January 29, 1998 1123 1131 DEPOSITION OF RONALD 0. GROVER (141 APPEARING FOR THE COMPLAINANT:
[1s3 COLLETTE R. JONES, ESQUIRE
[16]
CHAMBLISS, BAHNER AND STOPHEL 1000 TALLAN BUILDING
[173 CHATTANOOGA, TENNESSEE 37402
[is]
APPEARING FOR THE RESPONDENT:
[ie]
BRENT R. MARQUAND, ESQUIRE TENNESSEE VALLEY AUTHORITY (20]
400 WEST SUMMIT HILL DRIVE KNOXVILLE, TENNESSEE 37902 (21]
Also Present: Donna Green Im HALL AND ASSOCIATES 14 104 TREMONT STREET CHATTANOOGA, TENNESSEE 37405-4145 (25" 423-267-4328
[i]
P)
Page 2 INDEX Page I
Deposition of RONALD 0. GROVER
[4]
Direct Examination by Ms. Jones-....
4 Cross Examination by Mr. Marquand...
103
[IQ EXHIBITS No.
Descriplon Page
[8]
1 Position Description 12 S2 Position Description 22 3
Performance Review and Development
[1i]
Plan for Gary L FIser 14 4
Questions for Program Manager II1]
Chemistry 76 1123 1131
[143
[153
[171 1141 0919 (211
[Im rA (124 MR3
[1]
The deposition of RONALD 0. GROVER.
[called as a wtm s at the instance of the R Complalnant. taken by agreement on the 29th day of
[4] January, 1998. at the Tennessee Valey Authority,
[R 12th and Chestnut Streets, Chattanooga, Tenunssee.
P)
STIPULATIONS M7 Deposiion Is being taken by agreement of
[8] counsel for the plainti and the defendant. it b (3 agreed that the deposition shal be taken In
[10l machine shorthand by Cathy H. Kerley, Notary Pubic
[i1] and Court Reporter. that the signature of the (12] witness to the completed deposition Is not waived,
[133 and that the winess may be sworn by the said (143 Notary Plblic.
[is3 It b further agreed that a formalIties 1is] as to caption, notice. certificate and mode of
[173 transmission we waived, and that the deposition Is
[ia] taken subject to the usual exceptions as to
[19I rrelevancy, Incompetency and kImaterality, which (20] are reserved to the hearing of the cause, except as (213 to the form of the question.
~ CD(
(243 M25 I
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(3) Page I -Page Hall & Associates (423)267-4328 Min-U-Scripte
In the matter of Gary L Fiser v.
Tennessee Valley Authority Ronald 0. Grove Tanuarv 2Q 1 OO
V]
RONALD 0. GROVER, I called as a witness at the instance of the pl Complainant, having been first duly sworn, was
[41 examined and deposed as follows:
DIRECT EXAMINATION al*
BY MS. JONES:
0 Q: Mr. Grover, can you please state your tsj full name and address for the record.
tu A: Ronald 0. Grove ve t,2]
0: And are you married?
p3l A: Yes.
1i41 0: And what is your wife's name?
lisl A: Sharon.
(tIs 0: And do you have any children?
(p17 A: Yes.
iej Q: Do they live with you or in this area?
1,91 A: I have three sons, two live with me and t0 one is in college.
czil Q: Okay.What are their names?
pm A: Ronald 0. Grover, Jr., Myron Grover and r23 Brian Grover.
"41 0: Okay. Do you have any other immediate family?
cii A: In the area?
rM 0: Yes, sir.
pl A: No.
(43 0: Okay.What is your current position at m TTVA?
pq A: Well, I'm classified as a senior r( manager in corporate nuclear engineering.And I'm ta] really in a transitional state right now. I just M recently was - returned from a temporary lioj assignment at the Institute of Nuclear Power uiii Operations in Atlanta, Georgia. I was there for 15 1,21 months.And I'm scheduled to undergo five months (133 of operator type training at the Sequoyah plant l,41 starting February 16th.
(is]
So I'm really classified in like a ciel developmental status, senior manager, but I'm a 1,7 part of the corporate engineering organization uiaj reporting t1ip 0: Corporate engineering did you say?
N A: Corporate engineering reporting to Jack Bailey.
Q: Okay. In preparing for your deposition t
here today, did you talk to anyone other than 124) Mr. Marquand?
pq A: Mr. Marquand?
Page 4 Page 5 Page 6 cIl MR. MAROUAND: That's me.
tA A: Oh, I'm sorry.
pi 0: That's your attorney sitting next to
[,4 you there.
A: Oh, I'm sorry. Okay. No.
0: Did you review any statements that you p had given previously?
is]
A: No.
m, Q: Are you aware of any statements that c'o] you had given previously?
ill)
A: Yes. I believe I spoke with
[12 Mr. Marquand before when this first came up and p13 Ms. Cathy Welch. I believe I talked with her p4] somewhat during tisi Q: And who is Cathy Welch?
- pis, A: She was the HR person, human resources p173 person, that was researching the case at the time cies that it occurred.And since - I'm sorry.I lip] forgot your name.
r(
MS. GREEN: Donna Green.
(213 A: Yeah. Ms. Green. I'm sorry, Donna.
pm Ms. Green has taken over - has replaced Cathy r23 Welch.And also I spoke with a representative from 124] the Department of Labor about it. So I think there r4 was three people.
lit 0: And did the Department of Labor take a r4 statement?
m A: Yes.
141 Q: Did Ms. CathyWelch take a statement mi independently of that.
Rs A: Yes. She took notes. I don't know M whether she put it into a form of a written - I m wasn't asked to sign a deposition from Cathy.
pi 0: You anticipated my next question. Did cial you ever review anything and then sign it?
[ill A: No,asfaras Irecall.NowI don't (12l recall signing anything from a legal staff 113] standpoint or anything like that.
p4l 0: In preparation for your deposition, did (is) you review any of those notes that had been taken clie about your prior interviews?
(l17 A: No.No,Idid not.
cii]
0: When did you begin with TVA?
(1s]
A: February - I believe it was February p the 28th, 1994. It was the last day of February in r21 1994. 1 believe it was the 28th. I believe it fell on the 28th of February.
(23 Q: Where had you been employed prior to t243 that?
CD000763 (2sl A: NewYork PowerAuthority for Page 7 Hall & Associates (423)267-4328 Min-U-Script (4) Page 4-Page Hall & Associates (423)267-4328 min-U-Scripte (4) Page 4 - Paste January 20 1001 I
Pag 6
in the matter of Gary L Fiser v.
Tennessee Valley Authority Ronald o. Grover January 29, 1998 Page 12 (13 A: Correct.
rm 0: Okay.
Pj (Thereupon, the position description was marked (41 Exhibit No. 1 to the deposition of Mr. Grover pj and filed herein.)
(6 BY MS. JONES:
17] 0: Let me hand you a document which has (83 been marked as Plaintiff's Exhibit 1, which is a Mj position description for the chemistry and li( environmental protection operation services, and
[11] ask you if you can identify that.
(12l A: Oh, me?
(121 0: Yes, sir.
1141 A: Oh, I'm sorry.
I1S] 0: If you need to take a few minutes to
[is) look at it.
(1l A: Yes. I'm aware of it.
fie]
0: Is this the position description for (t1] the newly combined chemistry, environmental manager pq that you have just described for me?
1211 A: The - yes.That's for the program rm manager position, PG-8.
(233 Q: PG-8?
",4)
A: Right.And then there was sj 0: And that would be the position held by Page 13 (il Mr. Fiser as well as your other two direct reports?
r2 A: Correct.And then when we combined M3 see, we combined and we had a total of five 141 positions.When you combine - when we combined M5 chemistry and environmental, we had a total of five 3 positions that reported to the manager of that M combined group, the chemistry and environmental an organization.
R3 And as it worked out from a practical (01 standpoint, it was, you know, three chemistry and (13 two environmental basically positions, but there
[23 was one position description written for all, but (133 there was four PG-8 level positions and one PG-7 (143 position that formed that organization.
liq Q: All right.
(i16 A: But they all had the same basic (73 position description.
(18 Q: Okay.
(*1l A: Which can be chemistry and 20 environmental.
0i 0: And that position description is reflected in Plaintiff's Exhibit 1?
A: Correct.
1241 Q: All right.
(25 A: But there was two PDs.There was this Page 14 mi one for all the PG-8 level positions and there was r( a separate one for PG-7 because you had - it was a 3i] different level position.
(43 0: 1 understand.Thank you for (s5 A: But that was the direction we were
[61 given to go - combine it, develop one PD.
0: Okay.And did you sit on the selection
- 8 board for the people who had bid into that im position, the position of PG-8 I'm referring to?
p1oi A: Yes, but not until after-I'm trying
[113 to recall.As I recall, the position I was vying (123 for had to be - you know, had to be resolved
[131 first.And once you - once the manager's position (14] was resolved, then - since I was selected to (1s] fulfill that position, then I participated on the (i16 selection board of the other positions.
(1*7 0: Okay.And who was chosen for the newly (18] created PG-8 positions that are reflected in l(1] Plaintiff's Exhibit 1?
(20 A: As I recall, Gary Fiser, Sam Harvey, (213 E.S. Chandrasekaran and Dave - I'm drawing a blank w here. Oh, boy. He was the environmental manager p2] at the time.
124]
MR. MARQUAND: Is that Sorrell?
r(
A: Sorrell. I'm sorry.Yeah. David Page 15 m1 Sorrell was the fourth individual for those four In spots.
- j 0: Okay.Turn to Plaintiff's Exhibit I
- 4 and the principal accountabilities that are
[sl reflected on page two and three of that document.
(sl Generally in what ways does this position
- description differ from the prior job description
- 3 that Mr. Fiser held in his position?
m A: The main difference was the addition of (10 the environmental function into this PD.That was (t1] the main - because basically we - you know, from (12i a chemistry standpoint, they fulfilled all these 1133 requirements.They met all these - you know, (143 these tasks, accountability, principal (i13 accountabilities.
(163 Q: Would it be fair to say, then, they (1l were doing everything they did before in chemistry, (163 but environmental duties were added to that list?
(193 A: Yes. I think that's a fair statementrC 0DO00765 (2
0: All right.
(21]
A: And vice versa. I mean, if you were in tA the environmental group, you could say the same A thing because, now, you know, we're doing 1241 everything environmentally plus now we're doing r2m we got the chemistry functions added into that.
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I Hanl & Associates (423)267-4328 min-U-Scripta (6) Paee 12 - Paee 15
in tne matter ox (Cary L Fiser v.
Tennessee Valley Authority Ronald 0. Grover Tni.va l9n I Ona T~n2-1'70 1o V]
Q: Okay. Excuse me for knocking feet here rA under the table.
t1 After this reorganization in I believe 14]
-,a said summer of '94 when Mr. Fiser was selected (5] by the board on which you sat for the newly created (6 position that we've been discussing in Plaintiff's pm Exhibit 1, did he actually perform the aj environmental duties that are reflected in this m revised job description.?
1i0o A: No.At the time the - the whole
[I1I objective was to over time, and we're looking at, p12] you know, a couple of years, probably two years at (13] best, to transition into having everyone in the (14] organization competent enough to do environmental lisl work as well as chemistry. In other words, you 16] got - you're merging a group and you got chemistry
[17 people that are specialists in chemistry and you've tial got people that are specialists in environmental.
[i9]
The plan was or the objective was to 2] combine the group and form one PD and over time 121] because you're getting smaller, you have less pm resources, but you still have to accomplish the w23]
same job load, so that the focus was or objective (4] was to get everyone, you know, up to speed to be pq able to function in both arenas, if you will. Not (o] to say they've got to be environmental specialists m and chemical specialists, but at least they could p] function in various - in both capacities. Same l,] thing in the environmental people, you know, get m them more involved in the chemistry function.
Mu And we started to do that. We started m to do some there. But basically when we started p8 off at the time, I mean, the chemistry people pq focused primarily on the chemistry tasks and the (10] environmental people focused on the environmental (II] piece with the idea that we started doing some of 12] that cross-fertilization, you know, and we would be
[p3 able to assign some of the chemistry duties and (143 some various tasks to environmental people.
[is]
Conversely, some environmental things ilg we would be able to, you know, get the chemistry
[17l people to help on based on what the nature of the
[1s] task was.
[1q Q: Let's focus on the next year and a p0 half.And by next I'm referring to about a year (21] and a half after that July reorganization in '94, ng taking us up until approximately the beginning of tq 1996, which, if I'm doing my math in my head 2i] correctly, is about a year and a half.
r(
A: Uh-huh.
Page 16 Page 17 V]
0: During that time period was that M2 cross-training or cross-assumption of duties, did (3] it actually take place in your department?
- 4]
A: Toward completion, no, it didn't.
Q: Okay.What, if anything, did occur?
[6]
A: During that time period?
rm Q: Yes, sir.
(8 A: Well, we - one thing, I guess, that m kind of
[10]
Q: And before you start, let me ask for
(]ii your favor here.You're talking to a nontechnical
[i2] person.
(13]
A: Okay.
(14]
0: So you have to be very basic with me lisi A: Okay.
(161 Q: - and specific about what particular
[(171 jobs or duties do you recall your chemistry folks (1a] taking on that was an environmental responsibility
[19] before.
[20]
A: There were very little, if any. I'll
[21] give you an example. I would ask the chemistry
= folks to help out with chemical - what's called r3] chemical traffic controlling. In other words, t24] controlling - control of the chemicals used at the
[5 plants.That was a chemistry function at the Page -18 I
Page 19 m1] plants, but it was - in years past during this m time prior to me coming it was moved into the m3 environmental organization as a responsibility at t] the sites.
So I had the chemistry people because
- they were knowledgeable in that area and on
- occasion I had some of our chemistry folks would Pq help out in assessing that area and helping them m make sure they were meeting the requirements in the (10 chemical.That's one example.
III]
But there was very little as far as 12] environmental.And one reason is because the 133 workload was so heavy in the chemistry area.That (4] was our main focus.We had some issues and some (16l challenges we had to deal with.We had problems at p16] two of the sites. So we had to put our main focus (1*7 on chemistry.
[1s]
And then - and, conversely, we had CD00076
[i9] several chemistry things that I had to ask for the
[20] environmental people to do, but there wasn't a big
[2i] shift or major, okay, I'm going to break this W environmental ongoing task over and I'm going to nrs put it into - you know, I'm going to give this 124] assign this to one of the chemistry guys and he has 2] to do it on an ongoing basis. So that didn't Hall & AssocIates (423)267-4328 Min-U-Script (7) Page 16-Page 19
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0
Luic mauer of Gary L Fiser v.
Tennessee Valley Authority Ronald 0. Grover Tanualry2Q 1 Goi Page 20
[II occur.
"4 The other thing I wanted to mention
,3] that kind of thwarted our efforts to move in that 14] direction was the fact that we lost two of the p two of the environmental people that hired in
[61 during the merging found other jobs. So Jim m Mantooth left shortly after the reorganization and tel Dave Sorrell left and took another position, you pi know, six months - several months after that.
ri*
So - so we were - you know, because, 1i] you know - those individuals were long-standing
[12] specialists in the environmental area in the 113] corporate organization. So one of the things that
[14] you need to make this type thing work is you've got
[IS] to have your expertise there so you can
[16] cross-fertilize.
[17]
Okay. So with losing that piece, now
[18] we had to bring in new people that didn't have
[19 maybe didn't have the level of experience that
[203 these individuals had, so - but you're set
[211 backwards because once you lose a person, you know, pm you're talking six, eight months to try to fill jpa1 that position.
r41 So that effort was really thwarted, if I you will, to try to do that. So we pretty much -
[I] and that combined with the fact that we had some R mountains to climb to - you know, to tackle in r3] the chemistry arena, we had to focus - had to have
[4I the chemistry people to focus on the chemistry ms] things to get - in support of the plants to get us
[s] back - get us where we needed to be from a m chemistry perspective.
jsl Q: Let me make sure I understand your m9 answer here.Would it be fair to say, then, that
[io] between July '94 and January of '96, Mr. Fiser ji q performed and all your chemistry specialists before
[12] performed essentially the same functions that they tl1] had performed prior to working under the new job
[14] description that is Plaintiff's Exhibit 1?
i1t]
MR. MARQUAND: I object to that.That
[Ie] mischaracterizes the previous testimony.
[i7I MS. JONES: I'm asking him if it's l16] fair.
Page 21
[0 Q: If it's not, please tell me how it is not.
A: Well, the only thing I would add, like r[] I said before, was I did ask the chemistry people r24] on occasions to do some environmental function.
[2s] But functionally, yes, they basically did the
[II chemistry function.They carried out the chemistry 2 function.
131 Q: Okay. Could you assign a percentage
[4] figure to the amount of time that your chemistry jq specialists including Mr. Fiser performed any kind
[61 of environmental responsibility.
m A: It would have probably been less than (e] five percent. I mean, if you're talking about m9 aggregate time and look at the number of tasks we ji0] gave them
[11]
0: Yes, sir.
[12]
A: - you know, you're probably looking at
[13] five percent, less than five percent.
114]
0: All right.Thank you. Since we're (is) talking about position descriptions, let's go on to
[161 the next position description that's going to be at
[i7I issue in this lawsuit.
[is]
(Thereupon, the position description was marked
[1j] Exhibit No. 2 to the deposition of Mr. Grover w20 and filed herein.)
[21)
BY MS. JONES:
[22)
Q: Let me hand you a two-page document
[3] that's been identified as Plaintiff's Exhibit 2, 124] which is the PD-8 description for the chemistry (2sl program manager and the initials are PWR and ask if Page 22 Page 23
[1) you can identify that.
m A: PWR? Oh, okay.Yeah.That's rA abbreviations for pressurized water reactor.Are t,4 you asking am I aware of this?
m Q: Are you familiar with this?
I6 A: Yes.
p*
Q: Okay.And is this the position
- description that was posted in approximately June p of 1996?
l101 A: When you say - you said posted?
- 11) 0: Was this a position that was - when I
[12 use the word posted, I mean competitively bid for.
[13)
A: Well, I don't know.This was - I'm
[14] aware of-of-in context I'm aware of this
[is] particular position description. I don't know
[1j6 whether this was the latest version.You know, I (171 can't tell you whether this was the latest version
[16] that was used for the, you know, posting of the j19] position and so forth. I mean, it's dated July the w 16th, 1996.
t211 I can't recall whether, you know rm when I look at it, I'm aware of the information 23 there. It looks like there - you know, if this
,24] wasn't the latest version, it was close to the
['5 latest version; okay?
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Tennessee Valley Authority Page 2 Vi] 0: Okay.
A: I mean, when it got to this stage, it
- 3] was either little small changes, pen and ink type 41] things, you know, the typo, but the content - you is] know, the basic content was essentially the same.
M6 0: Okay. Let's focus on that content. In M comparing - taking that job description and ms comparing it, by that one I mean Plaintiff's m Exhibit 2, in comparing it to Plaintiff's (10] Exhibit I till A: Uh-huh.
1121 0: - what are the essential differences (13m in duties between those two position descriptions?
114]
A: Well, one of the main changes was Ivs the - the exclusion of the environmental piece out ti¶] of the PD as it's written. Okay.That was im basically the main difference here.
(is]
That combined with we wrote two PDs for 1191 the two chemistry positions that were to remain, 120 one for BWR, which is boiling water reactor, 121] because TVA has two units - two unit boiling water tM reactors, and one for PW1R which is primarily Rm pressurized water reactor, which TVA has three (24] sites or actually two right now that function.
M So the main difference was that you Page 25 mij took the environmental piece back out of this, but m2 essentially, you know, from an overall sense the ml chemistry functions in here, chemistry 14 accountabilities, stayed the same.
is 0: Okay.
ts A: But they were split somewhat between m the PWR and the BWR. Some of the things that isi you know, PWR or BWR focus we put in the BWR and m then PWRs was like steam generators are system-wise t10] a part of the PWR, not part of the BWR. So that w11] control - that chemistry controlled that equipment (12] built into this particular one.
t12 0: Okay. Now, at the risk of being t14] tedious because I'm, again, as I warned you, a lisl nontechnical person (16]
A: Okay.
tTii 0: - I'm going to have to have a little pli bit of specifics on what you just told me so that I (19] can better understand what you mean by both of them
[20 as they're applied in this position description.
1211 For instance, can you tell me by pointing out on rM Plaintiff's Exhibit 2 which duties here are unique M3 to a PWR position.
124]
A: Okay.Well, statement number or line 25 item number two here on page two, function as the Ronald 0. Grover January 29, 1993 Paae 26 p1] that you have identified as statement number two on m Plaintiff's Exhibit 2.
m A: Correct.
14]
0: All right. Is there anything else on
- Plaintiffs Exhibit 2 that is unique to the PWR
- chemistry position?
m A: No.The only difference is that we (8 specify - you know, we specified the plants, the m9 PWR plants, Sequoyah, Watts Bar. So you reference
[10 those.And then the BWR ones you would reference v11] the BWR, but the function stays the same. So, you
[1i know, the main difference is you got a different it3] chemistry program for PWRs than you do BWRs and 1141 that's referenced in the - you know, the secondary tisi chemistry control, but, again, it's - so tie essentially they're basically the same except you tia just made specific reference to the PWR plant 118 versus the BWR plant because the chemistry program ti1 is a little bit different.
[2w 0: Okay. So then would it be fair to say
[21i that all of the chemistry responsibilities that are cm included in the job description on Plaintiff's r2] Exhibit 1 included both the PWR and BWR (24] responsibilities that were later divided - CD000768 im A: Correct.
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Hail & Associates (423)267-4328 Min-U-S cripta tmi TVAN senior technical expert to the sites in the
[2 areas of PWR secondary chemistry control, okay, r] which is different from BWR chemistry control.
F'] 0: Okay.
m A: Now, that's where the steam generators (si come into play.That whole system chemistry is m fits in under number two; whereas, you don't have
[al steam generators in boiling water reactors.
pi Q: But in the prior job description that ti] is Plaintiff's Exhibit 1, were those wiij responsibilities included?
112]
A: Yes.They're embedded in here, yes.
(13] They were embedded in here.We didn't make the
[14] distinction in this one.Are you with me?
[is]
Q: Right.
lisl A: You know, to give you an example here, p17l well, number one here, page two, provide technical t18] and programmatic expertise for implementation of t[ii the TVAN chemistry and environmental protection trc programs at individual sites. So we didn't make 2q1 the distinction. It was all rolled into one r42 statement.
p 0: Let me make sure I understand you, r24] then. So statement number one on page two of r4 Plaintiff's Exhibit 1 incorporates those duties Page 27
in tie matter of Gary L Fiser v.
Tennessee Valley Authority Ronald 0. Grover Jantuary 29, 1998 January 29. 1998 11 Q: - into two job descriptions?
A: That's correct.
Q: So the only thing that was excluded s4 from the two new job descriptions, and by new ones tSI I mean PWR and BWR job descriptions, was the Im exclusion of those environxhental responsibilities m that were included in Plaintiff's Exhibit 1; is isi that correct?
pn MR. MARQUAND: I'm going to object. I ioi think that rnischaracterizes the testimony. I also till think the documents speak for themselves.
tp2 0: You may answer.
1131 MR. MARQUAND: You can answer.
t14]
A: I don't know how this is lis]
Q: This is a lawyer thing here.
[l1]
A: I don't know whether I'm supposed to, p173 you know ie8 MR. MAROUAND: I'm making these
[191 objections for the record.
12p]
THE WITNESS: Oh, okay. I didn't know 121] whether I'm supposed to stop or what.
r MR. MAROUAND: You do stop when I start I2] to make an objection. Let me state it and then "VAt THE WITNESS: Okay. I didn't know ihether I had to - okay. Could you repeat the question. I mean, I forgot what MS. JONES: Can you read it back.
C(hereupon, the requested portion of the record was read back by the reporter.)
THE WITNESS: That's correct. In addition to we tried to delineate more when we split the two out in that we may have had a general statement in the old one and we tried to delineate more like you have to be a part of this working group or this, that and the other.
So it's not a direct word for word parallel.You know, you can't take this one and say, okay, I'm going to lay it beside this one and it should be word for word except for environmental.There was some rewriting or reengineering to be more specific on, well, I have to participate in this user's group or I have to do, you know, this.
0: Right.
A: But it was all embedded in this one, t yet it was more general and it wasn't broken Page 28 Page 29
ý_gt.
p2 3:
Okay.
msj A: So I just wanted you to understand it's (25] not going to be a direct word for word, you know,
[m] correlation.
m2] 0: I didn't mean by my question to imply tPi that the words were the same.
14] A: Yeah. But functionally, yes.
]
0: Let me ask a follow-up question and 161 make sure that we have that clear. So functionally
- if you took - let me ask it this way:. If you took
- s all the responsibilities, chemistry
[] responsibilities, in the PWR, added it to all the
[10] chemistry responsibilities in the BWR job 111i descriptions, would that cover all the chemistry
[12] responsibilities that are included in Plaintiff's pi3] Exhibit 1, which was the old job description?
t14]
A: Yes.
pIs]
Q: Thank you. Go off the record for a
[16] minute.
(171 (Thereupon, a brief recess was taken.)
(1s]
BY MS. JONES:
[19]
0: Mr. Grover, I'd like to turn our
[] attention to the reorganization that occurred in
[21] 1996. How did you first learn aboutTVA's plans to pm do a reorganization in '96 that would affect your
[23] department?
t24i A: Well, we had a staff meeting, an r25] initial staff meeting. It was the March time Page 30 Page 31 II] frame. I don't recall the exact date, but we tm had -Tom Magrath called a staff meeting and he Pi had discussed what the - that we were going to be 141 doing a reorganization and it basically entails a Iq staff reduction, budget reduction basically, you m know, and laid out some objectives that we'd have m to look to accomplishing this reorganization.
p1 0: And did he tell you what the - did he on give you some firm objectives that you were going
[1o] to have to meet?
[vii A: As I recall, we had to reduce our
[12] current budget/head count level by 40 percent by
[13] the year 2000. Okay.And
[14]
0: So that was about a five year time is1] span?
(16]
A: Well, let's see, '96 to 2000.
1173 0: Four years.
[1e]
MR. MARQUAND: This was for fiscal year
[191 '97, though.
t[]
A: Yeah. It was starting for '97, fiscal 121] year '97, through the year 2000.What, three rzn three years? '97, '98, '99, 2000. So four years.
m3 0: Okay. Did you say - what was the 124] percentage?
CD000769 r2s5 A: Roughly 40 percent.
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[17]
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jan me matter of Gary L Fiser v.
Tennessee Valley Authority Ronald 0. Grover T-n rw,n-vL- "YI Itett 7
Y
)
.7lo ui]
Q: Okay. Did you have a short-term goal rA that you had to meet initially that was identified P3] in this March staff meeting?
141 A: Well, I'm not sure what you mean by
" short term. I mean, I didn't have an immediate "r* goal like, for example, by the end of 19961 had to
" have reduced it down by - you know, achieve this
" budget level.
We - we were directed to come - to uvi develop a plan to - a proposed plan to get to that
[1i] end. Okay.That was the initial direction was to
[i2] develop a plan to get to that end.
[13]
Q: At that time period.
[14]
A: At that time period.
[IS Q: Okay.
[isl A: And he would look at that and then, you
[1p7 know, we would try to work - you know, work it out t*ej from there.
fisg 0: Okay.Was your understanding initially w that you didn't have to make the entire 40 percent 12] cut in the next fiscal year?
pm A: That was the initial information that rM was put out and then we had a subsequent meeting p24] and it was - it was discussed that your proposal 1[2s would be reviewed and if it was saw fit that we can Page 33 Iii do it all now, you know - you know, Tom Magrath m* was the general manager of the department.Tom ra said that's what I'll - you know, I'll make the l4] decision and we'll do it.
Msj You know, so it was, well, if we can p I'll look at the plan and we'll make a decision as p] to - based on how you've got it laid out. We may pB get it.We may wait. It may go to 2000 or we may pq do it sooner.We may - you know, so it was - you lial know, it was a management decision to change it or
!11) move it up or that sort of thing.
p23 Q: Did you submit an initial plan to tp3 Mr. Magrath for his consideration that was less t14] than the 40 percent reduction in the next year for lis] him to look at?
pes A: Yes.The original submittal was - was
[17] structured such that we would achieve the 40 lial percent in the year 2000. 1 believe it was 1999 tisq between 1999 and 2000 we would r40]
Q: Under that first initial scenario how
[i21 did you envision staff cuts or meeting those goals im in your department?
pq A: Well, as I recall, the first submittal 124] for 19 - I know 19 - you know, if we're looking ps through the year 1997-1998, we were able to meet,
[ii you know, a certain percent reduction.You know, Ma in my recollection, we may have been given a Pi certain percentage that we had to reduce by fiscal i*l year 1997. It may have been like 17 percent or
- something like that.
[]
In fact, now that I remember it, it was
- some number, some intermediate number, like we want
[8] to see a 17 percent for the first year, something M like that.
110]
Well, the plan included - it met that
[p] criteria because one thing we had - we had - we
[12] had one position that we hadn't filled yet, so we 13] had one vacancy. So from a budgetary standpoint we 14] were able to achieve that.
[is]
And then we looked at it and, you know, l18] I had the team look at it and we - the team, my
[p7 group, we all kind of looked at it and we - we put
[is] together a plan to achieve that end of 40 percent
[191 with intermediate reductions. Okay. So w20 intermediate reductions were in that plan.We
[21] didn't just say, well, we'll stay like we are and
=aai then at the year 2000, boom, we'll just reduce by p23 40 percent.
r24]
0: In that initial plan that you said that m2g you discussed with your group members, did you Page 35 ti' was part of that changing the job description that
- a we've discussed at length already in creating new 13 positions?
l4]
A: No, not the initial one because m initially organizationally I looked at the j61 chemistry and environmental piece and we tried to mn look at it in a horizontal fashion.And then the p other groups did the same thing, RadChem and p] training and, you know, the other organizations
[10] reporting under operations support at the time. So p11 I was just looking at between environmental
[12] within the environmental chemistry organization how
[13l are we going to achieve that.
114]
0: Okay. So in your initial plan, meaning t15] this interim about 17 percent I believe you said
[118 A: Right.
[171 0: - reduction, your chemistry and
[1a] environmental managers would have stayed in the
[19] position that they were in; is that right?
pq A: Well, for the first - for the f21) 0: For that time period.
CD000770 Im A: For the first year.
r23 Q: That's right.
1241 A: For the first year. Obviously you w5 couldn't - we couldn't maintain the same -
Hall & AssocIates (423)267-4328 Mn-U-ScriDt@
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Page 12-page ;S Min-U-Scritift Page 32 Page34 Hall & Associates (423)267-4328
In the matter of Gary L Fiser v.
Tennessee Valley Authority Ronald 0. Grove January 29, 1991 taj because the problem is we didn't have a significant i amount of additional expenses over the overhead.
.t] The overhead meaning the individuals in the 14] positions. Okay. Overhead was us. Okay.
M Q: Yes.
im A: So there wasn't a lot 6f room above M overhead.You had some - some basic expenses that pi we had to, you know, carry, travel to the plants mi and some minimal things, office support and that
[10] sort of thing, but there wasn't a lot of overhead.
III]
So we - you know, and everybody 12] realized that.You couldn't sit here until 2000
[1a3 and think you got this - you know, you got a big 1141 chunk of variable costs that you can reduce down tisi and that's going to give you 40 percent.We didn't lie] have that luxury. So it involved - it was going p1l to involve people.
pis Q: Right.
[19]
A: So I think the plan, if I recall w20]
correctly, included maintaining the head count at p21 least through 1997, okay, before we hit our first pm reduction of the people that were already in these rq positions because we - again, we had a position
-241 that we didn't have filed and we had some room to reduce some of the other operating expenses.
Page 36 Page 37 V]
0: Okay. In this initial plan, was moving r2 Mr. Harvey to the - I believe it was to an on-site m3 location part of your initial plan.
[j A: No.
0i Q: Okay.Was he tansferred to -I m wanted to say Sequoyah, but I'm not sure if that's m accurate.
pq A: Was he transferred?
Pq 0: Yes.
ioi A: No, he wasn't transferred.At the time cIII he was working on a project in support of Sequoyah (12] which we - which required that he work a lita considerable amount of time there, but, no, he was (141 never transferred to Sequoyah.
ils]
0: Okay.Was there any action regarding i1e] Mr. Harvey that you were going to take that would 1i7] have taken him out of your budget and helped you palj meet your goals?
li1l A: Well, there was - there was something r20 that came up.You know, let me preface this with this:You know, at the time when we've gone through this - and the people here atTVA have 2] been through this before.
-241 Okay.And I always took the position 25 that whenever we go through reorganization and Page 38
- il particularly if it looks like there's going to be a
- staff reduction, this, that and the other, my 1P1 primary concern was communicating to the people, 14] letting them know as much as I knew that I could m discuss with them, letting them know that here's
[61 what - here's the situation. Okay. Here's what Mj wev'e been asked to do. Here's the objective of pi this whole effort, okay, as far as I've been 19 directed to carry out.
1i]
Okay.And I always asked - I always ri q advised or encouraged rather is a better word, I 112] always encouraged all the people in our 1131 organization, okay, look at - first of all, we p4] support - our number one objective is supporting isi the sites.We basically work for the sites.
116] Okay.
[171 So the number one objective is - the t11] first thing I encourage all of them to do is go to
[o9 your respective sites and your counterparts and let rm them know here's the situation because what - as 121l it boils down or when it boils down as this all
[22] shakes out, what's going to count is if the site r[3 wants your particular position, your function,
[241 they're going to stand - they have to want to 125 stand up and say this is what we want.We don't Page 39 III want this.We want to maintain this particular rA function. So that affects all of our organization p] on an individual basis or a collective basis or
('1 however you want to look at it.
So the first thing I encourage them is
- to go talk to your counterparts and the RadChem
- chemistry managers and let them know what's going pa on.And if they sense a need that they need to pi keep your particular function, okay, now, we're lioj talking functions now, they need to feed that back p[i to organization.
(121 Okay.And that's generally how it pri goes, okay, when you go through reorganization.
[14] Okay.We need to look at everything. Look at tisl everybody's function.What's everybody doing?
t16] What kind of support are we getting from
[m' corporate? Let's feed that back. If we need this, lial what can we do without? We still need this.You
[1o] know, that's what - that's our goal. So I said p you need to let them know that so if they want your 21] function, they need to feed that back.
CDO00771 r~m Okay.The second thing I always 2] encourage them to do is look around, look for other
[241 options.There may be other positions that you
[2s5 could - you could apply for because I don't know Hall & AssocIates (423)267-4328 Min-U-Script (12) Page 36-Page 3 X~in-U-S cripta (12) Page 36 - Page 3 I
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in me matter of Gary L Fiser V.
Tennessee Valley Authority Ronald 0. Grove Tanilarv 2') 1')')
- 1] how this is going to all shake out. Okay. I don't
- know how it's going to go, this, that and the pi other.
(41 I'm in the same situation, okay, m because my position is being phased out and merged is) into one. So I told them I w;ould be straight up m with them, straight forward with them.
pq And I encourage that because if these m positions get redefined and re - you know, liol combined and they get reposted, this, that and the tiii other, you're not just interviewing back in the job
[12] you had.There's other people that's going to (13] interview. So you're competing against other
[14] people that weren't in this organization before.
tisj Now, oh, this is a new job, so I can come in and 1i16 compete, as well.
[17]
So there is no guarantee even if liS] there were three slots left and you got three pg chemistry people and we have to repost it. It's p the same thing we went through in '94.You know, I r21 had to interview with other - there were four or pm five other candidates I had to interview with, you pl know, and it worked out okay for me. Same thing 1241 with the other individuals.
[2s]
So you're not just - you know, well, v) we're just going to - it's not just a paperwork
- drill. Okay. It's posted. It's an open
- ] opportunity for everybody to - that's interested 141 in that position. So you're competing against
" other people. So I always tell them to look
" around, explore your options, you know.
m Q: Did Mr. Harvey do that?
p A: I - I would think that all of them (M looked at that and I think he did that, as well (101 you know.
[II]
And to answer your question as a
[l12 follow-up, shortly after we had that - I think our l13l second meeting in the March time frame, I was out
[14] at Sequoyah and Charles Kent, which is RadChem 1s5] chemistry manager at Sequoyah, and Gordon Rich, l16 which is chemistry manager, we were - you know, p17l they approached me.We were talking about some liej other matters, but they approached me and asked tioj that - Howard felt if they would request his (20 position be transferred out at Sequoyah because at
[21] the time I think they had a vacancy because they pq had a person left a year ago and they had a
- 23] vacancy.
124]
You know, I didn't get into the
[2A5 specifics of what they had available.They asked Page 40 Page 41
[i] me how would I feel? Would I be opposed, this,
[ that and the other.
Page 42 P1l And I expressed to him, I said, I'm not 141 opposed to anyone, you know, looking at another m opportunity or - you know, because you know what
[61 we're going through.And they were aware of it. I m mean, it was common knowledge what we were going jai through. It was no secret.
Ro So I said - I told them, I said, ci0] I'm not opposed to anything. If any of the pii individuals - it didn't have to be Sam's (l12 position. It could have been Gary position or
[13] Chandra's position or one of the sites had come to
[14] me and said we would - we would like - we would
[is] wonder what you would think about this and would tisj you support it, I would be all for it, you know, if tl17 the individual is for it.
t18]
And when they approached me with that, lig the first thing I did, I went and talked with Sam.
2]
Q: Okay.
121]
A: And I had a direct conversation with pm Sam and I asked Sam, I said, Sam, this is what they r23] asked me and you're probably aware of it because
[24] that was his primary plant that he supported. So m obviously if they're your primary plant, they're[
(25] obviously if they're your primary plant, they're v1] going to want to ask for you, I mean, if you're rA doing a good job for them.
- S Okay. It was like the other-the
(*4 other individuals.You know, I would expect the
[5) same type of relationship and same type of support R from the others.
So I asked Sam pointedly, I said, Sam,
- 8] is - I will support this if this is what you want
- to do. I said don't get me wrong.There's nothing lio] going on that's trying to force you out into 1i ] another position or this would alleviate the 12 problem, this, that and the other because it
[i3] doesn't. I mean, you're welcome to - you know,
[141 whatever spots is left, you'd be interviewing for (is] that. If you want to go out and pursue a position
[is] out at Sequoyah, that's your choice.
1171 I said you let me know what you want to
[IS] do and that's what I'll support, okay, because it's p1o no pressure. It's not a directive I've been given p20] or anything like that, you know.
CDO00 121J And that's - that was with any of ram the people in the group. I - you know, I tried r23 to work as much as I could to try to help people t24] get - you know, my main objective was that
[*2] everybody would have a job after all this. Okay.
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u Jth it V.
Tennessee Valley Authority Ronald 0. Grov.
Tanar~v 20 10(
Page 44 iii And I worked with other people in the organization, (2 Dedra Smith and we had an intern, Trish Landers.
pj You know, I worked. I tried to call other people m43 and we tried to work effectively to see whether 19 there was other options in other organizations.
SQ:
Okay.
m A: So, you know, I didn't mean to belabor 1 that.
m9 0: No. I appreciate that.That's very
[103 helpful information.Thank you.
(11 A: But I just wanted to give you a
[12] background on that particular situation.
(13]
0: Yes.And I appreciate that. Let me tu1 ask a question, though, so that I understand how lis) this works.You're very familiar with how internal 13el things work atTVA and I am not.
(173 This position that Charles Kent and the (18 other man out at Sequoyah approached you about that
[1o9 they said, you know, how about this, how about if (4 we transfer Sam Harvey into this, would (213 MR. MARQUAND: I'll object.That's a rm mischaracterization of his testimony. He said pi transfer Sam Harvey's position.
(241 Q: Transfer Sam Harvey's position.
(5 A: Right.
[1]
Q: I didn't mean to mischaracterize. I M think this is because I don't understand TVA's m procedures.
(41 A: I understand. Right.
Iq Q: If his position were transferred to 16 Sequoyah, would that position still be in your mn budget?
pr A: Well, it would have - it would have p depended upon how it was done. Okay. Now, I lio] wasn't aware - when they approached me, they could ti l have had a slot available for him.
l123 Q: Okay. If a slot were available, would tli' it be in your budget?
14]
A: Well, no, it wouldn't be in my - see, i1s] it was two ways.They could have had a vacant (163 position. Okay.That's one thing.They could
[1T] have - it could have been - I know they did ltel have - they had a position at one time and the (193 person left and they didn't fill it.
In I didn't know - I don't know and you'd
"-13 have to talk with their human resource people A whether that position was still being carried in gta their budget or not. I don't know that. Okay.
1241 If they didn't and then if you were r2 willing to - the other way a position would be Page 45 mij created is you've got a function that supported the rA site and you wanted to transfer that function to pi the site, you would have to transfer that head
[41 count and that budgeted piece to the site for that t9 year.And then in subsequent years the site would 161 have to agree to - you know, we'd be happy to add m it to their head count and they would have to
- budget it into their proposed budget for the 1 upcoming year.
[101 0: Okay. I'm trying just to
[113 A: So my understanding is it could have
[1*] been, you know, looked at in two different ways.
(13] Okay.
(143 Q: Okay.
(is5 A: But
[16]
0: And either way, however, it would have
[t1 reduced your head count.
[1e8 A: Oh, correct.Well, in the standpoint
[193 of-well, if he was vying for a position out (r2 there and they had a position, I would still - the r213 first way if they had a position, vacant position, r42] there at Sequoyah, okay, and they wanted to try to 2] see if they could move him into that position, 1241 okay, whatever the procedure was laid out by HR, if (2s5 it could be done, then the position would still Page e Page 4" (13 functionally stay - the position he would - he m would just leave - leave out of that position that rp was at corporate.
Nq The position would still be there.
m Okay. It would be vacant until it's eliminated.
m Okay.And it would be, you know, if the reorg pi eliminated that position, then it would go away.
m Q: But your dollars spent would go down p) because the dollars spent for his salary would no
[ial longer be attributed to you.
(i1 A: Correct. If they had dollars for that
[12 position or if-if-if-well, either way it
[13] would go down. I would spend it if the dollars
[143 stayed in my budget or if they needed the dollars p15] out there and we transferred it over to their (16 budget, it would still go down.
(t1n 0: Okay. I just wanted to make sure I (183 understood that. Did you ever have a conversation I1ng with Mr. Magrath about this potential transfer of r2 Sam Harvey to Sequoyah?
(21l A: Yes.
CD000 73 pq Q: Tell me about that.
(3 A: WeUl, this is not a normal routine type (243 evolution. I know it's - you know, I was aware t2s] that it's been done before.We move people from Hall & Associates (423)267-4328 (14) Page 44 - Page '
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[ri corporate into site positions and we've transferred r[ people from site into corporate positions. So, you pi know, to my understanding this has been done m4j before.
M And so I guess I was thinking at the iq time he approached me and said, yeah, you know, I tn was thinking that the site would have to initiate m1 this and request it and so forth, but essentially m9 it got back because Wilson had approached me and
[103 said, well, you know, they're waiting on you to
[113 initiate this transfer.
[123 And I said, well, I'm not sure how it's 1131 supposed to be done. So I went and talked with the (14] HR representative at the time, which was Ben lisj Easley, and said, well, Ben, this is what the site
[16] is requesting. How does this - you know, how do
[Fi you do this, you know?
1110 And at the time he had mentioned that,
[19] well, you have to start with a rcquest.A request wo memoz-andum or request letter has to come requesting lij that this, you know, action be taken, okay, be w initiated and then we'd work with HR and follow p)j what the proper procedures are and this sort of 124] thing.
M253 So I went and talked with Tom Magrath l[ about it because, you know, I had told him, I said, 2 well, you know, this is something that the site
- asked me about and they were interested in bringing 14] Sam to the site.
Okay.And I told him I had talked with
( HR about it to get whatever the procedure was and a
- letter of-initiating letter, but the site, you
- know, they wanted me to check and me to probably
- run this by you and see if you are comfortable lo1 with it, you know, supporting this, this attempt or pii just - just what your position is.There's no l12] need in us going through all the groundwork and, t1l you know, he wasn't supportive of it.
1143 So he, you know, responded to me and 15sl said that he didn't - he didn't support moving Sam liel Harvey to the site.
t117 Q: Did he tell you why?
p163 A: Well, he just mentioned that he - he
[19 preferred that he keep Sam down at corporate in the p organization to fill - fill a corporate function.
(213 Okay. So he didn't want him, you know, being pm transferred to the site.
r(l 0: Okay. Did he say anything more about (241 that?
(2]
A: No. He just - he - he - he just Page 49
[1i said he preferred Sam - you know, his choice was M* to have Sam down here fulfilling one of those 13] whatever position would be left, one of the
[4 positions that would be left.
(5)
And so I didn't pursue it anymore.
is6 There was no need to - you know, I mean, that's m what he had stated. So I didn't - you know, we
[8] didn't get into a long discussion or I didn't try
[m to challenge it or anything. I said, well, if
[1o that's what you want, that's - you know, I said
[11] okay.
(12]
You know, I justwent back and
[13] informed Charles Kent and Gordon Rich that - and
[14] also Sam. I said, well, you know, it's - there pIsi was a - you know, I said basically, you knowTom
[is] Magrath doesn't support proceeding in that way with (i1 Sam's - you know, transferring Sam out to the site
[18] because I had to get back to them because they were
[I1] asking me, you know, let's get it going.
(w 0: Sure.
r21]
A: So that's how it ended, you know.
[2 0: Okay. Let me make sure I understand p23 the time line.At the time you had this 124] conversation with Mr. Magrath about Harvey's r[s] potential transfer, had you submitted another plan
[13 for the reduction in your chemistry department by rA then that would have required a reduction of three R positions to two?
(43 A: We probably had. I mean, we - you p know, you understand this kind of went back and i6 forth. It was a number of - number of iterations, m okay, and, you know fis Q: When you say go back and forth, you m mean between you and Magrath?
ti0]
A: Well, yeah. It was - really we - at p1i] the time, you knowTom had mentioned, well, you
[12 know, I want you to - at one of the subsequent (i3] meetings I want RadChem and chemistry to basically
[14l combine - you know, combine this plan and send in
[1s] one plan.So that's what we did.We worked
[i6l together with RadChem and combined it with the
[173 assumption that - with the understanding that one 1 1l manager would be left and the organization would be
[19] combined into one group.
CDO00774 20 So I worked in conjunction with Wilson
[21] and his organization and we went through several pm iterations. So it was - this was a part of it. I (23 just can't say, you know, which iteration it was.
[243 We must have went through, you know, six 1[25 iterations, three to six iterations at that time or age 5C I
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lil something like that, you know, trying to get to the
,n end point of where - because, you know, I'm sure
.I Tom was looking at the other organizations and 141 looking at the total dollars and saying, well, 1q you're not there yet. I wanted this or I'd like to Is6 see it - you have this much. So you had a lot of m that going on in the process.
p) 0: Well, I take it from your answer, then, p that the initial plan that we had discussed prior, lio prior in your testimony, where you were going to p1] get about a 17 percent reduction in the next fiscal
[12] year was rejected by Mr. Magrath.
1131 A: Correct.
1141 Q: And so you had to come up with another lis] plan; is that right?
[i]
A: Yeah.Well, at the time then he - he
[17] looked at it and he made a decision, well, I want
[Is] the entire - you know, we can get it down to 40
[19] percent now.
20 0: Now meaning the next fiscal year?
[21]
A: Right. 1997. Let's do that.You
[22] know, he - he made the decision to eliminate the
[23 environmental function completely out of the r24] organization.Well, at the time - you know, at the time we were going through this he'd say I want F
[1] to move all environmental functions and budgets to rA the sites.And so we don't need a - we don't have pl a need for the environmental function.
14] Q: Okay.
M A: So try to get it down, force it down as 1q much as you can for fiscal year '97.
(7]
0: So basically what he wanted was the
- a entire several year 40 percent reduction done in pl the next fiscal year?
[lo]
A: Yeah. I mean, that's - that's ii] his - that's his prerogative. So he chose to, you 112] know
[1M 0: Were there any other groups under (143 Mr. Magrath that were required to meet the 40 (1s) percent reduction goal in the next fiscal year?
[ie]
A: Not that I'm aware of.
[1,7 0: Okay. In order to meet this 40 percent
[la] reduction mandate by Mr. Magrath, did you have to
[19] reduce the number of positions, the chemistry r0 positions, to two from three?
A: Yes.
0: Was Mr. Magrath involved in how those
[23 positions - the decision about how those positions
[24] would be defined?
[2]
A: Well, he gave direction. I mean, he Page 52 sage 53 Page 54 ril wanted to - he specifically said that he wanted rM one BWR - you know, one BWR specialist and one PWR pi specialist for the two remaining positions.
t4]
0: Okay.
m A: Now, I'm calling specialists
[6] chemnistry.You know, in other words, you - your m specialty area is BWR chemistry and your specialty rsl area is PWR chemistry respectively.
m 0: Did Mr. Harvey have expertise in BWR lioj chemistry?
(11]
A: He did a little. He worked a little
[i2] bit in the BWR side, but his primary expertise is
[13] in PWR chemistry. Very little - he'd done - he's
[14] done some work at Brown's Ferry, but very little.
lisj But as far as from an expertise standpoint, his
[(is expertise lied in the
[i7i 0: Primarily FWR?
[iaj A: Primarily PWR chemistry.
[19]
Q: And Mr. Fiser's expertise, how would 20 you characterize it?
t21]
A: It was primarily PWR.
im Q: Okay.
r3]
A: Again, he did probably comparative
[24] from a comparative standpoint, he did more on the
[25] BWR side, but his primarily expertise was PWR.
Page 55
[1]
Q: And Mr. Chandra?
- r.
A: He - he - he was - well, if I P] correctly categorize him, he was proficient in 141 both, okay, but he - because of his extensive tm experience in the BWR side, he was more toward m the BWR. In other words, all BWR issues went t through - was really addressed by, you know,
- 8] Mr. Chandra as opposed to the others.That was
- his - his primary assignment was Brown's Ferry,
[10] which was a BWR plant.
f111 Q: Did Mr. Magrath give you any li2] explanation or share with you his reasoning in i1] wanting to divide the chemistry specialists into (14] PWR and BWK?
[1s]
A: Well, he just mentioned - he just
[i6] stated that that's what he felt that it should
[17] be structured, I mean, to have one - if we're
[18] going down to two people, have one in the BWR side
[(19 and one in the PWR side, you know, just as 20 specialists. I mean, that's what he stated to me, t21] he shared with me.We didn't get into a long, pq drawn out discussion or in-depth discussion on his m3] reasoning.
CD000775 r2]
Now, support-wise, you know, it's not t25] balanced because you've got one BWR site and you've HaIl & AssocIates (423)267-4328 Min-U-Script (16) Page 52-Page 5 Mitt-U-Scripft (16) Page 52 - Page 5 I
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Tennessee Valley Authority Page III got two PWR sites. So it wasn't a direct, you r know, balance in workload, per se, from a site t3) standpoint. Okay.
141 0: Okay.Was Mr. Magrath involved in 15] drafting the new job descriptions?
on A: He was involved with the review.We M we - well, our organization, our group, our entire Pa group, had input on the new PDs.We initiated the m chemistry PD. And also, you know, the (lW environmental piece that went over to Bad Waste, an 1t 1 environmental person was able to review that 121 portion of it, you know, that position description, 113] but we put it together and essentially, you know,
[t4) submitted it for his concurrence.
[is]
0: Okay.And so when you said your group
[isi had input in it, then Mr. Harvey and Mr. Chandra (17) and Mr. Fiser also had an opportunity to review the tisj position descriptions?
[10]
A: Correct.
tq 0: Okay.And they each had an opportunity i21] to offer input?
w A: Correct.All of them had comments and r23i everyone submitted their comments and they were all
[24) incorporated.And we had - we've had - we had r4 several meetings on it and, you know, got Page 57 n) everyone's concurrence that - you know, that m2 wanted input, you know, that had input.And (3] everybody had some - you know, had - had some
[4) comments.
m 0: Was Ben Easley involved in the creation tr or drafting of that position description?
m A: He wasn't involved in the drafting. He P8 was involved from a human resources standpoint and p he had to - you know, we had to submit the PDs (10] through HR and they had to review them and make
[1q sure they were consistent.You know, whatever HR's
[12] function.
[13)
Now, I didn't mean that in a negative
[14) sense. I mean, but they look at it and make sure gps we got the - like the dimensions right and the lIa) purpose right and, you know, it's consistent. It's (17l not too wordy and we're - you know, we meet the
[a] format from that standpoint.
lie]
And if there's something there that rq they don't understand, they ask for clarification (21) and they give us - you know, they provide good
= feedback if we're too wordy or we got too many r3] accountabilities, we'll combine some of that. So, 124) no, they provide us good feedback on, you know, r2q well, you're kind of off base on this or this seems I1]
A: Well, there was discussions on how to m go about - the right way in going about p] transitioning from where you are now to where 14' you're reducing to. Okay.And that - this is my
[5 understanding and what I've been exposed to in my E6] experience here up to this point on how the process m7 should work from a procedural standpoint based on pq what you're trying to do.
M You know, there's a - there's a 10] certain percentage. If you're creating a new
[1] position, there's a - there's a basis for saying
[p2 that, okay, we're going to reorganize and we're 113] going to change some functions around.There's a
[1*] basis for when you have to create a new position (is] description, when you don't have to create a new
[IS] position description, when you - and as I (17 understand it, and I'm saying this to lead up to (ie] your question, that when - say if you're going to
[i9] change organization and you got five people in your (W organization and you're going to reduce it down to (21) three, but the functions stay the same. Okay.
pm Functionally they've got certain position p descriptions, but you've just got to reduce two (24] people.
CD000776 r(5 Well, as I understand it, the way it's age 59 Hall & Associates (423)267-4328 (17) Page 56 - Page 5 Ronald 0. Grove January 29, 199:
Page 56
[1 redundant.
M So we'll take that input, those (3] comments back, but as far as the technical content
[4) of it, we have to do that.
R Now, they'll help us put us in a
[6s right - package it right so it - you know, it m makes sense and all, you know, the positions and m all this stuff is filled out correctly.
Im 0: Let's take a step backward in time ii* prior to the creation of the position description v11q and whatever input that Mr. Easley may have had in
[1t2 that.Was Mr. Easley consulted about the decision
[13] to create new positions and to post them?
[14)
A: Yes. I'm sure. He was very involved
[1s] with all this - the entire reorganization effort.
[Is] And he's had - he had several conversations with
[l17 Wilson McArthur and Tom Magrath, you know, because i1s] they have to work closely with the - with the
[191 responsible manager in this whole evolution to make w] sure - you know, and that's my experience from 1211 before. I mean, they work with them closely to r] make sure it's being done the right way.
(3 0: In this instance are you aware of any 124] objections that Mr. Easley may have had to the t2s5 process of posting this position to begin with?
p Min-U-Scsipta
S,...~
jl
%*L A-.. riSer V.
Tennessee Valley Authority Ronald o. Grove Thn12v-r
'0 100' v] supposed to work is if you're not changing the mi position description, you don't go through a mi reposting or this, that and the other.You go on M14 seniority. Okay.
pi Q: Is that called rollover?
i6m A: I don't know what the term is.
0: All right. Go ahead.
A: But it's based on seniority because you
- 9 didn't change the - you didn't change the job.
[iol You didn't change the job function, this, that and pii] the other.
[12]
Now, if you combine several functions j13a and you redid the job description and if it changed j14] by, I believe, 15 percent or so to - you know, l1s] which is considered a significant amount or l16] whatever, then if it's changed by a significant
[i7] amount, now, they may be able to correct me on the 1al percentage, I believe it was 15 percent of the 19] original position description, then you're required tp0 to post the position and rehire - and rehire in, r21] you know, bid it and rehire in.
tm 0: Okay.
p]
A: Okay. So there was some discussion I r241 know back and forth as to which category this
,si would - you know, what you're trying to do, what Page 60 Page 61
[1] would that fit into, you know.And so I know Ben r Easley had some discussion back and forth with Tom p] and this, that and the other. So it was 141 discussions and it wasn't totally clear, at least I5 to me at the time, I mean, which way was the best m way to go, but the decision was ultimately made to 17] modify the job description this way and repost the
] positions.
pq 0: Okay. Do you know what Mr. Easley's l10] position was on that?
(11]
A: Well, his position was that - like I p23 basically said, his position was if-and he was p3l basically going on the HR policy at the time. If
[14] the
[15]
0: Let me ask you a more specific
[1e] question.
[17]
A: Okay.
(18]
MR. MARQUAND: Well, let him finish.
[19]
A: Yeah. Can I - let me
[20]
0: Go ahead.
A: His position was this: If the position description for the new positions didn't change r[] significantly by that 15 - I believe it's 15
[241 let's use 15 percent for working purposes now. I
[5 may be off on that. But if it didn't change
[i] significantly, then you don't - you basically m don't - aren't required to post it and you go on 131 seniority.
14j If the functions change significantly m and you rewrote the job description, then you post
[6] the job and - and competitive bid it and so m forth. Okay.That's what his position was. I p mean, he was following what the guidelines - what R the guidelines were at the time. Okay.
li1]
0: Did Mr. Easley conclude that this was a (11] job that did not have to be posted based on those
[121 criteria?
[1a3 A: Well, I can only say that he voiced 14] sentiment in that direction. Now, again, I don't
[1s] know what the final conclusion of it for HR. Maybe
[16] he got with Tom Magrath and just - you know, and t17l whoever was working with Magrath at the time or (is] whatever and they made that decision to go ahead
[19] and pursue this and post it. Okay. I can only t20] follow what was decided and - to proceed on.
12ij Q: Well, we know what the ultimate pq decision was.
p2]
A: I know he expressed sentiments that r24] this should be - it should meet one category or rA2 the other. So if it didn't change by 15 percent, p1] it should go on seniority. Okay.
M (Thereupon, an off-the-record pi1 discussion was held.)
[41 A: Did I answer your question?
R5] Q: You did.
A: Okay.
0: I think. Did you ever have a xsj conversation with Ben Easley about his sentiment as
] you described it?
- 10]
A: We talked. I mean, we talked all the
[ji] time during this - during this - you know, during p2] this period about 1m Q: So it's in those conversations that he 1141 expressed his sentiment that this may not be a
[1s5 position that needed to be posted?
t16 A: Yeah. Now, I'm calling it sentiment,
[17] but he was expressing a requirement to me.And he pal said based on his assessment of it, you know,
[I1] that's the way he felt about it.And, you know, he
[20] doesn't have the final decision, but, I mean 1211 Q: Sure.
n A: - that's the way he felt about it.
CDOOO0 23 Q: Okay.
r24]
A: And so it may have beenTom Magrath's psi ultimate decision to which way he wanted to go on Page 62 Page 63 7;77 Hall & Associates (423)267-4328 (18) Page 60 - Page 6?
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Va JAe y AAt hoArit V.
Tennessee Valley Authority Ronald o. Grover Janizary 29, 199,9 JaurI2,19 Ill it, this, that and the other, you know. So we r[ just - whatever decision was made, that's what we pi had to follow.
t4]
Q: Let's move forward a little bit more in 19 the process, then. Once the position is posted, t8] then people, as you descritied before, can rj competitively bid for it, be interviewed for it; is pi that right?
R A: Yes.
[t0]
Q: And a selection board is formed to Iiii interview the candidates; is that correct?
[121 A: Correct.
a131 0: Okay. Did you have any input into who pj4] was on that selection board?
[18]
A: No.
(is]
0: Okay. By that time, by the time that
[1i selection board, and I'm referring to the selection
[18] board for
[p9 A: For the pq 0: - the position Gary Fiser bid for, of (213 course, had your position been eliminated?
=2 A: Yes.
p23 Q: Okay.
t24]
A: Uh-huh.
ias Q: Are you aware of who was on the mi1 selection board for Mr. Fiser's m
A: Yes.
R 0: All right.Who made the determination
[4] of who was going to be on that board?
M A: I think it was, you know, between 1q Wilson McArthur and Tom Magrath.They made the In decision on who they invited for the board process.
0: Who was it initially?
- q A: If I recall correctly, Charles Kent, 10] which is Bad chemistry manager at Sequoyah;John 1ii Correy, which is Bad chemistry manager at Brown's i12] Ferry; and they did not have a Watts Bar plant
[I1] representative to my understanding.They had Rick
[i4] Rogers, which was the - he was in the technical
[15] support group here at corporate. I think he stood t[i] in as the third member representative from the
[17] plant - for the plant's standpoint.
[1]
Q: Who Il]
A: I believe Wilson sat in on it and I 20 think Ben was a part of it, as well, Ben Easley.
(21]
0: Mr. Rogers' background, is he in n chemistry?
12]
A: No. He was in the technical support.
[241 He was in the maintenance technical support.
tp Q: What would that have made his Page 64 Page 65
['1 background, engineering?
[
A: Primarily engineering.
p1 Q: Why
[4]
A: Now, I don't know - you know, I don't
[q know whether he's - he had a degree. I can't tell
[8] you from an educational standpoint. I can only I tell you what capacity he was functioning in at the
[8 time.
m 0: Sure.Who would have been the Watts p10] Bar representative had there been one on this (iii selection board?
[12]
MR. MARQUAND: Objection. Calls for t13] speculation.
[14]
0: If you know.
[isi A: Well, if you wanted to - if you're
[*1] looking at it from equal representation, you
[17 would - you would want the RadChem manager at 8is]
Watts Bar.That way they're all - you know, you
[1% got peers.You got like peers there.
2m Q: Who would that be?
1211 A: It would have been Jack Cox, but, you
= know, sometimes you can't - for various reasons, n for whatever in selection processes, that may not t24] always work out because of scheduling or whatever, 24 so - but that's what you would like even if-you
[1] know, when I sat in on selection boards, you know, m2 I always tried to get - would ask for like Pi representation at like levels so that, you know,
[14 you get the same perspective and the same
] viewpoints.You know, you're looking at it from t6] the same level and that sort of thing.
m 0: Okay. Do you know whetherJack Cox Pq was - it was ever discussed with him about serving R9 on the selection board?
Iioj A: Yes, it was.Yeah, it was discussed.
[ii] Wilson McArthur had informed me that it was
[12 discussed with him.You know, they had asked him,
[l3i you know, about it.
p4]
0: Did he have a conflict?
[isl A: He approached me and asked me - huh?
[is]
0: Did he have a conflict that day?
[1p]
A: Yeah. I don't know what the reason
[18] was, you know. And we - in fact, we were up - he
[9l] had asked - Ben was - Easley was - Ben and
[w0 Ben and I were talking about something and Wilson 121] called us over and said, well, here. Here's the
[22] selection process or his board lineup and for some M* reason he couldn't get Jack Cox.And, you know, he p4] had mentioned that to us while we were there
- m talking.
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AA-A aJIc,atIcr 01 (yary IL Fiser V.
Tennessee Valley Authority Ronald 0. Grove, Tanuarvy 20. 1 QQrý lil Q: Did they attempt to reschedule it to
,accommodate Mr. Cox's schedule?
A: Not that I'm aware of. I don't know 141 what the conflict was or what. I - you know, I psi wasn't privy to that.You know, not to - not that lel I'm aware of. I know they had it scheduled and m then the conflict came up.And I don't know
[8 whether the urgency to proceed on with the jj selection process had to take place or what.
ti0]
Q: Okay.Are you aware of any 1"] participation by Mr. Magrath in the scheduling or p2] composition of that board?
p3]
A: Well, again, he may have. I don't, you (14] know
[1s]
Q: I'm asking for your knowledge.
(i1]
A: Yeah.Yeah. It wasn't - he didn't (i17 communicate to me directly. He may have been lie] involved with it with Wilson. I don't know.
tie]
Q: Okay. Did you get any knowledge 120 indirectly about his participation in this
[21] selection or the scheduling of that selection rm board?
pq A: No. Other than he - you know, he 1241 wanted it to happen. He wanted it to move forward and happen as soon as possible.That's - you m] know, that's the only thing I heard through Wilson, rA you know, that he wanted to pursue it and move (3] ahead with it, but other than that, no.
14j Q: Now, Mr. Charles Kent, we've talked M about him before. He's the person who had
[8] approached you about getting Sam Harvey transferred p6 to 2 position at Sequoyah; is that correct?
m A: Yes.
p 0: Okay.And Mr. Correy; is that right?
lioj A: Uh-huh.
111]
0: Correy worked at Brown's Ferry.Was p1l Mr. Chandra the principal person, chemistry 13] specialist (14l A: Yes.
lis3 0: - who helped him out lsi A: Yes.
(173 Q: - at Brown's Ferry?
[i1] So there was no one on the selection
[iol board who had worked for any significant length of t20 time with Mr. Fiser, was there?
MR. MARQUAND: Objection. Lack of
.jundation.You can answer, if you know.
(233 A: Not directly, no, unless they had some
[24] prior work relationship that I wasn't aware of
[] with, you know, Mr. Fiser prior to me coming to Page 68 Page 69 ii] TVA, but not that I was aware of. Not since I've 2 been at TVA, no, they didn't.
pij Q: All right. If you want to take a break t4] so you can answer your page.
"m A: Oh, okay.
(Thereupon, a brief recess was taken.)
M BY MS. JONES:
p 0: Before we leave the selection process m topic, there are a few follow-up questions I needed
[io~ to ask you about procedure because you have both viit interviewed with a selection board and been on a
[12] selection board in your experience at TVA; is that 113) right?
v14]
A: Yes.
15si Q: Is it your understanding that the t16] selection board is supposed to review the
[17i candidate's most recent performance appraisals as l1s] part of its determination?
119]
A: The application for a position requires jro] that you attach the most recent service review to 1211 it. Okay.That's part of the application
= process.And that package goes with the booklets
[-3 made up for the selection process.
[24]
0: Okay. So it's available to the board r2 members.
Page 70 Page 71
[13 A: Yeah.You have the application.You 12 have this - the person's most recent performance r* review. So you have that basic information to 143 review and, you know, you've got information on p the - his educational background, what he's been i8 doing, his current position, that sort of thing.
p' So that's part of the basic information.
m8 0: And when you were on the selection m board, did you review that most recent performance
- 1o0 appraisal
[113 A: On the boards that I (123 Q: On which you served.
[13 A: Yes. Uh-huh.
(1%]
Q: When the process is ended and all the
[5si numbers are tabulated and totaled, in the (i8] particular selection that we're talking about here, p73 Mr. Chandra came out the winner for both positions,
[IlS is that right, BWR and PWIR
[19 MR. MARQUAND: I'm going to object to
,0 lack of foundation. Mr. Grover - and also - I l213 mean, he's already said by the time the board met, rM he wasn't in his job, neither was he on the board.
pq 0: Are you aware of what the end result of r241 the selection process was?
CD 00779 rim A: Yes.
(25]
A: Yes.
Hall & Associates (423)267-4328 (20) Page 68 - Page 71 Min-U-Scripts
TneL 'ee Vy A.
tri~ty-V.
Tennessee valley Authority Ronald 0. Grove Jranuary 2a 1 con V)] 0: Are you aware that Mr. Chandra came out m the high scorer for both the PWR and BWR positions?
ri A: Yes.
14 0: When that happens in a selection
- 5 process, is it your understanding that the
- candidate who is the winner may choose which of p* those two positions he wants?
tal A: Well, I don't know if there's a human m9 resource direction on that.
1101 0: I'm asking for your understanding.
fil A: Well, I would think it would work ti2l out - it would be based on the interaction between
[131 the hiring manager and the candidate.You know, 114] the hiring manager has a right if-the board may
[isl select a certain individual and, now, if the hiring tiel manager doesn't want to hire that individual, then i17] the hiring manager says, well, I want to look at ils some more candidates or whatever. I think - you (19] know, it's my understanding they have got that 2] option.
1211 So it's up to the hiring - you know, pm the hiring manager's discretion whether they wanted pq to ask the hiring manager which position you wanted (24] or I'm looking to get you to fill this - you know, p25 this particular position.
V1)
So I don't know what transpired between
- the hiring manager, which is Mr.Wilson McArthur,
- and Chandra. I don't know, you know, whether, you 141 know, he - I wasn't there when the discussion took Im place.
16 Okay.Again, I only was - I guess it ln was - I had gotten feedback that, you know, he had 181 an option. He was given a choice. Okay.Again, I m wasn't there when it took place, so I can't say, pal you know, factually that this, that and the other.
iii] That's the feedback I got.You'll have to talk (13 with those individuals, but I would have had the (13 understanding that he was given a choice between (14 the two positions.
[1is 0: Okay.And obviously you've been away lie) for a while at IN'PO, but I'm sure have kept up with
[in folks back here atTVA because you remained aTVA rlil employee that entire time; right?
npi A: Right. Right.
rW Q: Are you aware of changes in the c21] chemistry department or however it's now called, pm chemistry RadChem combined department, after this pm selection process was completed?
2l4 A: Am I aware of any changes in the A
0: Yes. Let me be a little bit more Paae 72 Page 73
[ij specific here.
m A: Yeah.
t3]
0: Are there still two chemistry
- 4 specialist positions in the combined departments?
A: Yes.As far as I know, yes.
0: Are they still denominated PWR and BWR?
7 A: Yes.
m 0: Okay.And are there still only two?
L A: Yes.
[10]
Q: Okay.
[11]
A: As far as I'm aware.
j1ig 0: Right.That's all you can answer to.
[ial And you were Mr. Fiser's supervisor
[141 when his latest performance appraisal was done; is p1si that right?That would be '95.
pl A: The last annual one I did for him (17 was - was, yes, 1995, fiscal year 1995.And we
[18] did quarterly reviews, as well. So the last actual (i1 assessment probably was the - what, the first pq probably the first quarter of 1996. 1 think it was 12i1 somewhere in that time frame.
S(Thereupon, the Performance Review and
[23 Development Plan for Gary L. Fiser was marked
[24] Exhibit No. 3 to the deposition of Mr. Grover (m and filed herein.)
Page 75 (I]
BY MS. JONES:
m* 0: You've been handed a document that's R been labeled as Plaintiff's Exhibit 3 which is the 141 annual performance appraisal for Gary Fiser for the
[5 time period 10-1-94 to 9-30-95.Turn to the last
- s page of that document where it asks for the m supervisor's signature. Is that your signature?
m A: Yes.
m 0: Okay. Obviously this is a multi-page
[10] document with many entries, but overall would you
[11] rate Mr. Fiser as someone who was weak in
[112 management or leadership skills?
[13]
A: No.
[143 0: Would you characterize this performance lisi appraisal as a good one?
[10)
A: Yes. It was a good performance review
[17 when you look at, you know, the overall rating.
(Ia] The way this is structured on a point basis and (19] discussion, it was a good review.
[20 0: Okay.And, in fact, when you were out
[21] on leave or had to be absent, you frequently pm appointed Gary as acting manager in.tdrmmen.
(23 isn't that right?
t
,UU UgCMJ
[241 A: Yes.Along with - you know, he wasn't (25) the only one that was appointed. Chandra served in Hall & Associates (423)267-4328 (21) Page 72 - Page 7 I
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In the matter of Gary L Fiser v.
Tennessee Valley Authority Ronald 0. Grovf Tanuarv 20 1 QC jin that capacity and, I think, Sam served on one or "2 two maybe occasions or - but he was - yeah. He mj served frequently in that capacity.
141 0: And by he then you're referring to iq Gary.
m A: Gary Fiser, yes.
mq 0: Did you help put the questions together isi that would be asked of all the candidates in the Im selection process?
)io A: I'm trying to think whether I was t*il I didn't physically put the questions together. If tul I - you know, I'm going on recollection here. I t131 think I was asked to review orWilson had asked me t14] for some questions that would be good questions to l1s5 ask, if I recall correctly. Okay. But I never did 11m review the entire list or give a sign of approval, ji~t that sort of thing. If I recall correctly, Wilson 1181 did ask for my input on what would be some jig9 questions to ask.
Wio (Thereupon, the Questions for Program Manager 121] Chemistry was marked Exhibit No. 4 to the rM deposition of Mr. Grover and filed herein.)
Page 76 BY MS. JONES:
- s 0: You have been handed a two-page Page 77
!il document which are the questions that have been r4 produced to us by Mr. Marquand as those being asked p] in this selection process.There are a lot of 141 handwritten notes here by whoever took these notes,
- 5 but I'm most interested in focusing in on the
- questions that were asked. So I'll give you an m opportunity to review those right now.
mi A: Okay.
M] Q: Do you see any of your questions there?
pol A: Well, again, I - you know, I don't tll specifically recall putting together, you know, (i12 these and, you know, say, okay, I submit these four pal questions here, this, that and the other.
t141 One thing I - I - there would be jtsl there are questions - I would say that there are pal questions on here that I would - you know, that I li7 would see - could see asking of the candidates.
lie]
Q: Okay.That wasn't my question.
olg A: Would you - do I see 201 Q: My question is do you - you had indicated before that you made a few suggestions of questions
'-ai A: Right.
p*!
0: - to Wilson McArthur, is that right?
r4 A: Right.
jii MR. MARQUAND: I think the testimony
[m was he had input.
p1 A: Yeah. I had input. I don't - and I l4) don't m
0: Do you remember specifically what you tel suggested to be asked?
m A: No.
1m Q: All right.
mg A: No.
(10]
Q: All right.
miij A: But I can look at here and tell you
[12) what - you know, there's obviously others on here ciaj that I didn't specifically, you know, request to be
- 14) asked.
11sj 0: Sure.The position that's being
[161 interviewed for requires a fair amount of i7] expertise, would you agree, in radioanalytical l18]
chemistry?
- lig, A: Say that again.
21 0: Certainly.
12ij A: Can you repeat that question.
rm 0: The position that is being interviewed 1jm for and these questions are being asked of the 124] candidates, that that position requires expertise r2 in radioanalytical chemistry;, is that correct?
ti]
A: Correct.
trj Q: What questions listed here on m Plaintiff's Exhibit 4 pertain to radioanalytical 141 chemistry of the, let's see, 16 typewritten
[5] questions and then there's one identified as 17 tm that's handwritten?
m A: There aren't any questions here that go specifically - that - that is specifically pi directed at a radio chemistry subject area.You jic know, there's no question that's pointed jitj specifically toward a radio chemistry subject area (12l or interest or, you know, issue.
(131 Okay.They're more global in nature.
[14] And, you know, you could get into that based on the l(s1 discussion. How the discussion went on the
[16] selection process, I don't know. I wasn't aware of 1m that.But there's not one specifically as I read l181 this-CDO00781 ji, Q: Okay.
[0 A: - specifically targeted toward that.
[21 0: Are there any questions here that would pm elicit a candidate's experience in that kind of r.31 radiological data interpretation?
t241 A: Well, I could see six if, you know rp or 16, discuss your specific management experience Page 71 Page 79 Hall & AssocIates (423)267-4328 Min-U-Script (22) Pase 76 - Page
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in me mauter of Gary L Fiser v.
Tennessee Valley Authority Ronald 0. Groyt January 29. lcqq Janury 2. 1I
[i] and training, if it would come out in that
[2 particular - under that particular question, but, 131 again, it's more management oriented.
14 0: But the question isn't directed toward
[sl that subject area.
R A: No.You would have to - like I said, m you would - it would have to come out, you know, p3 as one of these - as part of one of these Ms questions here.
[10]
Q: Okay.And, similarly, that's hard to
[l1] say that word, are there any questions here that
[12] would specifically elicit experience or expertise
[13] in radioactive effluence or failed fuel analysis?
[14]
A: Indirectly. I mean, say, number three i1s] there, it would have to come out - you know, it
[1l] would have to come out as part of one of these li7] questions here. I mean clis Q: All right.
[fi]
A: - you know, number three says part of r4 the accountabilities for this position is that of 121] assessments. How do you go about assessing the 1m effectiveness of the program and then to develop Mxi corrective actions for weaknesses? So if you used
[24] that as an example, you know r4 0: So the candidate would have to
[1] volunteer that.
R A: The candidate - the candidate would rs] have to, like I said, bring that up or it would 14] have to be a follow-up question from one of the pl board members to say, okay, here's an example.You 1q had indications of-what would be your Mj indications of a failed fuel condition from a ms chemistry standpoint? So it's not a - you know, pq it's not a direct question in that area.
i101 0: Okay. Were you aware that Mr. Fiser
[11] had filed a complaint in 1993 with the DOL, which
[1i is, of course, prior to your employment with TVA, 1n] but I'm asking were you aware that he had this
[14] prior complaint?
[153 A: Yes.
[is]
0: Did you and he ever discuss that?
i1 A: No.
[1i3 0: How did you become aware of it?
[19]
A: Well, it's just discussions.When I
[20 hired in, you know, I was told, you know, Wilson 21l] and several others, that, you know, this individual rM is coming back. He went through this ordeal, this n complaint and so forth, and it's been - you know, (24] it's been settled and the individual is coming back 125] to this particular position.
Page 80 Page 81
[1]
Okay.And others talk. I mean, the
[ other - well, they say, you know, well, here's pi what he went through, this, that and the other. So 14] it was mostly input from the work force and, you
[q know, what had transpired, this, that and the
[6] other.
M Again, I have no file case or written, pq you know, deposition or something. I didn't read m3 up on it. I didn't - it wasn't a case file or a
[1*] case history that I pulled off the shelf and read pi] up on it.
[12]
Q: Yes.Just general talk?
[13]
A: Yeah.And I didn't - I didn't discuss
[14] it with Gary. I mean, we - I knew it was a - you
[1s] know, he had went through this, that and the other,
[1s] but I just felt it wasn't my place. I mean, that
[Ip] happened before I come here and it's really - you pisl know, it's irrelevant to what - what goes on now,
[19] I mean, you know, from that point on.
[2w] Q: From your point of view in managing f21] him.
p A: Yeah. I had no - yeah. It was not
[23] I felt it was not my place to get into that, what r241 happened in the past, I mean, you know.
r25 0: But the person who informed you of this Page 8:
Page a.
vi was Wilson McArthur, is that right?
rg A: Well,Wilson and others.Wilson had ri mentioned it to me because I worked for him and
[4] he gave me some background on what - you know,
" what - you know, because I didn't know what was
"[ going on and, you know, why the position - because "r7 I thought we were going to post the position and "is move forward or go look outside and that sort of p] thing.And he mentioned to me what was - you pal1 know, what was in process and what was being worked
[1 q out, that sort of thing.
[12 0: How about Mr. Magrath, did you and he
[1] ever have a discussion about Mr. Fiser's prior (14] whistle blower complaint?
[l5]
A: No.
[1i]
Q: Did he ever indicate to you that he was
[17] aware of that?
[1l]
A: No.
[19]
0: Let's look at the knowledge of the cro] selection board folks. Did you ever have a t21] conversation with Charles Kent or otherwise aware r[m of any knowledge he may have had of Gary prior 23 complaint?
CD000782
[241 A: No.
r24]
0: How aboutJohn Correy?
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Te-e sJe V al l-e-Ahrit V.
Tennessee Valley Authority Ronald 0. Grovw Tann~r2Q 1I Page 84
[v1 A: No.
M2 Q: Rick Rogers?
31 A: No.
]i 0: At the time the selection board met
" let me back up a moment.When did you become aware "rs that Gary Fiser had filed a second complaint?
"r7 A: It was - if I recall correctly, it was
" like right around that time frame or right after "t9 the board met. I can't recall the exact, you know,
[10] date when - you know, when I became aware that he tp i did file, you know, a complaint on it.
[p2 0: Do you remember how you became aware of
[13] It?
114] A: Well, we - it must have been in one of lis! our discussions. I mean, we discussed it.
liil 0: From Gary himself?
(17]
A: Yeah, from Gary hisself.You know, he
[18] had voiced a lot of concerns and, you know, he had
[19] stated that he's proceeding on with filing a
[0 complaint, you know.And so that's each
[21] individual's right and prerogative.
rM 0: Sure. So this was when you were still r2] there in a managerial position with him, is that 124 right
,i A: Well-
[pi 0: - that he let you know that he was r2 upset and he was going to file a complaint?
pi A: Yeah. But, I mean, again, it was 141 and I can't with all this - you know, I can't p] remember the time - the exact time frame, you
[6 know. I probably wasn't in that capacity to be r3 I wasn't his direct manager at the time, you know.
pn I'm thinking it happened around that selection p process, that sort of thing, you know, right 10 afterwards and, obviously, Wilson was the manager
[1 q of the organization at the time. So I knew it was p12] somewhere in that time frame, but, I mean, he t1l expressed his concerns and sentiments, you know.
[*4l Q: Did he make it generally known in the 11si workplace that he had filed a complaint?
1163 A: Not that I'm aware of. I mean, he
[17l didn't go around broadcasting it.You know, he pal didn't put it on the Internet, you know. So I
[p9 don't think he did, you know.
(20 Q: Did you ever A: And I don't know who - who he discussed it with. I know he discussed it with me ral and I kept - you know, I always kept those type of 2l4 things confidential.
r2s]
0: Did anyone else discuss it with you?
Page 85
[V]
A: That he had filed a complaint?
m 0: Yes.
mJ A: No.
[4]
MR. MARQUAND: Other than counsel and isi the people you've
[6]
A: And, again, counsel and HR, they talked pi to me, but I don't know M
0: Oh, I know there's an investigation pi later, but p10j A: But, see, I don't know whether - see, 11]q I don't know the time. I don't know whether - you pi* know, he didn't give me the paperwork he sent in to 1i3 file the complaint. So I don't know whether he had
[143 discussed it with personnel and personnel came and lis] discussed it with me and the complaint was jiq officially filed. I don't know.
[17]
I'm just - it may have been - they Is] may can tell you exactly when and the sequence of
[19] events, but, you know, I just didn't want to r20] mislead or give you the wrong information that I (2q knew the exact time and date that he did that.
rm 0: Oh, no. No. I didn't mean to imply r23 that.
t241 A: All right.
r4 Q: About when did you leave TVA to go to Page 8 Page 87 li' work for INPO?
- 2 A: September 30th, 1996.1 reported to t* INPO on - yeah. I reported to INPO on the 30th of i4 September.
SQ:
And I think you said at the very pq beginning of this deposition that you were there m for about 15 months; is that right?
M A: Correct.
Im 0: During the time period that you were isol there, were you aware that Mr. Fiser had applied
[1i] for employment with INPO?
[19 A: Yes.
i1]
Q: Okay. Did you talk to Mr. Fiser about (4] that application for employment?
l[s]
A: Yes.
(16]
0: Okay.Were there any statements made pi'j internally at INPO about his application?
piel A: Well, you mean statements like - I
[p9l mean, we had talked and, you know, he had asked po me.And he's got other individuals at INPO that he 12il talked with.And, obviously, I was a loanee. I
[22 wasn't a permanent employee there.
CD0007*83 cM And we just talked in general. He j241 thought what about - you know, what did he think
[2sl about - what I thought about INPO because I was Hall & Associates (423)2674328 Min-U-Script3 (24) Page 84-Page f Hail & Associates (423)267-4328
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r later that he had tried to call and find out when m they was going to schedule it. I got feedback (4] the department director - the departmental manager (q told me they were going to call him in for an (l6 interview.
M' You know, I said, well, that's great, Iaj you know, fine.
M9 He had asked me - you know, asked me (101 for some input for Gary. He was looking at some fil] other candidates, as well. He told me that. He (12] said that - he had told me that he had performed p13] several - we're going to call him in for an
[4,] interview.
1161 I said, well, that's - that's great, (16] you know.
1171 Then sometime later nothing 1i18 transpired. I guess Gary hadn't heard anything.
pol And then it didn't take place and - and I had - I pq had asked one of the other permanent employees (21) because I know they had worked together for a long M period of time and that sort of thing that he had na heard anything or had something happened or this, (24] that and the other.
(26' And basically I heard that the - I
[1]
A: No.Again, I wasn't trying to push him m in the interview.That was strictly the (3i departmental manager's - he called me and asked me
[1 ]what I thought about him and he talked to three or
" four, five other people.
"g* I gave my input and that was - you "m
know, I tried not to get involved. I told him "1 you know, I told him specifically, you know, this
"[u is - that's - that's your process.You know, I'm (101 independent of that.You make your own decisions.
fil] You're looking at other candidates. So don't think
[12] I'm here trying to influence you one way. I'll
[13] just give you what I know, you know, about the titj individual.
(161 0: What was the name of the department
[i1 manager you're referring to here?
(17 A: Chris Hobfoster.
[1s]
0: Chris?
fig]
A: Hobfoster.
CDO00784 20]
Q: Hobfoster.
(211 A: Hobfoster.Again, that feedback I got
= was - like I said, that was - you know, it wasn't (23] directly from an individual or the source or it was (24] just feedback I got from the other people that (f2] worked there.
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in tue matter ot Gary L Fiser v.
Ronald 0. Grove Tennessee Valley Authority January 29, 199 Page 88 Page 9C Ilj down there and my perspective on it as a potential
[ll guess a comment was made that Gary was involved m place to work.And he had talked to others there m with a - let me see if I can remember this p] that he know - you know, that he had long-term
[3] correctly. Something was made to the effect 141 relationships with.
14j that - something was made to the effect that Gary 19 And, you know, I told him, you know, if Is] was having problems with TVA and he had - he was j6] the department manager from the chemistry is) in the middle of a case or something, some type of m standpoint, if he talks to me, you know, if he m employee's - filing employee's concern, that sort pi] wants to talk to me about you, you know, I'll be
[q of thing. Something to that effect, you know.
cm more than happy to tell him our relation - you R
So maybe that - you know, that
[103 know, discuss our relationship, working riol feedback, you know, and it was to the point where I (i¶1 relationship, we've had, that sort of thing (i i] had heard - you know, one of the other, I guess, 112] because, you know, that's what they do.
(12] employees in the group had said I had heard that 113]
They talk to - they try to get input
[13] he's - you know, he's got some problems up there 1U4 from other sources on the candidate that - such (14 and he's - you know, he's got an employee's 15] that they can get some different perspectives, that lisi concern in process or something like that, i6l sort of thing, to make a determination of whether i7l they want to call him in for an interview.
[17] epy s copint.
(11]
And so I think, you know, decisions Is) 0: All right. Did you ever relate to Il8] were made, well, let's - you know, we need to back 19] Mr. Fiser any statements that you had heard that
[19 off. Probably the decision. I'm not saying nobody
- oj TeA had made about Mr. Fiser?
[*
f.Poal h
eiin o aignbd 21]
A: Well, the - he put in the 1so] came to me and told me that, but I'm thinking a 121] decision was made to back off and not pursue him as al application. It was looked at.There were some -
r a potential candidate.That's what I suspect.
mj what I got - I got - initially got some feedback m Oka.
z4] that they were going to call him in for an 124]
0: He never got an interview, did he, at
] interview.
r45 INPO?
Page 89 Page 91 1]
An d then I - then I rec ewived fp,. llrqh~rPa e l I
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A-riser V.
Tennessee Valley Authority Ronald 0. Grove Thi-r JQ I
Vi]
Q: I understand.
"I A: So I - you know, don't quote me as
,I saying, you know, the personnel manager told me 14 that that's why they didn't do it.That didn't is) happen. Okay.
16 Q: Sure.And this what you're calling the
- feedback, this information that Gary was involved (8 in some sort of an employee dispute, who told you M that?
to]
A: A guy by the name ofJim Bates had p ii mentioned that to me.
123 Q: Is he still at INPO?
(1l A: Yes.
114]
0: Is he one of those loaned employees?
lisl A: No. He's a permanent employee.And, p6] again, that's feedback he had gotten and so, you
',7] know, he just shared it with me that that's what he lia] had heard. Okay. Now, he didn't say nIg 0: Did he share with you who he had heard (0 it frorm?
121]
A: Well, he didn't say that because of rzM that information, they made a decision not to bring 1" him in. He said I had heard that that was some t24] negative - some negative information that - that came out.
111 Q: I understand. Did he say who he had M heard it from?
r(3 A: Yes. He said who he had heard it from.
14]
Q: And who was that?
M A: Jim Corbit.
pq Q: Who is Jim Corbit?
rm A: He's an employee there at the - he's pu an evaluator there in the chemistry department, a tI permanent employee.
(10l 0: You say evaluator. Is that a q1] A: That's the position title.You're an (1I evaluator.That's what you - you know, that's (3] what you primarily do.That's the position title, (141 evaluator.
5isl 0: Job description?
pail A: Yeah.Ycah.That's what it's called.
(171 You know, like you're a chemist or a chemical (18] engineer.You're an evaluator.
pal Q: Would Jim Corbit be one of the people pq making an employment decision for the kind of
'>osition Gary was applying for?
A: Well, he would - he may have been
- "33 asked to talk with the person, to talk with the p4] candidate, I'm sure. He's a senior level person.
r5 He's the senior person there and been in the Page 92 Page 93
-I
- organization for a while.
I'm sure their process entails getting r3i] the candidate to talk - you know, lining him up m4 to - setting him up to talk with some of the is] employees that are long standing.
(6]
0: Sure.
m A: You know, and the department head gets ti] that feedback and he makes the decision based on p what he's talked - you know, what his impressions
.10] are and also any other people that have talked with (11] him, he gets that input and he makes the decision.
(121 0: The position that Gary was applying (13] for, would he have reported to Jim Corbit?
(14]
A: No.
pisl 0: Okay.Who would he have reported to?
(16]
A: It would be Chris - the department (17i manager, Chris Hobfoster.
[is]
Q: Does Jim Corbit report to Chris (1] Hobfoster?
20 A: Oh, yes. Uh-huh.
(213 0: Okay.
22 A: Now, again, let me state that's only (m input that I received. Now, it could have been (24] some other reason why. I don't - you know, I M don't want to say that - I don't want to be on Page 9.
Page 9E In record as saying that because they got this m information, they made that decision.They made pm the decision.
141 It could have been some other reason.
m They looked at other candidates. I don't - you m know, I'm just giving you what m
0: What you know.
pq A: - was given to me. So I don't m want you to - I don't want anyone to draw the vioj conclusion that because someone said this or p q that negative input, that was the reason why. I
[121 can't - I can't attest to that, that that was the (1i case or not.
114) 0: Well, when you asked or were talking to p1si Jim Bates about, you know, basically what's the p1o status with Gary, other than this information we've li7l already discussed, did he give you any other pias information about Gary?
12n1 A: No. He just said that was the only rA that was the negative thing he had gotten back 121] about the whole thing.
m 0: Okay. He didn't give you any other rni negative things; did he?
CD000'785 1241 A: No.No.So I just (253 0: Did he give any other positive things?
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[1]
A: Well, you know, the context of the m conversation, I just asked him had he heard m anything.You know, did something go on or did w1 you know, did he hear anything? Was there a
[9 problem because Gary hadn't been contacted.?
- 6 Well, I take that back. Giry was
- contacted by the HR people and they went to - they 1ai were going to - see, that's what the question m was.That's what was puzzling me because they did t10] go ahead and contact him and said we're going to Ii1] set you up for an interview, going to bring you in p13] for an interview.
1131 Q: Okay.
114]
A: And then like more than a week
[1s] transpired and he hadn't heard anything. So he ps] said, well, Ron, is there - what's going - you (17] know, is there something going on or this, that and l(a] the other?
[119 I said I don't know. I just said I r0 you know, I can call up Jim and find out whether 12i] he's heard anything, this, that and the other rm because they usually - you know, when they p23] contacted him, they said we're going to bring you 124j in, you know, here shortly.We'll be contacting 12q you.
V)
But, as I said, they did make contact.
r2i As Gary explained to me, they did make contact with r3] him and said they were going to bring him in for an (4j interview.
[
Q: Okay.
p A: And then the decision was made not to.
m So I - that's the reason why I just - he asked me in and I said, well, let me find out from Jim because m Jim is a longtime employee. He knows how - I tio don't know how the process works or whether it Ii i takes a month after they say they're going to bring tul you in for an interview.
(131 You know, so I just asked him what's
[141 the status or have you heard anything or how long lisl does this take or was there a problem or a glitch?
lis You know, that's the reason why I - I just asked pl him because Gary asked me. I said, man, I thought pi that they were going to contact you by now, you
[W] know.
(20]
Q: Where is INPO located?
121l A: Atlanta, Georgia, the corporate - you pm know, the main headquarters.
(233 Q: Is that where you were?
p4]
A: Yes.
(2sl Q: Is that where Jim Bates and Jim Corbit Page 96 Page 97 mi are?
m A: Yes.
r3]
0: Okay. Let's move back in time.
[4]
A: Okay.
m5 0: Back to the - prior to the creation of (6] the selection board for the position that Gary lost m7 out on. Did you ever get any information that Sam
[8] Harvey was preselected for that position?
m A: Well, when you say did I get any p10 information he was pre - I didn't get anything in pi] writing that said that he was - no one came to me 12] directly and said that Sam is going into that
[13] position, no. Not from that standpoint, no, I
[*4] didn't get any information.
1is5 Q: Nothing in writing, nothing directly tI*6 from any person.Anything indirectly that would
[p1] indicate that Mr. Harvey had been selected or I1] designated as the winner prior to the selection (191 process even taking place?
[20]
A: Well, it was something that was - it
[r21 was a conversation that I had with Dave Volar. I r think I mentioned this to you - I think I (2] mentioned it earlier in our discussion.
[24]
And I don't - again, I don't know how w25 this transpired, but what was told to me by Dave F
Pi
- 1 Volar was the fact that Sam had went up there at
- some point in time and said pj 0: Sam Harvey?
141 A: Sam Harvey went up and had a little v meeting session with Dave Volar and, I guess, in pn the course of the conversation told Dave that he m was up here because he wanted to, you know, kind
[81 of get reoriented with Dave because he's going to me be - you know, once this reorganization is
[10] finished, he's going to be working directly for li] supporting Dave and words to that effect, that (13] basically he'll be - you know, he's looking to be (13] in that position and so forth.
1141 And, I guess, they had discussion back
[15] and forth and Dave didn't know, well - you know, l16] you'll have to talk to Dave Volar to find out the p17] actual words that was said, but to the effect
[18j 0: And I plan to, but what I'm asking for
[19] right now is your memory of what Mr. Volar told 0 you.
r21]
A: Well, and then Dave was concerned and rm he called me. I was -
CDO007S6 rz3 0: Why was Dave concerned?
124]
A: Well, he was concerned from the A25 standpoint, well, he thought they was going through Hall & Associates (423)267-4328 Min-U-Script
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in me matter of Gary L Fiser v.
Tennessee Valley Authority Ronald 0. Grove, Tarniarv2Q~ 1 aor Page 100
[1] a selection process. I mean, just Sam would have M to go through a selection process just like m -everybody else.And I guess he's gotten - he's 141 getting input that, you know, this was already m made - you know, the decision was already made.
tp Q: A done deal.
m A: Yeah. So we had talked because, you l8] know, I had heard feedback and then we were trying 191 to get - so he called me.And I can't remember.
p0] We're missing - playing phone tag or whatever, but p i] he called me, I called him or I can't remember who p2] got ahold of who first, but he had stated that this I13 was what transpired.
[14 And I said, well, as far as I know, (is] Dave, you know, they've got - they're still going I1s] through the selection process unless somebody made Ii-] a decision and didn't tell me about it, you know.
li8]
So I wouldn't - you know, I wouldn't (isj personally put stock in it from the standpoint of p20] it's a done deal and the decision was made to go 121) another way.We still - as far as I know and as r224 far as the HR people told me, we're still going 2l] through the process.
124]
So I told him that that's the way I'm s] proceeding with this as far as my participation is Page 101
[] concerned.And I can't - you know, I can't attest m to what - that statement he made to you, you pi know.You know, unless something - some decision m4] was made that I wasn't aware of, this is the tq direction we're still going with this.
[6l 0: Well, it was your feeling from talking m to Mr. Volar that Sam Harvey had led him to believe pi otherwise.
pq A: Correct.
11o]
0: Okay. Let's move even further back in
[11] time to the discussion we had talked about earlier
[12] where we talked about the potential transfer of Sam t13] Harvey to the Sequoyah plant prior to the posting
[14] and selection process that happened later.And you I1s] had related to me the conversation, to the best of p6] your memory, I think, of Mr. Magrath about how he p7] had disapproved of that idea, transferring him out
[in8 there.
119]
A: (Witness moves head up and down.)
pq 0: Do you recall Mr. Magrath telling you, Ron, sometimes you just have to make things come
- out the way you want?
W23] A: No.
1241 0: Did he say anything similar to that?
rA2] A: Not that I recall.
Page 102
[]
Q: Did you ever tell anyone else that he r had?
m A: What, said that you have to make
[41 things m
Q: That.
le]
A: Not that I recall, no. I didn't - I In didn't - you know, I've just tried to repeat what
[8] was said to me at face value, you know.You know, m that he expressed his sentiments and kind of the li0] way he wanted to go with this and that's fine. I
[p1] didn't argue with him or we didn't get into a long, p1i drawn out discussion.
1131 You know, he's the manager and if
[14] that's the call he wants to - you know, the
[15] direction he wants to go, then that's the way I li1 looked at it. He expressed his - you know, he was 17] pretty clear about his sentiments. So I didn't see p18] any need to pursue it further.
119]
MS. JONES: Okay. Give me just about r2o ten minutes to review my notes. I think I'm pretty r2i1 close to done.
z O(Thereupon, a brief recess was taken.)
P23 BY MS. JONES:
t24]
Q: Mr. Grover, you just had a lengthy w conversation out here in the hall with Page 103
[] Mr. Marquand. Do you need to change the answers to r any of your questions, any of the questions Ire pj asked you?
l4l A: No. I think, Brent, you wanted to just Ms clarify.
p MR. MARQUAND: No. If counsel has got
- any more questions, go ahead.
A: No. I didn't want to change any m9 answers.
[1i]
MS. JONES: All right. I have nothing
[i1] further.I pass the witness.
[12)
CROSS EXAMINATION (13]
BY MR. MARQUAND:
[14]
Q: Mr. Grover, I have a few questions.
is] Counsel asked you earlier about the amount of p1i time - let me see the exhibits.
[I17 A: Okay.
pai 0: Referring to Exhibit 1, that's the
[19] chemistry and environmental protection senior w20]
program manager position.
CD000787 r213 A: Okay.
pm Q: And you testified that, in fact, that r2l Mr. Fiser and his peers who had been chemistry 1241 program managers when they were in this new p2s] chemistry and environmental position spent a small Hall & Associates (423)267-4328 Min-U-Script (28) Page 100 - Page 105 (28) Page 100 - Page 10:
I Hall & Associates (423)267-4328 M*in-U-Scripte
Tennessee Valley Authority Ronald 0. Grove, Y
O1n~
'7,
-. 77~C 11] portion of their time doing environmental types of M] functions.
R]
A: Correct.
14]
0: All right. When you review the written m position description, which is Exhibit 1, is there Rs a very - is less than five percent of the r functions - are less than five percent of the pq functions environmental functions in the written me position description?
tiol A: No, because it was written, you know, ti] on a balance - the attempt was - like I said
[12] before, a balanced PD to combine chemistry and pjia environmental. So on paper it should be a 1u, balance.
1631 You know, ideally we were shooting for lisj an individual could - could spend half of his time 117] with the chemistry, half of his time with (8] environmental, 60/40 or whatever the need is for p9i the plant. So it wasn't limited to just five pq percent, you know.
1211 It wasn't intended for the chemistry pm people with the chemistry expertise just to stay r4 all chemistry and just do a little bit of l24] environmental.We were trying to cross-fertilize r45 and get everybody up expertise-wise.
Page 104 Page 105 V)
Q: As I understand it, your intent was m that over time people would pick up the expertise pi in the other area and work into a more balance.
1,]
A: Correct.
M Q: Okay.
p A: Yeah, but that didn't happen.That was m our objective, but it didn't happen in the time tq frame we're talking about.
pi 0: All right. Now, later counsel asked 110] you about your understanding of the consequences of piq reorganizing and eliminating positions and there
[il was a discussion about whether or not positions l1] were similar or dissimilar and what the
[143 consequences would be. Do you recall that?
P15 A: Yes.
l1i]
0: Where did you gain those types of
[171 understandings about the personnel consequences?
[18]
A: Talking with the HR, human resources,
[19 you know, specialists involved and particularly 120 primarily Ben Easley at the time.We worked - he (21] was assigned to our organization, so we did all our jz you know, really conversing with him.
2m 0: Did you rely on the human resource 124] specialist and Mr. Easley to tell you what the 25 human resource policies and practices were?
V]
A: Yes.
m 0: You're not claiming to be well versed pi in TVA human resource policy and practice.
H41 A: It depends on what you mean by well ts versed. I feel like I've been 6]
Q: Do you feel m
A: I feel like I've got a little handle on jai it with all that we've gone through, but I don't pq claim to be the specialist. I think, you know, pio0 after working with Ben Easley for a time period, I i11q felt at least we had a (12 0: Comfortable.
[13 A: It was my responsibility as a manager (14] to have a good working knowledge of what could be
[is] done and what can't be done. So I felt p~i comfortable. Now, I'm not sitting here claiming
[(i that I was the expert in all the nuances of what
[IS] the policy was, but I felt I had a good working
[zig understanding of what the policy was.
r2 0: There was a discussion about your (211 understanding that if job functions changed by more 12 than 15 percent, then new positions - then any new i] position descriptions which were rewritten are r24] required to be posted. Do you recall that 125 testimony?
age 106 I
Page 107
[]
A: Correct.Again, I don't know if that's rA fact or not. We'd have to talk with the HR people, 131 but I believe it was around 15 percent.
l41 0: But at some percentage there's some m sufficient dissimilarity that they're required to 161 be posted.
m A: Correct.
- B Q: Now, do you know, in fact, if the
- policy is to compare the written position liq descriptions or the jobs that are being performed?
p(l A: Well, the way it's supposed to be, the
[1l] way it's supposed to work is the jobs that you're
[13] actually performing should match the position
[j4] description.
[1]
0: Right.
[161 A: So there shouldn't be a disparity in
[17] your position description with what you say you do pls on paper and what you actually do. If there is a
[1] disparity, then it should be rectified. So it (r2 really starts with the position description, which 121] is what's written.
pm2] Q: Okay. So they compare position CDO0007i
[2 descriptions?
t12]
A: Right. Now, if there was some reason 2] why you can't do everything in the position Hall & AssocIates (423)267-4328 Min-U-Script
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AtUtALLCr OX kvary L Fiser
- v.
Tennessee Valley Authority Page 108 pi description, it should be understood, and I think
[2 in this - in our particular case it was, you know,
[3] what we were trying to get to, that sort of thing.
[4]
0: All right.You're familiar with both
[5 Plaintiff's Exhibit 1 and Plaintiff's Exhibit 2.
[6]
A: Right.
0: Just looking at the position
- 8 descriptions, are they similar or dissimilar?
Iq A: Are they similar or dissimilar?
[10]
0: How much - are they substantially t11]
A: Well, they're dissimilar because you've l12] got the environmental piece.
f13 0: Okay.
[14]
A: But in actuality, I mean, you know, lis] from an actual standpoint or a practical
[p6 standpoint, you know - you know, like I said 1i7 before, the chemistry people did the same thing
[18] functionally in one that they did in the other.
[19]
0: Now, you told us that you had a number
[20] of people reporting to you.You had Mr. Fiser, 121] Mr. Chandra, Mr. HarveyAllen Sorrell.
pm A: Right. No. David Sorrell.
1] 0: David Sorrell.And what job 124] description did David Sorrell have?
i A: He had the same description as this PD Page 109
[1] dated 10-17-94.
m Q: But he was performing primarily pM environmental functions?
141 A: Correct.And we had another M individual,Jim Mantooth, who was in the PG-7
[6] position. Primarily same - same basic position M description, but it was PG-7 instead of PG-8 level.
pl 0: So under this position description, M which is Exhibit 1, an individual could perform any li1] of these functions consistent with that position
[p1l description; is that correct?
1121 In other words, if you had an 1*] individual who was working as a senior technical l14] adviser on specific environmental permitting In1] tasks l16]
A: Correct.
li7l 0: - that's the type of thing that t18] Mr. Sorrell and Mr. Mantooth were working on?
f19]
A: Correct.
[20 0: And at the same time you would have individuals such as Mr. Harvey or Mr. Fiser who were working as TVAN senior technical experts in A chemical traffic control?
w24]
A: Well, let's use another example, lab l2s] QAQC, because chemical traffic control was really Ronald 0. Grover Tan"u~'t-la3 I Ono~e Ta JTr'9010
[I] on the environmental side, but chemistry, that was rA one of those tasks where we actively - chemistry r3i people had expertise and they actually helped out.
[41 0: In fact, it's not - do you know if
- it's TVA human resource policy that an individual
] has to, in fact, be doing all of the specific
- 1 assignments or that they can just be assigned some
[8] of the specific assignments consistent with a m position description?
Ila]
A: Well, if you look at it - you know, m1] I'll call it - use this, coin a phrase, letter of (12] the law, I mean, from HR. again, you're supposed to p1l be performing - you're supposed to be actually u14] doing what the position description says you do, lis] you know.That's the purpose of the position
[16 description.
i17]
0: Your manager can assign you any of
[18] these things.
v19]
A: Your manager has that flexibility, 20 but his intent is to have you do what's in the 121] otherwise, you have the wrong position description.
23]
0: Okay.
1241 A: You know, so you should be right in A the position description should be developed based Page 110 Page 111 lil on what you actually do and - unless we were R trying to accomplish something different in this ri3 case and that's what we started out with the (4] objective of doing.
m 0: In fact, you were trying to accomplish
[6e something different.
ri7 A: Well, that's why we laid out the jai objective, but we didn't get there, but, M] functionally - you know, I'll be honest with you, pqoj functionally the chemical guys still did the same
[1] thing.The environmental guys still did the same 12] thing under the existing PD.We didn't get there ptl yet, you know.
[141 Because you change it on paper doesn't tls] mean you have the ability from a human standpoint,
[1i] from a personnel standpoint, to go right in it, but p17] if you got a plan to try to transition into it,
[pel which we did, that's what we was tying to do.
[19 0: You said that Mr. Easley expressed some r2q sentiment about not posting for competitive bidding 121] the new chemistry program manager PWR specialist im position. Do you recall that testimony? CD000789 23 A: Correct.
[24]
0: Do you know if, in fact, at some point r
in time he did compare Exhibit I with Exhibit 2 to Hall & AssocIates (423)267-4328 Min-U-Scr1pt
(30) Page 108 - Page 111 Hall & Associates (423)267-4328 Min-U-Scripte
Tennessee Valley Authority Page 11; v13 determine if they were substantially dissimilar so
- as to require that the position be posted?)
- 3 A: I'm sure he did.You know, he didn't 14 sit down with me and say, Ron, let's go through
" this line by line, but he had all the PDs. He was
"(6 reviewing it. He has to make the determination.
[I The organization has to consult him,
" his organization.The operating organization, you "pz know, the responsible organization that is doing riol the change, making the change, has to consult the riti human - that's the way it's supposed to work.
[p2 They're supposed to consult the human resources li3 personnel, the appropriate personnel, and decide (143 and with them get the right way to do this.
ptsb Here's what we're trying to do.Advise i16] us as to how we're supposed to, you know, p1i7 procedurally do it in the right way.
fie]
Q: And the advice you ultimately got from piuq human resources was that you needed to post that po position for bidding, the position in pil MS. JONES: Objection. Leading and im mischaracterizes his prior testimony.
23 A: Well, I wasn't - again, I wasn't M2 0: Okay.
pw A. - in this process directly. My Page 113 III conversations with Mr. Easley were that he M expressed concern, sentiments or whatever you want M3 to call it that it looked like on - based on the 141 way these were written, there was that 15 percent M or greater change functionally in what they did.
1q Okay.And he understood it because he was with us M73 with this whole process in developing it and so Po forth, you know. Now, again, I wasn't in that m loop. Okay.
(1o0 a: Okay.
pji A: Because I was basically, you know
[123 0: You were a bystander.
1131 A: That's right. So he - but I tried to t*,4 help.And Wilson asked me, well, can you give t1sl comments on this and this, that and the other. So p16 I tried to help as much as I could.Although, I 173 wasn't in the process, I still tried to help, you tiai know, take - you know, with this transition.
liq Q: Now, when the interviews were - I want tpq to change the subject again.When the interviews l213 were done for the PWR chemistry program manager, on rm the day they were done, that selection board also r2 interviewed people for a number of other positions; p24 didn't they?
r45 A: I don't - I don't recall.
Ronald 0. Grover January 29, 1998 Page 114
[1]
0: Well, do you know that they interviewed
- people for the BWR chemistry program manager
- position?
141 A: Well, yeah.The PW and BW, yeah.Yes.
M Yes.
- s 0: Do you know that they interviewed
- people for the environmental - I guess it wasn't
[9] environmental; was it?
m A: Well, the Rad waste environmental 0iol position, they combined that function.
I113 0: That was interviewed on the same day?
[12]
A: I don't know whether that was the same 113] board or they interviewed - they may have. I 1143 don't know. I don't recall.
(15]
Q: Now, you, in fact - you earlier
[16] testified as to the individuals who were on the
[17] selection board, Mr. Kent, Mr. Correy and Rick (16 Rogers.
(19]
A: Yes.
[20 0: Do you know, in fact, who chose them to
[213 sit on that selection board or is that something
[2 you just have an understanding about through the
[23] grapevine?
[24 A: No. I don't know who made the final
[i2s selection. I knowWilson McArthur was involved Page 115
[v1 with that. I mean, he shared that with me, but
[2 0: He was the selecting official m ultimately, wasn't he, for the positions?
m4]
A: Right. But he was also involved m with selecting the people on the board. I m don't know whether he came up with the names and m Tom Magrath approved it, but I know he had Pn involvement because he - you know, he discussed m that with me. He said, you know, he was involved 110] with that.
(113 0: The day they interviewed people for the t123 PWR chemistry program position, did you witness who (v3 was, in fact, present for the interview?
(14]
A: No. I wasn't, you know, aware of (s1]
0: Of who was actually involved in the (16]
A: Right.This was only feedback I p17 received of who was actually on the board from
[18] you know, the candidates mentioned who was - who
[t1 sat on the board to me.
rDO00790
[20 And I may have been in error because I
[]
want to correct that if I had stated that, you r' know, Ben Easley was - was on the board. I know 2] it was an HR representative. I may have said Ben
,243 Easley. I think I understand from you that may ps3 have been an error and it was another -
Hall&
Asoc~tes(42)267432 MinU-SriI (31) Page 112 - Page 115 I
Hall & Associates (423)267-4328 Min-U-Scripta
In the matter of Gary L Fiser v.
Tennessee Valley Authority Ronald 0. Grover January 29. 1998 Page 116 (i1 Q: I can't testify.
"A A: Oh, okay. But I just want to let you pl know I - this was feedback I got and I may have t41 been in error in that, but there was an HR m representative on the board.
Ms Q: You earlier testified that, of course, rn obviously you came to TVA after Mr. Fiser's pi previous DOL case had been filed.
tq A: Correct.
(103 Q: And you said that you were told by (t11 Wilson McArthur that Mr. Fiser had a previous DOL (123 case.
113]
A: Correct.
(143 0: What was the context of that (i15 conversation?
1161 A: Well, he had mentioned to me - you jIqj know, he had discussed with me to an extent that it (183 was - it was really tying into the vacant position (19 that the decision was made with the settlement that 1] Mr. - you know, Gary Fiser would be returning to 13i1 TVA and would work back - would come back to the rm chemistry organization and would fill that rzA position.
i41 And that's when he said, well, you I know, it was part of a complaint that was filed and Page 117 I1] a settlement was reached and that sort of thing.
rA So it was tied into - it was tied into - because rij he explained to me because I didn't - obviously (41 I'm new and I've got a vacant position and I'm 1 thinking, well, we need to go ahead and follow the Iq right procedure in getting it filled. So he M explained to me the background and why Gary Fiser pi was coming back into the position.
p 0: Okay. So to summarize or rather for me (103 to restate that, you were the manager of that t11q vacant position.
(123 A: Right.
1is 0: And you were sitting there thinking 14] I've got to go through whatever the proper jIs) procedure is to fill that position.
(113 A: Correct.
117]
0: And Dr. McArthur told you that we are
[18] putting Gary Fiser in that position as part of the
[io] settlement of his previous DOL complaint.
vq A: That's correct.
Q: Okay.
A: Now - and, you know, I was informed of pm that right before he - he returned because I was 1241 taking steps at the time to go ahead and try to 12s3 flU the position because we're going to look
- I] outside.We were going to canvas outside.
2 0: So the explanation was to you as to why
- 3 it wasn't necessary to conduct (41 A: Correct.
(
- - a search or even a bidding or Page 118 Iq whatever.
rn A: Correct. Because initially when I come m to the position, I mean, we were going to look for pq3 a candidate to fill the position. So I was taking p10] action to do that.And then, I guess, the Iti] settlement was reached and then we were told, well, (12] let's all stop and this is what - how it's going 113] to transpire.
(141 0: Okay.There was some discussion in
[i3 your previous testimony about Mr. Fiser applying (16] for a job at INPO and comments that you heard,
[171 input that you heard, about Mr. Fiser being (18] involved in the middle of a DOL complaint with t[1q TVA.
20 A: (Witness moves head up and down.)
1213 Q: And you said you heard that fromJim
[22] Bates, who is an INPO employee.
rA3 A: Right.
1243 Q: And he expressed or he had heard t2s] something along those lines from Jim Corbit, Page 119 tl1 another INPO employee.
m A: Correct.
SQ:
Okay.
l4 A: Now, I don't know whether he heard it Rs directly or he heard that he'd stated that.Again, im I'm just giving you what I heard from Bates.That m was the only negative that came up - issue that jai came up that may have had an impact on him not m being interviewed.
(103 0: And I think you said that Jim Bates liq knew Mr. Fiser?
[1l2 A: Yeah.Yeah.They-they - yeah, 113 recognizing that they had been in the industry a (u1 long time.They worked together in the past and he lisi knows - Gary Fiser knows Jim. And, you know, pie they've been at the plant, so they know all the VIm long-term employees like Bill Nestel.
CDO00791 tie You know, I mean, they've either 1191 worked together or because of evaluators, they've 10 known each other over the years. So all the t21] permanent people there, long-standing permanent pm people, basically the industry knows, but Gary pzm has, you know, the opportunity to - he's worked (241 with them as well as been on - you know, been 1253 evaluated at plants that he's worked at, that sort Hall & AssocIates (423)267-4328 Min-U-Script (32) Page 116 - Page 119 Hall & Associates (423)267-4328 M~in-U-Scripte (32) Page 116 - Page 119
Ln UxC maater 01 kyary LI Fiser v.
Tennessee Valley Authority Ronald 0. Grove January 29. 1cqq I1] of thing.
S MR. MARQUAND: That's all the questions SI have.
141 MS. JONES: Nothing further.
m FURTHER THIS DEPONENT SAITH NOT.
17]
Page 120
[1)
WITNESS CERTIFICATE (2]
I, RONALD 0. GROVER, do hereby certify:
p3]
That I have read and examined the
[4] contents of the foregoing pages of record of testimony as given by me at the time and place
[5] herein aforementioned; (6]
And that to the best of my knowledge and belief the foregoing pages are a complete and M7] accurate record of all the testimony given by me at said time, except as noted on the errata sheet Is] attached hereto.
to]
I have or have not made corrections to be attached.
[to]
I1I]
Page 121
[12]
RONALD 0. GROVER 113] STATE OF TENNESSEE
[14] COUNTY OF HAMILTON
[15]
I, Notary Public for the County of
,State of (16 hereby cartify:
(17]
That the herein above named personalty appeared before me this day of (1tS 1998, and that I personally witnessed the execution of this document for the intents and purpose herein
[19] above described.
W20]
Sworn to and subscrbed before me this dayof
.1998.
r~l]
124]
PQ5 NOTARY PUBLIC My commission expires:
Page 122
[1]
The witness. RONALD 0. GROVER.
( requests the toflowing changes to be made In the
( transcript of the deposition which was taken on 14] January 29,1998.
I5 PAGE LINE CHANGE
!16]
Pq)
[1101
[II]
1131 114]
(157 Its]
[17]
[161]
(19]
(203 (2t]
M25
[24]
W25 RONALD 0. GROVER Notary Public CD000792 My commission expires:
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I I
Hall & Associates (423)267-4328 K~in-U-S cripto (33) Page 120 - Page 12;
j.A Luc mater ox Liary I-Fiser V.
Tennessee Valley Authority Ronald 0. Grove January 29, 199:
January 29, 199
[1]
REPORTER'S CERTIFICATE r2l STATE OF TENNESSEE:
COUNTY OF HAMILTON:
I, Cathy H. Kerley, the officer Sbefore whom the foregoing deposition was taken, do hereby certify that the witness whose thstimony (73 appears In the foregoing deposition was duly sworn by me; Pq That the testimony of said witness was M9 taken by me in machine shorthand and thereafter reduced to typewriting; that the said deposition Is 1io] a true record of testimony given by said witness;
[113 That I am neither counsel for, related to, nor employed by any of the parties to the 1123 action in which this deposition was taken, and further that I am not a relative or employee of any (13] attorney or counsel employed by the pasties hereto, nor financlalfy or otherwise Interested in the
[14] outcome of the action;
[15' That the said deposition has In no manner been changed or altered since same was given
[16% by said witness, but that the same has remained In my possession up to the time of delivery.
[173 1171]
[i1]
124]
rA5 In witness whereof, I have hereunto set my hand thls dayol
.1998.
CATHY H. KERLEY, Registered Professional Reporter.
Notary Public In and for the State of Tennessee at Large.
My commission expires June 23, 1999.
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Min-U-Scrlpta
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In the matter of Gary L Fiser v.
Tennessee Valley Authority Ronald 0. Grove January 2Q 1 QQ.
1 12:4,8; 13:22; 14:19;
--- 15:3; 16:7; 21:14; 24:10; 26:10,25; 27:23; 28:7; 30:13; 103:18; 104:5; 108:5; 109:9; 111:25 10-1-94 75:5 10-17-94 109:1 11 8:1 15 5:11; 60:14, 18; 61:23, 23, 24; 62:25; 87:7; 106:22; 107:3; 113:4 1679:4,25 16th 5:14; 23:20 17 34:4,8; 35:15; 52:11; 79:5 19 33:24,24 1993 81:11 1994 7:20, 21; 11:1 1995 74:17, 17 1996 17:23; 23:9,20; 30:21; 32:6; 74:20; 87:2 1997 34:4; 36:21; 52:21 1997-1998 33:25 1999 33:18,19 2
22:19, 23; 24:9; 25:22; 27:2,5; 108:5; 111:25 2000 31:13, 16,21,22; 33:8, 18,19; 34:22; 36:12 28th 7:20,21,22 3
3 74:24; 75:3 30th 87:2,3 37363 4:10 374 4:10 4
4 76:21; 79:3 40 31:12,25; 32:20; 33:14, 17; 34:18,23; 36:15; 52:18; 53:8, 14, 17 6
60/40 104:18 9
'g'-30-95 75:5 94 8:14; 9:4; 16:4; 17:21; 21:10;40:20 95 74:15 96 21:10; 30:22; 31:16 97 31:19, 20, 21, 22; 53:6 98 31:22 99 31:22 9920 4:9 A
abbreviations 23:3 ability 111:15 able 16:25; 17:13, 16; 33:25; 34:14; 56:11; 60:17 above 36:6 absent 75:21 Academy 8:8 accommodate 68:2 accomplish 16:22; 111:2,5 accomplishing 31:7 accountabilities 15:4, 15; 25:4; 57:23; 80:20 accountability 15:14 accurate 37:7 achieve 32:7; 33:17; 34:14, 18; 35:13 acting 75:22 action 37:15; 48:21; 118:10 actions 80:23 actively 110:2 actual 74:18; 99:17; 108:15 actuality 108:14 actually 16:7; 18:3; 24:24; 107:13, 18; 110:3, 13; 111:1; 115:15,17 add 21:22; 46:6 added 15:18,25; 30:9 addition 15:9; 29:6 additional 36:2 address 4:8 addressed 55:7 advice 112:18 Advise 112:15 advised 38:11 adviser 109:14 affect 30:22 affects 39:2 afterwards 85:10 again 25:14; 27:15; 36:23; 54:23; 62:14; 68:13; 73:6, 8;77:10; 78:19; 80:3; 82:7; 85:3; 86:6;91:1, 21; 92:16; 94:22; 98:24; 107:1; 110:12; 112:23; 113:8, 20; 119:5 against 40:13; 41:4 aggregate 22:9 ago 41:22 agree 46:6; 78:17 ahead 9:25; 60:7; 61:20; 62:18; 69:3; 96:10; 103:7; 117:5,24 ahold 100:12 Allen 108:21 alleviate 43:11 Along 75:24; 118:25 already 35:2; 36:22; 71:21; 95:17; 100:4,5 Although 113:16 always 37:24; 38:10,10, 12; 39:22; 41:5; 66:24; 67:2; 85:23 amount 22:4; 36:2; 37:13; 60:15,17; 78:16; 103:15 analysis 8:11; 80:13 annual 74:16; 75:4 anticipated 7:9 anymore 50:5 anyone 5:23; 42:4; 85:25; 95:9; 102:1 application 70:19,21; 71:1;87:14,17; 88:22 applied 25:20; 87:10 apply 39:25 applying 93:21; 94:12; 118:15 appointed 75:22,25 appraisal 71:10; 74:14; 75:4,15 appraisals 70:17 appreciate 44:9, 13 approached 41:17,18; 42:18; 44:18; 45:10; 48:6, 9; 67:15; 69:6 appropriate 112:13 approval 76:16 approved 115:7 approximately 8:1; 9:9; 10:25; 17:22; 23:8 area 4:18; 5:1; 19:6,8,13; 20:12; 54:7, 8; 79:9, 11; 80:5;81:9; 105:3 areas 26:2 arena 21:3 arenas 16:25 argue 102:11 around 39:23; 41:6; 59:13; 84:8; 85:8,17; 107:3 assessing 19:8; 80:21 assessment 63:18; 74:19 assessments 80:21 assign 17:13; 19:24; 22:3; 110:17 assigned 105:21; 110:7 assignment 5:10; 55:9 assignments 110:7,8 assumption 51:17 Atlanta 5:11; 97:21 attach 70:20 attempt 49:10; 68:1; 104:11 attention 30:20 attest 95:12; 101:1 attorney 6:3 attributed 47:10 Authority 7:25 available 41:25; 45:11, 12; 70:24 aware 6:9; 12:17; 23:4, 14, 14, 22; 42:6, 23; 45:10; 47:24; 53:16; 58:23; 64:25; 68:3,6, 10; 69:24; 70:1; 71:23; 72:1; 73:20, 24; 74:11; 79:16; 81:10, 13,18; 83:17, 21; 84:5, 10, 12; 85:16; 87:10; 101:4; 115:14 away 47:7; 73:15 B
back 10:4; 21:6; 25:1; 29:2,4; 39:10,17,21; 40:11;48:9; 50:12, 18; 51:5, 8; 58:3; 60:24; 61:2; 73:17; 81:22, 24; 84:5; 90:18,21; 95:20; 96:6; 98:3,5;99:14; 101:10; 116:21,21; 117:8 background 8:12; 44:12; 65:21; 66:1; 71:5; 83:4; 117:7 backward 58:9 backwards 20:21 Bailey 5:21 balance 56:2; 104:11,14; 105:3 balanced 55:25; 104:12 Bar 27:9; 65:12; 66:10,18 base 57:25 based 17:17; 33:7; 59:7; 60:8; 62:11; 63:18; 72:12; 79:14; 94:8; 110:25; 113:3 basic 13:16; 18:14; 24:5; 36:7; 71:3, 7; 109:6 basically 13:11; 15:11; 17:7; 21:25; 24:17; 27:16; 31:4, 5; 38:15; 50:15; 51:13; 53:7; 61:12,13; 62:1; 89:25; 95:15; 99:12; 113:11; 119:22 basis 19:25; 39:3,3; 59:11,14; 75:18 Bates 92:10; 95:15; 97:25; 118:22; 119:6,10 became 84:10, 12 become 81:18; 84:5 begin 7:18; 58:25 beginning 17:22; 87:6 belabor 44:7 believe 6:11, 13;7:19, 21, 21; 16:3; 33:18; 35:15; 37:2; 60:14,18; 61:23; 65:19; 101:7; 107:3 Ben 48:14, 15; 57:5; 61:1; 63:8; 65:20,20; 67:19,19, 20; 105:20; 106:10; 115:22,23 beside 29:13 best 16:13; 61:5; 101:15 better 25:19; 38:11 bid 11:18, 20; 14:8; 23:1:2 60:21; 62:6; 64:7,20 bidding 111:20; 112:20:.
118:5 big 19:20; 36:13 Bill 119:17 bit 25:18; 27:19; 54:12; 64:4; 73:25; 104:23 blank 14:21 blower 83:14 board 14:8, 16; 16:5; 64:10,14,17,18; 65:1,4.
7; 66:11; 67:9, 22; 68:12.
22; 69:19; 70:11, 12,16, 24; 71:9, 21, 22; 72:14; 81:5; 83:20; 84:4,9; 98:6:
113:22; 114:13,17,21; 115:5,17,19,22; 116:5 boards 67:1;71:11 boiling 24:20,21; 26:8 boils 38:21,21 booklets 70:22 boom 34:22 both 16:25; 17:3; 25:19; 27:23; 55:4; 70:10; 71:17; 72:2; 108:4 boy 14:22 break 19:21; 70:3 Brent 103:4 Brian 4:23 brief 30:17; 70:6; 102:22 bring 20:18; 81:3; 92:22 96:11, 23; 97:3, 11 bringing 49:3 broadcasting 85:17 broken 29:21 Brown's 54:14; 55:9; 65:11;69:11, 17 BS 8:10 budget 31:5; 32:8; 37:17; 45:7, 13,23; 46:8,8; 47:14, 16 budgetthead 31:12 budgetary 34:13 budgeted 46:4 budgets 53:1 built 25:12 BW 114:4 BWR 24:20; 25:7,8,8, 10 26:3; 27:10,11,18,23; 28:5; 30:10; 54:2,2,7,9, 12, 25; 55:5,6,6, 10,14, 18,25; 71:18; 72:2; 74:6; 114:2 BWRs 27:13 bystander 113:12 OI1()
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In me matter of Gary L Fiser v.
Tennessee Valley Authority Charles 41:14; 44:17; 57:4; 58:3; 1 50:13; 65:9; 69:4; 83:21 common 4 check 49:8 communic call 11:14;44:3; 88:17, chemical 8:16, 18, 19; communic 24; 89:2, 5, 13; 96:20; 17:2; 18:22, 23; 19:10; Company 102:14; 110:11; 113:3 93:17; 109:23,25; 111:10 comparati called 4:2; 10:16; 18:22; chemicals 18:24 31:2; 60:5; 67:21; 73:21; chemist 93:17 compare 14 91:3;93:16;99:22; 100:9, 111:25 11,911 chemistry 8:17, 18; comparing calling 54:5; 63:16; 92:6 10:19,20,23; 11:2,6; ping Calls 66:12 12:9, 19; 13:5,7,10, 19; compete 4n Calls 66:12; 37:2; 7;
15:12,17,25; 16:15,16, competent came 6:12; 37:20; 68:7; 17; 17:5, 8,9, 13, 16; competing 71:17; 72:1; 86:14; 90:20; 18:17,21,25; 19:5,7, 13, competitive 92:25;98:11; 115:6; 17,19,24; 21:3,4,4,7, 11, competitive 116:7; 119:7,8 23; 22:1,1,4,24; 24:19; 64:7 can 4:7; 9:20; 12:11; 25:3,3, 11; 26:2,3,6, 19; Complainai 13:19; 20:15; 23:1; 25:19, 27:6,13,15,18,21; 30:8, complaint 8 21; 28:13; 29:2; 32:25; 10, 11; 35:6, 12, 17; 39:7; 83:14, 23; 84 33:5; 36:14; 39:18; 40:15; 40:19; 41:15,16; 51:1,13; 85:2,15; 86:1 52:18; 53:6; 61:19; 62:13, 53:19; 54:6,7,8, 10,13, 90:16;116:2 19; 64:6; 66:6; 69:22; 70:4; 18; 55:13; 56:9; 65:10, 11, 118:18 74:12;78:11,21; 8618-22; 69:12; 73:21, 22; 74:3; completed 88:15; 90:2; 96:20; 110:7, 76:21; 78:18, 25; 79:4,9, 17; 113:14 11; 81:8; 88:6; 93:8; completely candidate 72:6, 13; 103:19,23,25; 104:12, 17, completion 80:25; 81:2,2; 88:14; 21,22,23; 108:17; 110:1, compositioi 90:22; 93:24; 94:3; 118:9 2; 111:21; 113:21; 114:2; concern 38:
candidate's 70:17; 79:22 115:12; 116:22 113:2 candidates 40:22; 64:11; children 4:16 concerned 5 72:18; 76:8; 77:17; 78:24; choice 43:16; 50:1; 73:8, 101:1 89:11;91:11;95:5; 115:18 13 concerns 84 canvas 118:1 choose 72:6 conclude 62 capacities 17:3 chose 53:11; 114:20 conclusion capacity 66:7; 76:1, 3; chosen 14:17 concurrenci 85:6 Chris 91:17, 18; 94:16, condition 81 carried 22:1;45:22 17,18 conduct 118 carry 36:8; 38:9 chunk 36:14 confidential case 6:17; 82:7,9, 10; claim 106:9 conflict 67:1 90:6; 95:13; 108:2; 111:3; claiming 106:2,16 conjunction 116:8,12 cla im in 57:2 0 conj unt categorize 55:3 clarification 57:20 consequenc category 60:24; 62:24 clarify 103:5 14, 17 cathry 60:1122; 2:24, classified 5:6, 15 considerabl Cathyclear 30:6; 61:4; 102:17 consideratio certain 34:1,3; 59:10,22; climb 21:2 considered 72:15 clm 12considered Certainly 78:20 close 23:24; 102:21 consistent 5 challenge 50:9 closely 58:18,21 109:10; 110:8 challenges 19:15 code 4:11 consult 112:7 Chandra 55:1,8; 56:16; coin 110:11 consulted 58 69:12; 71:17; 72:1; 73:3; collective 39:3 contact 96:1C 75:25; 108:21 college 4:20; 8:5,7 contacted 96 Chandra's 42:13 combine 13:4; 14:6; contacting 9*
Chandrasekaran 8:25; 16:20; 51:14, 14; 57:23; content 24:4, 14:21 60:12; 104:12 context 23:14 change 33:10; 59:13, 19; combined 11:2,8, 10; 116:14 60:9,9, 10; 61:22,25; 12:19; 13:2,3,4,7; 21:1; control 18:24; 62:4, 25; 103:1,8; 111:14; 24:18;40:10; 51:16, 19; 26:2,3;27:15; 112:10,10; 113:5, 20 73:22; 74:4; 114:10 controlled 25 changed 60:13, 16; combining 11:12 controlling 18 106:21 comfortable 49:9; conversation changes 24:3, 14; 73:20, 106:12, 16 47:18; 50:24; 6:
24 coming 10:4; 19:2; 69:25; 96:2; 98:21; 99:
changing 35:1; 60:1 81:22,24; 117:8 102:25; 116:15 characterize 54:20; comment 90:1 conversation:
75:14 comments 56:22.23:
63:11 11 4 :
Ronald 0. Groves January 29, 1991 l13:15; 118:1(
2:7 ate 68:17 ating 38:3 8:2
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- 6,11,20; 1,13,15; 5; 117:19; 73:23 52:23 18:4 n 68:12 3; 90:7, 15;
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- 18; 85:13
- 10 62:15; 95:10 D 56:14; 57:1
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- 11 1:23,24 42:21; 3:8; 83:21;
- 6; 101:15; s 58:16; Conversely 17:15; 19:18 conversing 105:22 Corbit 93:5,6,19; 94:13, 18; 97:25; 118:25 corporate 5:7, 17, 19, 20; 8:16,17; 10:23; 11:5,6; 20:13; 39:17; 47:3; 48:1, 2; 49:19,20; 65:15; 97:21 corrective 80:23 correctly 17:24; 36:20; 55:3; 58:8; 65:9; 76:15, 17; 84:7; 90:3 correlation 30:1 Correy 65:11;69:9, 11; 83:25; 114:17 costs 36:14 couldn't 35:25,25; 36:12; 67:23 counsel 86:4,6; 103:6, 15; 105:9 count 31:12; 36:20; 38:22; 46:4,7, 17 counterparts 38:19; 39:6 couple 16:12 course 64:21; 81:12; 99:6; 116:6 cover 30:11 COX 66:21; 67:7,23 Cox's 68:2 create 58:13; 59:14, 15 created 14:18; 16:5; 46:1 creating 35:2; 59:10 creation 57:5; 58:10; 98:5 Creek 4:9 criteria 34:11; 62:12 CROSS 103:12 cross-assumption 18:2 cross-fertilization 17:12 cross-fertilize 20:16; 104:24 cross-training 18:2 current 5:4; 11:16; 31:12; 71:6 cut 32:21 cuts 33:21 D
data 79:23 date 31:1; 84:10; 86:21 dated 23:19; 109:1 Dave 14:21; 20:8; 98:21, 25;99:5,6,8, 11,15,16, 21,23; 100:15 David 14:25; 108:22, 23, 24 day 7:20; 67:16; 113:22; 114:11; 115:11 deal 19:15; 100:6,20 decide 112:13 decided 62:20 CD 0796._.
decision 9:13; 10:2,8; 33:4,6, 10; 52:17, 22:
53:23; 58:12; 61 18, 22; 63:20, 25; 6, s 90:19,21;92:22, 94:8, 11; 95:2,3; 97:6; 100:5, 17,20; 101:3; 116:19 decisions 90:17; 91:10 Dedra 44:2 defined 53:24 definition 11:15 degree 8:9, 10; 66:5 Delaware 8:3 delineate 29:6,8 denominated 74:6 Department 6:24; 7:1; 11:4; 18:3; 30:23; 33:2,22; 51:1; 73:21,22; 75:22; 88:6; 89:4; 91:15; 93:8; 94:7, 16 departmental 89:4; 91:3 departments 74:4 depended 45:9 depends 106:4 DEPONENT 120:5 deposed 4:4 deposition 5:22; 7:8,14; 12:4; 22:19; 74:24; -74.22; 82:8; 87:6 described 12:2L 64:6 description 12:3,9,18; 13:12,17,21; 15:7,7; 16:9; 21:14; 22:16,18,24; 23:8, 15; 24:7; 25:20; 26.9; 27:22; 30:13; 35:1; 56:12; 57:6; 58:10; 59:15, 16; 60:2,13, 19;61:7, 22; 62:5; 93:15; 104:5,9; 107:14,17,20; 108:1,24, 25; 109:7,8, 11; 110:9, 14, 16, 22, 25 descriptions 11:13; 22:15; 24:13; 28:1, 4, 5; 30:11; 56:5,18; 59:23; 106:23; 107:10,23; 108:8 designated 98:18 determination 65:3; 70:18; 88:16; 112:6 determine 112:1 develop 14:6; 32:10,12; 80:22 developed 110:25 developing 113:7 Development 74:23 developmental 5:16 differ 15:7 difference 15:9;.
25; 27:7. 12 differences 24:12 different 14:3; 26:3; 27:12,19; 46:12; 88:15; 111:2,6 dimensions 57:15
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in me matter of Gary L Fiser v.
Tennessee Valley Authority Ronald 0. Grove.
January 20
'Gas DIRECT 4:5; 8:23; 11:25; 13:1; 29:11,25; 42:21; 56:1; 81:9; 85:7 directed 32:9; 38:9; 79:9; 80:4 direction 14:5; 20:4; 32:11; 53:25; 62:14; 72:9; 101:5; 102:15 directive 43:19 directly 9:1; 68:17; 69:23; 91:23; 98:12,15; 99:10; 112:25; 119:5 director 89:4 disapproved 101:17 discretion 72:22 discuss 38:5; 79:25; 81:16; 82:13; 85:25; 88:10 discussed 10:13; 31:3; 32:24; 34:25; 35:2; 522:9; 67:8,10,12; 84:15; 85:22, 22; 86:14, 15; 95:17; 115:8; 116:17 discussing 16:6 discussion 50:8; 55:22, 22; 60:23; 61:2; 63:3; 73:4; 75:19; 79:15, 15; 83:13; 98:23; 99:14; 101:11; 102:12; 105:12; 106:20; 118:14 discussions 59:1; 61:4; 81:19;84:15 lisparlty 107:16, 19
___dispute 92:8 dissimilar 105:13; 108:8, 9, 11;112:1 dissimilarity 107:5 distinction 26:14,21 divide 55:13 divided 27:24 document 12:7; 15:5; 22:22; 75:2,6, 10; 77:1 documents 28:11 DOL 81:11; 116:8, 11; 117:19; 118:18 dollars 47:8,9,11,13, 14; 52:4 done 45:9; 46:25; 47:25; 48:3,13; 53:8; 54:13,14; 58:22; 74:14; 100:6,20; 102:21; 106:15, 15; 113:21,22 Donna 6:20,21 down 32:7; 36:14; 38:21, 21;47:8, 13, 16;49:19; 50:2; 52:18; 53:5,5; 55:18; 59:20; 88:1; 101:19; 112:4; 118:20 Dr 117:17 dirafting 56:5; 57:6,7 aw 95:9
\\'.rawlng 14:21 drawn 55:22; 102:12 drill 41:2 Drive 4:10 duly 4:3 DuPont 8:2 during 6:14; 18:1,6; 19:1; 20:6; 63:11,11, 11; 87:9 duties 15:18; 16:8; 17:13; 18:2,17; 24:13; 25:22; 26:25 E
E.S 8:24; 14:21 each 11:9,24; 56:20; 84:20; 119:20 earlier 98:23; 101:11; 103:15; 114:15; 116:6 Easley 48:15; 57:5; 58:11,12,24; 61:2; 62:10; 63:8; 65:20; 67:19; 105:20, 24; 106:10; 111:19; 113:1; 115:22, 24 Easley's 61:9 educational 66:6; 71:5 effect 90:3,4, 8; 99:11,17 effectively 44:4 effectiveness 80:22 effluence 80:13 effort 20:24; 38:8; 58:15 efforts 20:3 eight 20:22 either 24:3; 46:16; 47:12; 119:18 elicIt 79:22; 80:12 eliminate 52:22 eliminated 47:5,7; 64:21 eliminating 105:11 else 27:4; 85:25; 100:3; 102:1 embedded 26:12,13; 29:20 employed 7:23; 8:2 employee 73:18; 87:22; 92:8,15; 93:7, 9; 97:9; 118:22; 119:1 employee's 90:7.7,14, 16 employees 8:20; 89:20; 90:12; 92:14; 94:5; 119:17 employment 81:12; 87:11, 14; 93:20 encourage 38:18; 39:5, 23; 40:8 encouraged 38:11,12 end 32:6,11,12; 34:18; 52:2; 71:23 ended 50:21;71:14 engineer 93:18 engineering 5:7,17,19, 20; 8:11, 16,19;66:1,2 enough 16:14 entails 31:4; 94:2 entire 32:20; 52:18; 53:8; 56:7; 58:15; 73:18; 76:16 entries 75:10 environmental 11:3,6; 12:10,19; 13:5,7,11,20; 14:22; 15:10,18,22; 16:8, 14,18; 17:1,4,10,10,14, 15; 18:18; 19:3, 12,20,22; 20:5,12; 21:24; 22:6; 24:15; 25:1; 26:19; 28:6; 29:15; 35:6,11,12,18; 52:23; 53:1,3; 56:10, 11; 103:19,25; 104:1, 8, 13, 18,24; 108:12; 109:3, 14; 110:1; 111:11; 114:7,8,9 environmentally 15:24 envision 33:21 equal 66:16 equipment 25:11 error 115:20, 25; 116:4 essential 24:12 essentially 21:12; 24:5; 25:2; 27:16; 48:8; 56:13 evaluated 119:25 evaluator 93:8,10,12, 14,18 evaluators 119:19 even 40:17; 66:25; 98:19; 101:10; 118:5 events 86:19 Everybody 11:14, 18; 36:11; 39:15; 41:3; 43:25; 57:3; 100:3; 104:25 everybody's 39:15 Everyone 11:20; 16:13, 24; 56:23 everyone's 57:1 everything 15:17,24; 39:14; 107:25 evolution 47:24; 58:19 exact 31:1; 84:9; 85:5; 86:21 exactly 10:25; 86:18 EXAMINATION 4:5; 103:12 examined 4:4 example 18:21; 19:10; 26:16; 32:6; 80:24; 81:5; 109:24 except 27:16; 29:14 excluded 28:3 exclusion 24:15; 28:6 Excuse 8:12; 16:1 Exhibit 12:4, 8; 13:22; 14:19; 15:3; 16:7; 21:14; 22:19,23; 24:9,10; 25:22; 26:10,25; 27:2,5,23; 28:7; 30:13; 74:24; 75:3; 76:21; 79:3; 103:18; 104:5; 108:5,5; 109:9; 111:25, 25 exhibits 103:16 exist 11:18 existing 111:12 expect 43:4 expenses 36:2,7, 25 experience 20:19; 55:5; 58:20; 59:6; 70:12; 79:22, 25; 80:12 expert 26:1; 106:17 expertise 20:15; 26:18; 54:9,12,15,16, 19,25; 78:17,24; 80:12; 104:22; 105:2; 110:3 expertise-wise 104:25 experts 109:22 explained 97:2; 117:3,7 explanation 55:12; 118:2 explore 41:6 exposed 59:5 expressed 42:3; 62:23; 63:14;85:13; 102:9, 16; 111:19; 113:2; 118:24 expressing 63:17 extensive 55:4 extent 116:17 F
face 102:8 fact 20:4; 21:1; 34:6; 67:18; 75:20; 99:1; 103:22; 107:2, 8; 110:4, 6; 111:5,24; 114:15,20; 115:13 factually 73:10 failed 80:13; 81:7 fair 15:16,19; 21:9,18; 27:20; 78:16 familiar 23:5; 44:15; 108:4 family 4:25 far 7:11; 19:11; 38:8; 54:15; 58:3;74:5, 11; 100:14,21,22,25 fashion 35:7 favor 18:11 February 5:14; 7:19,19, 20, 22; 9:3 feed 39:10, 17,21 feedback 57:22,24; 73:7, 11; 88:23; 89:1, 3; 90:10; 91:21,24; 92:7, 16; 94:8; 100:8; 115:16; 116:3 feel 42:1; 106:5,6,7 feeling 101:6 feet 16:1 fell 7:22 felt 41:19; 55:16; 63:19, 22; 82:16, 23; 106:11, 15, 18 Ferry 54:14; 55:9; 65:12; 69:11,17 few 12:15; 70:9;77:21; 103:14 figure 22:4 file 82:7,9; 84:11; 85:2; 86:13 filed 12:5; 22:20; 74:25; 76:22; 81:11; 84:6; 85:15; 86:1,16; 116:8, 25 filing 84:19; 90:7 fill 20:22; 45:19; 49:20, CDO00797 20; 72:24; 116:22; 117:15 25; 118:9 filled 9:2,6; 10: i6; 11:7; 34:12; 36:24; 58:8; 117:6 filling 10:5 final 62:15; 63:20; 114:24 find 89:2; 96:20; 97:8; 99:16 fine 89:8; 102:10 finish 61:18 finished 99:10 firm 31:9 first 4:3; 6:12; 8:13; 14:13; 30:21; 33:20,23; 34:8; 35:20,22,24; 36:21; 38:13, 18; 39:5; 42:19; 46:21;74:19, 20; 100:12 fiscal 31:18, 20; 32:21; 34:3; 52:11, 20; 53:6, 9, 15; 74:17 Fiser 9:7,14; 10:4; 13:1; 14:20; 15:8; 16:4; 21: 10; 22:5; 56:17; 64:20; 69:20, 25; 74:23; 75:4, 11; 76:6; 81:10; 84:6; 87:10,13; 88:19,20; 103:23; 108:20; 109:21; 116:11, 20; 117:7, 18; 118:15,17; 119:11,15 Fiser's 10:15; 54:19; 65:1; 74:13; 83:13; 116:7 fit 32:25; 61:1 fits 26:7 five 5:12; 8:5; 13:3, 5; 22:8,13,13; 31:14; 40:22; 59:19; 91:5; 104:6,7,19 flexibility 110:19 focus 16:23; 17:19; 19:14,16; 21:3,4; 24:6; 25:8 focused 17:9,10 focusing 77:5 folks 18:17, 22; 19:7; 73:17; 83:20 follow 48:22; 62:20; 64:3; 117:5 follow-up 30:5; 41:12; 70:9; 81:4 following 62:8 follows 4:4 force 43:10; 53:5; 82:4 forgot 6:19; 29:1 form 7:7; 16:20 format 57:18 formed 13:14; 64:10 forth 23:19; 48:8; 51:6,8; 60:24; 61:2; 62:7; 81:23; 99:13, 15; 113:8 forward 40:7; 64:4; 68:24; 83:8 fossil 8:18 found 20:6 foundation 9:17,22; 69:22; 71:20 four 9:9; 13:13; 15:1; 31:17,22; 40:21; 77:12; f?'%
T-%TT),,re-r ir--
TV-011 A, AccfNr-;-vf#-c (ZL7A)1A"7-4a7Q
In the matter of Gary L Fiser v.
Ronald 0. Grovel Tennessee Valley Authority January 29, 199e 91:5 fourth 15:1 frame 31:1; 41:13; 74:21; 84:8; 85:5, 12; 105:8 frequently 75:21; 76:3 Frost 4:9 fuel 80:13; 81:7 fulfill 14:15 fulfilled 15:12 fulfilling 50:2 full 4:8 function 15:10; 16:25; 17:3, 5; 18:25; 21:24; 22:1, 2; 24:24; 25:25; 27:11; 38:23; 39:2, 9, 15, 21; 46:1, 2; 49:20; 52:23; 53:3; 57:12; 60:10; 114:10 functionally 21:25; 30:4 6;47:1; 59:22; 108:18; 111:9, 10; 113:5 functioning 66:7 functions 11:12; 15:25; 21:12; 25:3; 39:10; 53:1; 59:13, 21;60:12;62:4; 104:2,7,8,8; 106:21; 109:3, 10 further 101:10; 102:18; 103:11; 120:4, 5 G
gain 105:16 Gary 9:7; 14:20; 42:12; 64:20; 74:23; 75:4,22; 76:5,6; 82:14; 83:22; 84:6, 16,17; 89:10, 18; 90:1, 4; 92:7; 93:21; 94:12; 95:16, 18; 96:5,6; 97:2, 17; 98:6; 116:20; 117:7,18; 119:15, 22 gave 22:10; 53:25; 83:4; 91:6 general 8:11; 29:7,21; 33:2; 82:12; 87:23 Generally 15:6; 39:12; 85:14 generators 25:9; 26:5,8 Georgia 5:11; 97:21 gets 94:7, 11 given 6:7, 10; 14:6; 34:2; 43:19; 73:8, 13; 95:8 giving 95:6; 119:6 glitch 97:15 global 79:13 goal 32:1, 6; 39:19; 53:15 goals 33:21; 37:18 goes 39:13; 70:22; 82:18 good 43:2; 57:21, 24; 75:15, 16,19;76:14; 106:14, 18 Gordon 41:15; 50:13 graduate 8:9 graduated 8:10 grapevine 114:23 hadn't 9:2; 34:12; 89:18; 96:5,15 half 8:3; 17:20,21,24; 104:16,17 hall 102:25 hand 12:7; 22:22 handed 75:2; 76:25 handle 106:7 handwritten 77:4; 79:6 happen 68:24, 25; 92:5; 105:6,7 happened 82:17,24; 85:8; 89:23; 101:14 happens 72:4 happy 46:6; 88:9 hard 80:10 Harvey 8:24; 14:20; 37:2, 16; 41:7; 44:20; 47:20; 49:16; 54:9; 56:16; 69:6; 98:8,17; 99:3, 4; 101:7, 13; 108:21; 109:21 Harvey's 44:23,24; 50:24 head 17:23; 36:20; 46:3, 7, 17; 94:7; 101:19; 118:20 headquarters 97:22 hear 96:4 heard 69:1; 88:19; 89:18, 23,25; 90:11, 12; 92:18, 19,23; 93:2, 3; 96:2,15, 21; 97:14; 100:8; 118:16, 17, 21, 24; 119:4,5,6 heavy 19:13 held 12:25; 15:8; 63:3 help 17:17; 18:22; 19:8; 43:23; 58:5; 76:7; 113:14, 16, 17 helped 37:17; 69:15; 110:3 helpful 44:10 Idea 17:11; 101:17 ideally 104:15 identified 22:23; 27:1; 32:2; 79:5 Identify 12:11; 23:1 immediate 4:24; 32:5 impact 119:8 implementation 26:18 Imply 30:2; 86:22 impressions 94:9 in-depth 55:22 Included 26:11; 27:22, 23; 28:7; 30:12; 34:10; 36:20 including 22:5 incorporated 56:24 incorporates 26:25 independent 91:10 independently 7:5 Indicate 83:16; 98:17 Indicated 77:21 Indications 81:6,7 indirectly 68:20; 80:14; 98:16 Individual 15:1; 26:20; 39:3; 42:17; 72:15,16; 81:21,24; 91:14,23; 104:16; 109:5, 9, 13; 110:5 104:16; 109:5, 9, 13; 110:5 (4:20; 46:8, 23; 48:1,2; great 89:7,15 greater 113:5 GREEN 6:20,20,21,22 groundwork 49:12 group 8:16,17,18; 11:2, 3; 13:7; 15:22; 16:16,20; 29:10, 17; 34:17,25; 43:22; 51:19; 56:7, 8, 15; 65:15; 90:12 groups 35:8; 53:13 GROVER 4:1,7,9,22,22, 23; 12:4; 22:19; 30:19; 71:20; 74:24; 76:22; 102:24; 103:14 guarantee 40:17 guess 18:8;48:5;73:6; 89:18; 90:1, 11; 99:5, 14; 100:3; 114:7; 118:10 guidelines 62:8,9 guy 92:10 guys 19:24; 111:10, 11 H
helping 19:8 here's 38:5,6,6,7,20; 67:21; 81:5; 82:2; 112:15 herein 12:5; 22:20; 74:25; 76:22 high 72:2 himself 84:16 hire 72:16 hired 8:15,24; 9:10; 20:5; 81:20 hiring 72:13,14, 15, 17, 21,22,23; 73:2 hisself 84:17 history 82:10 hit 36:21 Hobfoster 91:17,19,20, 21;94:17, 19 hold 10:22 honest 111:9 horizontal 35:7 Howard 41:19 HR 6:16; 11:15; 46:24; 48:14, 22; 49:6; 57:10; 61:13; 62:15; 86:6; 96:7; 100:22; 105:18; 107:2; 110:12; 115:23; 116:4 HR's 57:11 huh 67:15 human 6:16; 45:21; 57:8; 72:8; 105:18,23,25; 106:3; 110:5; 111:15; 112:11,12,19 I
19; 83:19, 22; 106:14 flflflfl(
oQQ XY-11 91-
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individual's 84:21 Individuals 8:25; 20:11, 20; 36:3; 40:24; 42:11; 43:4; 73:12; 87:20; 109:21; 114:16 industry 119:13, 22 Influence 91:12 Information 23:22; 32:22; 44:10; 71:3,4,7; 86:20; 92:7, 22, 24; 95:2, 16,18; 98:7, 10,14 informed 10:3; 50:13; 67:11; 82:25; 117:22 initial 30:25; 32:11,22; 33:12,20; 34:24; 35:4,14; 37:1,3; 52:9 initially 32:2, 19; 35:5; 65:8; 88:23; 118:7 initials 22:25 initiate 48:7, 11 initiated 48:22; 56:8 initiating 49:7 ink 24:3 INPO 10:24; 73:16; 87:1, 3.3, 11, 17,20,25; 90:25; 92:12; 97:20; 118:16,22; 119:1 input 56:8, 16,21; 57:2,2; 58:2, 11; 64:13; 76:18; 78:2, 3; 82:4; 88:13; 89:10; 91:6; 94:11, 23; 95:11; 100:4; 118:17 instance 4:2; 25:21; 58:23 instead 109:7 Institute 5:10 intended 104:21 Intent 105:1; 110:20 interaction 72:12 interest 79:12 Interested 41:3; 49:3; 77:5 interim 35:15 intermediate 34:7, 19,20 intern 44:2 Internal 44:15 Internally 87:17 Internet 85:18 interpretation 79:23 interview 40:13, 21, 22; 64:11; 88:17,25; 89:6, 14; 90:24; 91:2; 96:11, 12; 97:4,12; 115:13 interviewed 64:7; 70:11; 78:16, 22; 113:23; 114:1, 6,11, 13; 115:11; 119:9 Interviewing 40:11; 43:14 interviews 7:16; 113:19, 20 into 7:7; 11:8,10,18,20; 14:8; 15:10,25; 16:13; 19:2, 23; 25:12; 26:6,21; 28:1; 40:6; 41:24; 43:10; 44:20; 46:8, 23; 48:1,2; 50:8; 51:19; 55:13,21; 61:1; 64:13; 79:14" R2:23:
98:12; 102:11; 111:17; 116: 18, 2,
investigation 8-&
Invited 65:7 Involve 36:17 involved 17:5; 36:16; 53:22; 56:4, 6; 57:5,7, 8; 58:14; 68:18; 90:1; 91:7; 92:7; 105:19; 114:25; 115:4, 9, 15; 118:18 involvement 115:8 irrelevant 82:18 Issue 22:17; 79:12; 119:7 issues 19:14; 55:6 item 25:25 iteration 51:23 iterations 51:6,22,25, 25 J
Jack 5:20; 66:21; 67:7,23 January 21:10 Jim 20:6; 92:10; 93:5,6, 19; 94:13, 18; 95:15; 96:20; 97:8,9,25,25; 109:5; 118:21,25-10, job 11:20; 15:7; 1,*.
z3; 21:13; 24:7; 26:9; 27:22; 28:1,4,5; 30:10, 13; 35:1; 40:11,15; 43:2, 25; 56:5; 60:9,10,13; 61:7; 62:5, 6, 11; 71:22; 93:15; 106:21; 108:23; 118:16 jobs 11:19, 19; 18:17; 20:6; 107:10, 12 John 65:10; 83:25 JONES 4:6; 9:24; 12:6; 21:17, 19; 22:21; 29:2; 30:18; 70:7; 75:1; 76:24; 102:19,23; 103:10; 112:21; 120:4 Jr 4:22 July 10:25; 17:21; 21:10; 23:19 June 10:25; 23:8 K
keep 10:14; 39:9; 49:19 Kent 41:14; 44:17; 50:13; 65:9; 69:4; 83:21; 114:17 kept 73:16; 85:23.,:k kind 18:9; 20:3;,
34:17;39:16;51:,
l 79:22; 93:20; 99:7; -:9 knew 38:4; 82:14; 85:11; 86:21; 119:11 knocking 16:1 knowledge 42:7; 68:15, 19; 83: 19,22;:106:14
%DL IJd.L y A-, riser V.
Tennessee Valley Authority Ronald 0. Grove January 20 100qQ knowledgeable 19:6 known 85:14; 119:20 knows 97:9; 119:15,15, 22 L
L 74:23 lab 109:24 labeled 75:3 Labor 6:24; 7:1 lack 9:16,21; 69:21; 71:20 laid 31:6; 33:7; 46:24; 111:7 Landers 44:2 last 7:20; 74:16, 18; 75:5 later 27:24; 86:9; 89:2, 17; 101:14; 105:9 latest 23:16,17,24,25; 74:14 law 110:12 lawsuit 22:17 lawyer 28:15 lay 29:13 lead 59:17 leadership 75:12 Leading 112:21 learn 30:21 least 17:2; 36:21; 61:4; 106:11 leave 47:2,2; 70:8; 75:21; 86:25 led 101:7 left 10:23; 20:7, 8; 40:18; 41:22; 43:14; 45:19; 50:3, 4; 51:18 legal 7:12 length 35:2; 69:19 lengthy 102:24 less 16:21; 22:7,13; 33:13; 104:6,7 letter 48:20; 49:7,7; 110:11 letting 38:4,5 level 13:13; 14:1,3; 20:19; 31:12; 32:8; 67:6; 93:24; 109:7 levels 67:3 lied 54:16 limited 104:19 line 25:24; 50:23; 112:5,5 lines 118:25 lineup 67:22 lining 94:3 list 15:18; 76:16 listed 79:2 Itle 18:20; 19:11; 24:3;
, __*5:17; 27:19; 54:11,11, 13, 14; 64:4; 73:25; 99:4; 104:23; 106:7 live 4:18.19 load 16:23 loaned 92:14 loanee 87:21 located 97:20 location 37:3 long 50:8; 55:21; 89:21; 94:5; 97:14; 102:11; 119:14 lo ng-standing 20:11; 119:21 long-term 88:3; 119:17 longer 11:17,18;47:10 longtime 97:9 look 12:16; 22:9; 23:22; 31:7; 32:16; 33:6, 15; 34:16; 35:7; 38:13; 39:4, 14, 14, 23, 23;41:5; 57:14; 72:17; 75:17; 78:11; 83:8, 19; 110:10; 117:25; 118:8 looked 34:15,17; 35:5; 41:9;46:12; 52:17; 88:22; 95:5; 102:16; 113:3 looking 16:11; 22:12; 33:24; 35:11; 42:4; 52:3,4; 66:16; 67:5; 72:24; 89:10; 91:11; 99:12; 108:7 looks 23:23; 38:1 loop 113:9 lose 20:21 losing 20:17 lost 20:4; 98:6 lot 36:6, 10; 52:6; 77:3; 84:18 luxury 36:16 M
Magrath 31:2; 33:1,13; 47:19; 48:25; 50:16,24; 51:9; 52:12; 53:14,18,22; 55:11; 56:4; 58:17; 62:16, 17; 65:6; 68:11; 83:12; 101:16,20; 115:7 Magrath's 63:24 main 15:9,11; 19:14,16; 24:14,17,25; 27:12; 43:24; 97:22 maintain 35:25; 39:1 maintaining 36:20 maintenance 65:24 major 19:21 makes 58:7;94:8, 11 making 9:19; 28:18; 93:20; 112:10 man 44:18; 97:17 management 33:10; 75:12; 79:25; 80:3 manager 5:7,16; 8:15; 10:18,20,21,23; 11:5,6, 7; 12:19,22; 13:6; 14:22; 22:25; 33:2; 41:15, 16; 51:18; 58:19;65:10, 11; 66:17; 72:13, 14,16,17, 23; 73:2; 75:22; 76:20; 85:7, 10; 88:6; 89:4; 91:16; 92:3; 94:17; 102:13; 103:20; 106:13; 110:17, 19; 111:21; 113:21; 114:2; 117:10 manager's 14:13; 72:22; 91:3 managerial 11:7; 84:23 managers 11:9; 35:18; 39:7; 103:24 managing 82:20 mandate 53:18 Mantooth 20:7; 109:5,18 many 57:22; 75:10 March 30:25; 32:3; 41:13 marked 12:3, 8; 22:18; 74:23; 76:21 Marquand 5:24, 25;6:1, 12; 9:16,19; 14:24; 21:15; 28:9,13,18,22; 31:18; 44:21; 61:18; 66:12; 69:21; 71:19; 77:2; 78:1; 86:4; 103:1, 6,13; 120:2 married 4:12 match 107:13 math 17:23 matter 10:13 matters 41:18 may 9:17; 28:12; 29:7; 33:7, 8, 8, 8, 9; 34:2,4; 39:24; 58:11, 24; 60:17; 61:25; 63:14,24; 66:23; 68:13,17; 72:6, 14; 83:22; 86:17,18; 93:22; 114:13; 115:20,23,24; 116:3; 119:8 maybe 20:19; 62:15; 76:2; 90:9 McArthur 10:3; 58:17; 65:6; 67:11; 73:2; 77:24; 83:1; 114:25; 116:11; 117:17 mean 15:21; 17:8; 22:8; 23:12,19; 24:2, 8; 25:19; 28:5; 29:1; 30:2; 32:4, 5; 42:7; 43:1,13; 44:7; 45:1; 50:6; 51:4,9; 53:10,25; 55:17, 20; 57:13,14; 58:21; 61:5; 62:8; 63:10, 20; 71:21; 80:14, 17; 82:1, 14,16,19,24; 84:15; 85:3, 12,16; 86:22; 87:18, 19; 100:1; 106:4; 108:14; 110:12; 111:15; 115:1; 118:8; 119:18 meaning 35:14; 36:3; 52:20 means 9:25 meet 31:10; 32:2; 33:25; 37:18; 53:14, 17; 57:17; 62:24 meeting 19:9; 30:24,25; 31:2; 32:3,23; 33:21; 41:13; 99:5 meetings 51:13; 56:25 member 65:16 members 34:25; 70:25; 81:5 memorandum 48:20 memory 99:19; 101:16 mention 20:2 mentioned 48:18; 49:18; 51:11; 55:15; 67:24; 83:3, 9; 92:11; 98:22,23; 115:18; 116:16 merged 40:5 merging 16:16; 20:6 met 15:13;34:10;71:21; 84:4,9 middle 90:6; 118:18 minimal 36:9 minute 30:16 minutes 12:15; 102:20 mischaracterization 44:22 mischaracterize 45:1 mischaracterizes 21:16; 28:10; 112:22 mislead 86:20 missing 100:I0 modify 61:7 moment 84:5 month 97:11 months 5:12,12; 20:9,9, 22; 87:7 more 17:5; 29:6,9, 16, 21; 49:23; 54:24; 55:5; 61:15; 64:4; 72:18; 73:25; 79:13; 80:3; 88:9; 96:14; 103:7; 105:3; 106:21 most 70:17,20; 71:2,99; 77:5 mostly 82:4 mountains 21:2 move 20:3; 33:11; 46:23; 47:25; 53:1; 64:4; 68:24; 69:2; 83:8; 98:3; 101:10 moved 19:2 moves 101:19; 118:20 moving 37:1; 49:15 much 20:25; 38:4; 43:23; 52:6; 53:6; 108:10; 113:16 multi-page 75:9 must 51:24; 84:14 Myron 4:22 N
name 4:8,14; 6:19; 91:15; 92:10 names 4:21; 115:6 nature 17:17; 79:13 Naval 8:8 Navy 8:4 necessary 118:3 need 12:15; 20:14; 39:8, 8, 10, 14,17,18, 20, 21; 49:12; 50:6; 53:2,3; 90:18; 102:18; 103:1; 104:18; 117:5 needed 21:6; 47:14; 63:15; 70:9; 112:19 negative 57:13; 92:24, 24; 95:11,20,23; 119:7 neither 71:22 Nestel 119:17 New 7:25; 11:19,19; 20:18; 21:13; 28:4,4; 35a.
40:15; 56:5,8; 58:13; 59:10,14,15; 61:22; 103:24; 106:22,22; 111:21; 117:4 newly 12:19; 14:17; 16:5 next 6:3; 7:9; 17:19,20; 22:16; 32:21; 33:14; 52:11,20; 53:9,15 nobody 90:19 nontechnical 18:11; 25:15 normal 47:23 notes 7:6, 15; 77:4,4; 102:20 nothing 43:9; 89:17; 98:15, 15; 103:10; 120:4 nuances 106:17 nuclear 5:7, 10; 8:17 number 10:13; 22:9; 25:24,25; 26:7, 17,24; 27:1; 34:7,7; 38:14, 17; 51:6,6; 53:19; 80:14,19; 108:19; 113:23 numbers 71:15 0
04:1,9,22 Object 9:16; 21:15; 28:9, 44:21; 71:19 objecting 9:21 objection 9:20; 28:23; 66:12; 69:21; 112:21 objections 28:19; 58:24 objective 16:11,19,23; 38:7, 14, 17; 43:24; 105:7; 111:4,8 objectives 31:6,9 Obviously 35:24; 42:25; 73:15; 75:9; 78:12; 85:10; 87:21; 116:7; 117:3 occasion 19:7 occasions 21:24; 76:2 occur 18:5; 20:1 occurred 6:18; 30:20 off 17:8; 30:15; 57:25; 61:25; 82:10; 90:19,21 off-the-record 63:2 offer 56:21 office 36:9 official 115:2 officially 86:16 old 29:8; 30:13 on-site 37:2 once 14:13, 13; 20:21; 64:5; 99:9 one 4:20; 11:8, 10; 13:12, 3CDO00799 (5) knowledgeable - ont Hall & Associates (423)267-4328 Min-U-Scrintst
In the matter of Gary L Fiser v.
Tennessee Valley Authority Ronald 0. Grove, Januar-2Q~ 100c 13; 14:1,2, 6; 16:20; 18:8; 19:10, 12,24; 20:13; 24:8, 14,20,22; 25:12; 26:14, 17,21,24; 29:8, 12, 13, 20; 34:11, 12, 13; 35:4; 38:14, 17; 40:6; 42:13; 45:16, 18; 50:2,3; 51:12, 15, 17, 19; 54:2, 2, 2; 55:17,18,19,25; 62:24; 66:10; 69:18; 74:16; 75:15,25; 76:1;77:14; 79:5, 17; 80:8,8, 16; 81:4; 84:14; 89:20; 90:11; 91:12; 92:14; 93:19; 98:11; 108:18; 110:2 ones 27:10; 28:4 ongoing 19:22,25 only 21:22; 27:7; 28:3; 62:13, 19; 66:6; 69:1; 73:6; 74:8; 75:25; 94:22; 95:19; 115:16; 119:7 Ooltewah 4:10 open 41:2 operating 36:25; 112:8 operation 12:10 Operations 5:11; 8:11; 35:10 operator 5:13 opportunity 41:3; 42:5; 56:17,20; 77:7; 119:23 opposed 42:1,4, 10; 55:8 option 72:20; 73:8 options 39:24; 41:6; 44:5 ordeal 81:22 order 53:17 organization 5:17; 8:19; 11:9, 10; 13:8,14; 16:14; 19:3; 20:13; 35:12; 38:13; 39:2, 11; 40:14; 44:1; 49:20; 51:18,21; 52:24; 56:7; 59:19,20; 85:11; 94:1; 105:21; 112:7,8,8, 9; 116:22 organizationally 35:5 organizations 35:9; 44:5; 52:3 oriented 80:3 original 33:16; 60:19 others 43:6; 55:8; 78:12; 81:21; 82:1; 83:2; 88:2 otherwise 83:21; 101:8; 110:21 out 13:9; 18:22; 19:8; 22:1; 24:15; 25:1, 21; 29:7, 22; 31:6; 32:17,23; 33:7; 37:17; 38:9,22; 40:1, 5, 23;41:13, 20; 43:10, 15, 16; 44:18; 46:19, 24; 47:2, 15; 50:17; 52:23; 55:22; 58:8; 66:24; 69:15; 71:17; 72:1, 12;75:20; 80:1, 7, 15,16; 83:11; 89:2; 92:25; 96:20; 97:8; 98:7; 99:16; 101:17,22; 102:12,25; 110:3; 111:3,7 outside 83:8; 118:1, 1 over 6:22; 16:11, 20; 19:22; 36:2;47:15; 56:10; 67:21; 105:2; 119:20 overall 25:2; 75:10,17 overhead 36:2,3,4,7, 10 own 91:10 P
package 58:6; 70:22 page 15:5; 25:25; 26:17, 24; 70:4; 75:6 paper 104:13; 107:18; 111:14 paperwork 41:1; 86:12 parallel 29:12 part 5:17; 10:10; 25:10, 10; 29:9; 35:1; 37:3; 51:22; 65:20; 70:18,21; 71:7; 80:8,16,19; 116:25; 117:18 participate 29:17 participated 14:15 participation 68:11,20; 100:25 particular 18:16; 23:15; 25:12; 38:23; 39:1,9; 44:12; 71:16; 72:25; 80:2, 2; 81:25; 108:2 particularly 38:1; 105:19 pass 103:11 past 19:1;82:24; 119:14 PD 14:6; 15:10; 16:20; 24:16; 56:9; 104:12; 108:25; 111:12 PD-8 22:24 PDs 13:25; 24:18; 56:8; 57:9; 112:5 peers 66:19,19; 103:23 pen 24:3 people 6:25; 11:15; 14:8; 16:17, 18; 17:4,8, 10, 14, 17; 19:5, 20; 20:5, 18; 21:4, 23; 36:17,22; 37:22; 38:3, 12; 40:12, 14, 19; 41:5; 43:22,23; 44:1, 3; 45:21; 47:25; 48:2; 55:18; 59:19,24; 64:6; 86:5; 91:5, 24; 93:19; 94:10; 96:7; 100:22; 104:22; 105:2; 107:2; 108:17,20; 110:3; 113:23; 114:2,7; 115:5, 11; 119:21, 22 per 56:2 percent 22:8, 13, 13; 31:12, 25; 32:20; 33:14, 18; 34:1,4,8, 18,23; 35:15; 36:15; 52:11, 19; 53:8,15,17; 60:14, 18; 61:24; 62:25; 104:6,7,20; 106:22; 107:3; 113:4 percentage 22:3; 31:24; 34:3; 59:10; 60:18; 107:4 perform 16:7; 109:9 performance 70:17; 71:2,9; 74:14, 22; 75:4, 14,16 performed 21:11,12,13; 22:5; 89:12; 107:10 performing 107:13; 109:2; 110:13 period 18:1,6; 32:13, 14; 35:21; 63:12; 75:5; 87:9; 89:22; 106:10 permanent 87:22; 89:20; 92:15; 93:9; 119:21,21 permitting 109:14 person 6:16, 17; 18:12; 20:21; 25:15;41:22; 45:19; 56:11;69:5,12; 82:25; 93:23,24,25; 98:16 person's 71:2 personally 100:19 personnel 86:14, 14; 92:3; 105:17; 111:16; 112:13,13 perspective 21:7; 67:4; 88:1 perspectives 88:15 pertain 79:3 PG-7 13:13; 14:2; 109:5,.7 PG-8 12:22,23; 13:13; 14:1,9,18; 109:7 phased 40:5 phone 100:10 phrase 110:11 physically 76:11 pick 105:2 piece 17:11; 20:17; 24:15; 25:1; 35:6; 46:4; 56:10; 108:12 place 18:3; 68:9; 73:5, 9; 82:16,23; 88:2; 89:19; 98:19 Plaintiff's 12:8; 13:22; 14:19; 15:3; 16:6; 21:14; 22:23; 24:8,9; 25:22; 26:10,25; 27:2,5,22; 28:7; 30:12; 75:3; 79:3; 108:5, 5 plan 16:19; 32:10,10,12; 33:6, 12; 34:10, 18,20,24; 35:14; 36:19; 37:1,3; 50:25; 51:14,15; 52:9, 15; 74:23;99:18; 111:17 plans 30:21 plant 5:13; 8:2; 27:17,18; 42:24,25; 55:10; 65:12, 17; 101:13; 104:19; 119:16 plant's 65:17 plants 18:25; 19:1; 21:5; 27:8,9; 36:8; 119:25 play 26:6 playing 100:10 please 4:7; 21:20 plus 15:24 point 52:2; 59:6; 75:18; 82:19, 20; 90:10; 99:2; 111:24 pointed 79:10 TTnI1 N-ACc f+/-t,'t.C ('~
/,42-o pointedly 43:7 pointing 25:21 policies 105:25 policy 61:13; 106:3, 18, 19; 107:9; 110:5 portion 29:3; 56:12; 104:1 position 5:4; 8:13,21; 9:11,14; 10:5,15,16,22; 11:8,13,16; 12:3,9,18, 22,25; 13:12, 14, 17,21; 14:3,9,9,11,13,15; 15:6, 8; 16:6; 20:8,23; 22:15, 16, 18; 23:7,11,15,19; 24:13; 25:20,23; 27:6; 34:12; 35:19; 36:23; 37:24; 38:23; 40:5; 41:4, 20;42:12,12,13; 43:11, 15; 44:17,23,24; 45:5.6, 16, 18,22,25; 46:19, 20, 21, 21, 23, 25; 47:1, 2, 4,7, 12;49:11; 50:3; 56:12, 18; 57:6; 58:10, 25; 59:11, 14, 16, 22; 60:2, 19, 20; 61:10, 11, 12,21,21;62:7;63:15; 64:5,20,21; 69:7; 70:19; 71:6; 72:23, 25;78:15, 22, 24; 80:20; 81:25; 83:6,7; 84:23; 93:11, 13,21; 94:12; 98:6,8,13; 99:13; 103:20, 25; 104:5,9; 106:23; 107:9, 13, 17,20, 22,25; 108:7; 109:6,6,8, 10; 110:9,14,15,21, 25; 111:22; 112:2, 20, 20; 114:3, 10; 115:12; 116:18, 23; 117:4,8,11, 15,18, 25; 118:8,9 positions 10:13,14; 11:8; 13:4,6,11,13; 14:1, 16, 18; 24:19; 35:3; 36:4, 23; 39:24; 40:9; 48:1, 2; 50:4; 51:3; 53:19,20, 23, 23; 54:3; 58:7, 13; 61:8, 22; 71:17; 72:2,7; 73:14; 74:4; 105:11, 12; 106:22; 113:23; 115:3 positive 95:25 possible 68:25 post 58:13; 60:20; 62:2, 5,19; 83:7; 112:19 posted 9:11, 12; 11:19; 23:8,10,12; 41:2; 62:11; 63:15; 64:5; 106:24; 107:6; 112:2 posting 23:18; 58:25; 101:13; 111:20 potential 47:19; 50:25; 88:1;90:22; 101:12 Power 5:10; 7:25 practical 13:9; 108:15 practice 106:3 practices 105:25 pre 98:10 preface 37:20 preferred 49:19; 50:1 preparation 7:14 Frinnooon preparing 5:22 prerogative 53:11; 84:21 preselected 91 present 115:1.
pressure 43:19 pressurized 23:3; 24:23 pretty 20:25; 102:17,20 previous 21:16; 116:8, 11; 117:19; 118:15 previously 6:7, 10 primarily 17:9; 24:22; 54:17,18,21, 25; 66:2; 93:13; 105:20; 109:2,6 primary 38:3; 42:24,25; 54:12; 55:9 principal 15:4,14; 69:12 prior 7:16,23; 8:1, 4, 5; 15:7; 19:2; 21:13; 26:9; 52:9, 10; 58:10; 69:24,25; 81:12, 14; 83:13, 22; 98:5, 18; 101:13; 112:22 privy 68:5 probably 16:12; 22:7,12; 42:23; 49:8; 51:4; 54:23; 74:19, 20; 85:6; 90:19 problem 36:1; 43:12; 96:5; 97:15 problems 19:15; 90:5,13 procedural 59:7 procedurally i1 procedure 46:21,_
70:10; 117:6,15 procedures 45:3; 48:23 proceed 62:20; 68:8 proceeding 50:16; 84:19; 100:25 process 11:11; 52:7; 58:25; 59:6; 64:5; 65:7; 67:22; 68:9; 70:8,22,23; 71:14, 24; 72:5; 73:23; 76:9; 77:3; 79:16; 83:10; 85:9; 90:15; 91:9; 94:2; 97:10; 98:19; 100:1, 2, 16, 23; 101:14; 112:25; 113:7, 17 processes 66:23 produced 77:2 proficient 55:3 Program 10:18,20,21; 11:9; 12:21; 22:25; 27:13, 18; 76:20; 80:22; 103:20, 24; 111:21; 113:21; 114:2, 115:12 programmatic 26:18 programs 26:20 project 37:11 proper 48:23; 117 proposal 32:24 proposed 32:1L protection 12:10; 2-6:19; 103:19 provide 26:17; 57:21,24 pulled 82:10 p urpose 57:16; 110: 15 purpose 57:16; 110:15 7
d
.cr V.
Tennessee Valley Authority Ronald 0. Grover January 29 c).CQ8 Tanuav 29 iQP purposes 61:24 pursue 43:15; 50:5; 62:19; 69:2; 90:21; 102:18 "ush 91:1 it 7:7; 9:13; 11:14;
-- 9:16, 23; 25:8; 32:23; 34:17; 56:13; 58:5; 76:7, 11; 85:18; 88:21; 100:19 putting 77:11; 117:18 puzzling 96:9 PW 114:4 PWR 22:25; 23:2; 24:22; 25:7,8,10,23; 26:2; 27:5, 9, 17, 23; 28:5; 30:9; 54:2, 8,13, 17, 18,21,25; 55:14, 19; 56:1; 71:18; 72:2;74:6; 111:21; 113:21; 115:12 PWRs 25:9; 27:13 Q
QAQC 109:25 quarter 74:20 quarterly 74:18 quote 92:2 R
Rad 56:10; 65:10, 11; 1:9
,dChem 35:8; 39:6;
'-41:14; 51:13, 16; 66:17; 73:22 radio 79:9,11 radioactive 80:13 radioanalytical 78:17, 25; 79:3 radiological 79:23 rate 75:11 rather 38:11; 117:9 rating 75:17 re 40:9 reached 117:1; 118:11 reactor 23:3; 24:20,23 reactors 24:22; 26:8 read 29:2,4; 79:17; 82:8, 10 realized 36:12 really 5:8,15; 20:24; 51:10; 55:7; 82:17; 105:22; 107:20; 109:25; 116:18 reason 19:12; 67:17,23; 94:24;95:4, 11; 97:7,16; 107:24 reasoning 55:12,23
-sons 66:22 II 7:11, 12; 9:8;
>.*i1, 11, 20; 18:17; 23:21; 31:1, 11; 33:23; 36:19; 65:9; 76:15, 17; 77:11; 84:7,9; 101:20,25; 102:6; 105:14; 106:24; 111:22; 113:25; 114:14 received 89:1; 94:23; 115:17 recent 70:17,20; 71:2,9 recently 5:9 recess 30:17; 70:6; 102:22 recognizing 119:13 recollection 34:2; 76:12 record 4:8; 9:20; 28:19; 29:4; 30:15; 95:1 rectified 107:19 redefined 40:9 redid 60:13 reduce 31:11; 34:3,22; 36:14,25; 53:19; 59:20,23 reduced 32:7; 46:17 reducing 59:4 reduction 31:5,5; 33:14; 34:1; 35:17; 36:22; 38:2; 51:1, 2; 52:11; 53:8,15, 18 reductions 34:19,20 redundant 58:1 reengineering 29:16 reference 27:9,10,17 referenced 27:14 referring 9:3; 14:9; 17:20; 64:17; 76:4; 91:16; 103:18 reflected 13:22; 14:18; 15:5; 16:8 regarding 37:15 rehire 60:20,20,21 rejected 52:12 relate 88:18 related 101:15 relation 88:9 relationship 43:5; 69:24; 88:10,11 relationships 88:4 rely 105:23 remain 24:19 remained 73:17 remaining 54:3 remember 34:6; 78:5; 84:12; 85:5; 90:2; 100:9, 11 reorg 47:6 reorganization 11:1, 2, 4; 16:3; 17:21; 20:7; 30:20, 22; 31:4,7; 37:25; 39:13; 58:15; 99:9 reorganize 59:12 reorganizing 105:11 reoriented 99:8 repeat 28:25; 78:21; 102:7 replaced 6:22 report 94:18 reported 9:1; 10:3; 13:6; 87:2,3; 94:13, 15 reporter 29:4 reporting 5:18,20; 35:10; 108:20 reports 8:23; 11:25; 13:1 repost 40:19; 61:7 reposted 40:10 reposting 60:3 representation 66:16; 67:3 representative 6:23; 48:14; 65:13, 16; 66:10; 115:23; 116:5 request 41:19; 48:8, 19, 19, 20; 78:13 requested 29:3 requesting 48:16,20 require 112:2 required 37:12; 51:2; 53:14; 60:19; 62:2; 106:24; 107:5 requirement 63:17 requirements 15:13; 19:9 requires 70:19; 78:16,24 reschedule 68:1 researching 6:17 resolved 14:12,14 resource 45:21; 72:9; 105:23,25; 106:3; 110:5 resources 6:16; 16:22; 57:8; 105:18; 112:12, 19 respective 38:19 respectively 54:8 responded 49:14 response 10:9 responsibilities 26:11; 27:21, 24; 28:6; 30:8, 9, 10,12 responsibility 18:18; 19:3; 22:6; 106:13 responsible 58:19; 112:9 restate 117:10 result 71:23 returned 5:9; 117:23 returning 116:20 review 6:6; 7:10,15; 56:6, 11,17; 57:10; 70:16,20; 71:3,4,9; 74:22; 75:16, 19; 76:13, 16;77:7; 102:20; 104:4 reviewed 32:25 reviewing 112:6 reviews 74:18 revised 16:9 rewrite 11:12 rewriting 29:15 rewritten 11:13; 106:23 rewrote 62:5 Rich 41:15; 50:13 Rick 65:13; 84:2; 114:17 right 5:8; 9:4; 10:12; 12:24; 13:15, 24; 15:20; 22:14; 24:24; 26:15; 27:4; 29:19; 35:16,19,23; 36:18; 44:25; 45:4; 52:15, 21; 57:15,16; 58:6,6,22; 59:2; 60:7; 64:8; 65:3; 69:9;70:3, 13;71:18; 72:14; 73:18, 19,19; 74:12, 15;75:23; 77:7, 23, 24, 25; 78:8, 10; 80:18; 83:1; 84:8,8, 21, 24; 85:9; 86:24; 87:7; 88:18; 99:19; 103:10; 104:4; 105:9; 107:15,24; 108:4,6,22; 110:24; 111:16; 112:14, 17; 113:13; 115:4, 16; 117:6,12,23; 118:23 risk 11:14; 25:13 Rogers 65:14,21; 84:2; 114:18 rolled 26:21 rollover 60:5 Ron 96:16; 101:21; 112:4 RONALD 4:1,9, 22 room 36:6,24 Roughly 31:25 routine 47:23 run 49:9 S
SAITH 120:5 salary 47:9 Sam 8:24; 14:20; 42:19, 22,22,22; 43:7,7; 44:20, 23,24; 47:20; 49:4, 15, 19; 50:1,2,14,17; 69:6; 76:1; 98:7, 12; 99:1, 3,4; 100:1; 101:7,12 Sam's 42:11; 50:17 same 11:3; 13:16; 15:22; 16:23; 17:3; 21:12; 24:5; 25:4; 27:11,16; 30:3; 35:8, 25; 40:4,20,23; 43:5, 5; 59:21; 67:4, 4, 6; 108:17, 25; 109:6,6, 20; 111:10, 11; 114:11,12 sat 16:5; 65:19; 67:1; 115:19 saw 32:25 saying 52:4; 59:11, 17; 90:19; 92:3; 95:1 scenario 33:20 schedule 68:2; 89:3 scheduled 5:12; 68:6 scheduling 66:24; 68:11, 21 scorer 72:2 se 56:2 Seaford 8:3 search 118:5 second 39:22; 41:13; 84:6 secondary 26:2; 27:14 secret 42:8 seems 57:25 select 72:15 selected 14:14; 16:4; 98:17 98:17 selecting 115:2,5 selection 10:10; 14:7,16; 64:10, 14,17,17; 65:1; 66:11,23; 67:1,9, 22; 68:9,21, 21; 69:18; 70:8, 11, 12,16,23; 71:8, 16, 24; 72:4; 73:23; 76:9; 77:3; 79:16; 83:20; 84:4; 85:8; 98:6, 18; 100:1, 2, 16; 101:14; 113:22; 114:17, 21,25 send 51:14 senior 5:6, 16; 26:1; 93:24,25; 103:19; 109:13, 22 seniority 60:4,8; 62:3; 63:1 sense 25:2; 39:8; 57:14; 58:7 sent 86:12 sentiment 62:14; 63:8, 14,16; 111:20 sentiments 62:23; 85:13; 102:9, 17; 113:2 separate 8:18; 14:2 September 87:2,4 sequence 86:18 Sequoyah 5:13; 27:9; 37:6,11, 14; 41:14, 15,20; 43:16; 44:18; 45:6; 46:22; 47:20; 65:10; 69:7; 101:13 served 8:4; 71:12; 75:25; 76:1,3 service 70:20 services 12:10 serving 67:8 session 99:5 set 20:20; 96:11 setting 94:4 settled 81:24 settlement 116:19; 117:1,19; 118:11 several 19:19; 20:9; 51:21; 53:8; 56:25; 58:16; 60:12; 81:21; 89:13 shake 40:1 shakes 38:22 share 55:12; 92:19 shared 55:21; 92:17; 115:1 Sharon 4:15 shelf 82:10 shift 19:21 shooting 104:15 short 32:5 short-term 32:1 shortly 20:7; 41:12; 96:24 shouldn't 107:16 side 54:12,25; 55:5, 18, 19; 110:1 sign 7:8,10; 76:16 signature 75:7,7 significant 36:1; 60:15, significant 36:1; 60:15, Min-U-Scrift@
CD000801 (7) ourt)oses - sienflcant Hall & Associates (423)267-4328
In the matter of Gary L Fiser v.
Tennessee Valley Authority Ronald o. Grove_
January 20 lQc 16; 69:19 significantly 61:23; 62:1, 4
signing 7:12 similar 101:24; 105:13; 108:8,9 similarly 80:10 sit 14:7; 36:12; 112:4; 114:21 site 38:22; 46:2,3,4, 5; 48:1, 2,7, 15;49:2,4,7, 16,22; 50:17; 55:25; 56:2 sites 19:4, 16; 24:24; 26:1, 20; 38:15, 15,19; 42:13; 53:2; 56:1 sitting 6:3; 106:16; 117:13 situation 38:6,20; 40:4; 44:12 six 9:9; 20:9, 22; 51:24, 25; 79:24 skills 75:12 slot 9:1, 6; 10:17; 45:11, 12 slots 40:18 small 24:3; 103:25 smaller 16:21 Smith 44:2 somebody 100:16 someone 75:11;95:10 something 34:5,8; 37:19; 49:2; 52:1; 57:191 67:20; 82:8; 89:23; 90:3,4, 6,8,15; 96:3, 17; 98:20; 101:3; 111:2,6; 114:21; 118:25 sometime 89:17 sometimes 66:22; 101:21 somewhat 6:14; 25:6 somewhere 74:21; 85:12 sons 4:19 soon 68:25 sooner 33:9 Sorrell 14:24,25; 15:1; 20:8; 108:21, 22, 23, 24; 109:18 sorry 6:2,5, 18,21; 12:14; 14:25 sort 33:11; 36:10; 48:23; 67:6; 71:6; 76:17; 83:8, 11; 85:9; 88:11,16; 89:22; 90:7; 92:8; 108:3; 117:1; 119:25 source 91:23 sources 88:14 span 31:15 speak 28:11 specialist 54:2,3; 69:13; 74:4; 105:24; 106:9; 111:21 specialists 16:17, 18; 17:1, 2; 20:12; 21:11; 22:5; 54:5; 55:13, 20; 105:19 specialty 54:7,7 specific 18:16; 27:17; 29:16; 61:15;74:1;79:25; 109:14; 110:6,8 specifically 54:1; 77:11; 78:5,13; 79:8,8,11, 17, 20; 80:12; 91:8 specifics 25:18;41:25 specified 27:8 specify 27:8 speculation 66:13 speed 16:24 spend 47:13; 104:16 spent 47:8,9; 103:25 split 25:6; 29:7 spoke 6:11, 23 spots 15:2; 43:14 staff 7:12; 30:24, 25; 31:2,5; 32:3; 33:21; 38:2 stage 24:2 stand 38:24,25 standing 94:5 standpoint 7:13; 13:10; 15:12; 34:13; 46:18; 54:15,24; 56:3; 57:8, 18; 59:7; 65:17; 66:6; 81:8; 88:7; 98:13; 99:25; 100:19; 108:15, 16; 111:15,16 start 18:10; 28:22; 48:19 started 17:6,6,7,11; 111:3 starting 5:14; 31:20 starts 107:20 state 4:7; 5:8; 28:23; 94:22 stated 50:7; 55:16,20; 84:19; 100:12; 115:21; 119:5 statement 7:2,4; 15:19; 25:24; 26:22, 24; 27:1; 29:8; 101:2 statements 6:6,9; 87:16, 18; 88:19 status 5:16; 95:16; 97:14 stay 34:21; 47:1; 59:21; 104:22 stayed 25:4; 35:18; 47:14 stays 27:11 steam 25:9; 26:5, 8 step 58:9 steps 117:24 still 16:22; 39:18; 45:6, 22; 46:20, 25; 47:4,16; 74:3, 6, 8; 84:22; 92:12; 100:15,21,22; 101:5; 111:10, 11; 113:17 stock 100:19 stood 65:15 stop 28:21,22; 118:12 straight 10:14; 40:6,7 strictly 91:2 structured 33:17; 55:17; 75:18 student 8:6 stuff 58:8 subject 79:9, 11; 80:5; 113:20 submit 33:12; 57:9; 77:12 submittal 33:16,23 submitted 50:25; 56:14, 23 subsequent 32:23; 46:5; 51:12 substantially 108:10; 112:1 sufficient 107:5 suggested 78:6 suggestions 77:21 summarize 117:9 summer 16:4 supervise 8:20 supervisor 74:13 supervisor's 75:7 support 21:5; 35:10; 36:9; 37:11; 38:14; 39:16; 42:16; 43:5,8, 18; 49:15; 50:16; 65:15, 23, 24 support-wise 55:24 supported 42:24; 46:1 supporting 38:14; 49:10; 99:11 supportive 49:13 supposed 28:16,21; 48:13; 60:1; 70:16; 107:11,12; 110:12, 13; 112:11,12,16 sure 19:9; 21:8; 26:23; 30:6; 32:4; 37:6; 47:17; 48:12; 50:20,22; 52:2, 57:11,14; 58:14, 20, 22; 63:21; 66:9; 73:16; 78:15; 84:22; 92:6; 93:24; 94:2,6; 112:3 suspect 90:22 sworn 4:3 system 26:6 system-wise 25:9 T
table 16:2 tabulated 71:15 tackle 21:2 tag 100:10 talk 5:23; 39:6; 45:21; 73:11;82:1, 12; 87:13; 88:8,13; 93:23,23; 94:3, 4; 99:16; 107:2 talked 6:13; 42:19; 48:13, 25; 49:5; 63:10, 10; 69:4; 86:6; 87:19,21, 23; 88:2; 91:4; 94:9, 10; 100:7; 101:11,12 talking 18:11; 20:22; 22:8,15; 39:10; 41:17; 67:20,25; 71:16; 95:14; 101:6; 105:8,18 talks 88:7 targeted 79:20 task 17:18; 19:22 tasks 15:14; 17:9, 14; 22:9; 109:15; 110:2 team 34:16, 16 technical 9:19; 26:1, 17; 58:3; 65:14, 23,24; 109:13,22 tedious 25:14 telling 101:20 temporary 5:9 ten 102:20 Tennessee 4:10 term 32:5; 60:6 testified 103:22; 114:16; 116:6 testify 116:1 testimony 21:16; 28:10; 44:22; 52:10; 78:1; 106:25; 111:22, 112:22; 118:15 themselves 28:11 Thereupon 12:3; 22:18; 29:3; 30:17; 63:2; 70:6; 74:22; 76:20; 102:22 they'll 58:5 they're 25:20; 26:12; 27:16; 38:24; 42:25,25; 48:10; 66:18; 79:13; 97:11; 100:15; 107:5; 108:11; 112:12 they've 17:1; 59:22; 100:15; 119:16,18,19 thinking 48:5,7; 85:8; 90:20; 117:5, 13 third 65:16 though 31:19; 44:14 thought 83:7; 87:24,25; 91:4; 97:17; 99:25 three 4:19; 6:25; 13:10; 15:5; 24:23; 31:21, 22; 40:18, 18; 51:2,25; 53:20; 59:21; 80:14,19; 91:4 thwarted 20:3,24 tied 117:2, 2 title 93:11, 13 today 5:23 together 34:18; 51:16; 56:13; 76:7, 11; 77:11; 89:21; 119:14, 19 told 25:18; 40:6; 42:9; 49:1, 5; 81:20; 88:5; 89:5, 11, 12; 90:20; 91:7, 8; 92:3, 8; 98:25; 99:6, 19; 100:22,24; 108:19; 116:10; 117:17; 118:11 Tom 31:2; 33:1,2; 48:25; 50:15; 51:11; 52:3; 58:17; 61:2; 62:16; 63:24; 65:6; 115:7 took 7:6; 20:8; 25:1; 30:7, 7; 37:24; 73:4, 9; 77:4 topic 70:9 total 13:3, 5; 52:4 totaled 71:15 totally 61:4 Toward 18:4; 55:5; 79:11 20; 80:4 i
traffic 18:23; 10 5
training 5:13;31.
- 1 transfer 44:20, 23, 24; 46:2,3; 47:19; 48:11; 50:25; 101:12 transferred 37:5,8,10, 14; 41:20;45:5; 47:15; 48:1;49:22; 69:6 transferring 50:17; 101:17 transition 16:13; 111:17; 113:18 transitional 5:8 transitioning 59:3 transpire 118:13 transpired 10:8;73:1; 82:5; 89:18; 96:15; 98:25; 100:13 travel 36:8 tried 29:6,8; 35:6; 43:22; 44:3,4; 67:2; 89:2; 91:7; 102:7; 113:13,16,17 Trish 44:2 true 11:22, 24 try 20:22, 25; 32:17; 43:23; 46:22; 50:8; 53:5; 88:13; 111:17; 11"7"'
trying 10:14; 14 1 43:10;46:10; 52:,
60:25; 76:10;91:1, 12; 100:8; 104:24; 108:3; 111:2,5; 112:15 Turn 15:3; 30:19;75:5 TVA 5:5; 7:18; 8:14; 10:4; 24:21, 23; 37:22; 44:16; 70:1,2, 12;73:17,17; 81:12; 86:25; 88:20; 90:5; 106:3; 110:5; 116:7, 21; 118:19 TVA's 30:21; 45:2 TVAN 26:1, 19; 109:22 two 4:19; 8:3, 25; 11:7; 13:1, 11, 25; 15:5;16:12; 19:16; 20:4, 5; 24:13,18, 19, 21, 21, 24; 25:25, 25; 26:7,17, 24; 27:1; 28:1, 4; 29:7; 45:15; 46:12; 51:3; 53:20; 54:3; 55:18; 56:1; 59:23; 72:7; 73:14; 74:3, 8; 76:2 two-page 22:22; 76:25 tying 111:18;116:18 type 5:13; 20:14; 24:3; 43:5, 5; 47:23; 85:23; 90:6; 109:17 types 104:1; 10C typewritten 79:..
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"o IftWZ_ TT V-*-4.-
Au uic manuer or (Yary L Fiser v.
Tennessee Valley Authority Ronald 0. Grove January 29, 199t January 29, 199
ultimate 62:21; 63:25 ultimately 9:6; 10:2,7; 61:6; 112:18; 115:3 under 16:2; 21:13; 26:7; 33:20; 35:10; 53:13; 80:2; 109:8; 111:12 undergo 5:12 understandings 105:17 understood 9:15; 47:18; 108:1; 113:6 underwent 11:1 unique 25:22; 27:5 unit 24:21 units 24:21 unless 69:23; 100:16; 101:3; 111:1 up 6:12; 16:24; 17:22; 33:11; 37:20; 38:25; 40:6; 52:14; 59:6, 17; 67:18; 68:7; 70:23; 72:21; 73:16; 81:3; 82:9, 11; 84:5; 90:13; 94:3,4; 96:11, 20; 99:1,4, 7; 101:19; 104:25; 105:2; 115:6; 118:20; 119:7,8 upcoming 46:9 upon 45:9 upset 85:2 urgency 68:8 use 11:15; 23:12; 61:24; 109:24; 110:11 ujsed 18:24; 23:18; 80:23 user's 29:17 usually 96:22 V
vacancy 34:13; 41:21,23 vacant 9:1; 10:16; 45:15; 46:21;47:5; 116:18; 117:4,11 vacate 11:16 vclue 102:8 variable 36:14 various 17:3,14; 66:22 versa 15:21 versed 106:2,5 version 23:16, 17,24,25 versus 27:18 vice 15:21 view 82:20 viewpoints 67:5 voiced 62:13; 84:18 Volar 98:21; 99:1, 5,16, 19; 101:7 volunteer 81:1 vying 14:11;46:19 I
W wait 33:8 waiting 48:10 wants 38:23; 72:7; 88:8; 102:14,15 warned 25:14 Waste 56:10; 114:9 water 23:3; 24:20,21,23; 26:8 Watts 27:9; 65:12; 66:9, 18 way 30:7; 45:25; 46:16, 21; 47:12; 50:16; 58:22; 59:2,25; 61:5,6,7; 63:19, 22,25; 66:18; 75:18; 91:12; 100:21,24; 101:22; 102:10,15; 107:11,12; 112:11,14,17; 113:4 ways 15:6; 45:15; 46:12 weak 75:11 weaknesses 80:23 week 96:14 weeks 9:9 Welch 6:13,15, 23;7:4 welcome 43:13 weren't 40:14 what's 18:22; 38:22; 39:7,15; 95:15; 96:16; 97:13; 107:21; 110:20 whenever 37:25 whereas 26:7 whistle 83:14 whole 16:10; 26:6; 38:8; 58:19; 95:21; 113:7 wife's 4:14 willing 45:25 Wilson 10:3; 48:9; 51:20; 58:17; 65:6, 19; 67:11,20; 68:18; 69:1; 73:2; 76:13, 17; 77:24; 81:20; 83:1, 2, 2; 85:10; 113:14; 114:25; 116:11 winner 71:17; 72:6; 98:18 within 11:3; 35:12 without 39:18 witness 4:2; 9:18,23; 28:20,24; 29:5; 101:19; 103:11; 115:12; 118:20 wonder 42:15 word 23:12; 29:11,11, 14,14,25,25; 38:11; 80:11 words 11:15; 16:15; 18:23; 30:3; 54:6; 55:6; 99:11,17; 109:12 wordy 57:17,22 work 16:15; 20:14; 32:17, 17; 37:12; 38:15; 43:23; 44:4, 16; 48:22; 54:14; 58:18,21; 59:7; 60:1; 66:24; 69:24; 72:11; 82:4; 87:1; 88:2; 105:3; 107:12; 112:11; 116:21 worked 13:9; 40:23; 44:1, 3; 51:15, 20; 54:11; 69:11, 19; 83:3, 10; 89:21; 91:25; 105:20; 119:14, 19,23,25 working 21:13; 29:9; 37:11;61:24; 62:17; 88:10; 99:10; 106:10,14, 18; 109:13, 18,22 workload 19:13; 56:2 workplace 85:15 works 44:15; 97:10 writing 98:11,15 written 7:7; 13:12; 24:16; 82:7; 104:4, 8, 10; 107:9, 21; 113:4 wrong 43:9; 86:20; 110:21 wrote 24:18 Y
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zip 4:10 Hall & Associates (423)267-4328 CDO00S03 (olI fVlf~fnntf-. *'A 1W;im-lT-Ser;vf,ntM
Lawyer's Notes CDO00804
S PO NO.
POSITION _
a ESCZPTI0N T
r Posi tifon Title
- 'E" TRY ANI t
VaRONME'TAL PROTECTION SENIOR PROGRAM MANAGER Cha t t~anooca Organization Titles:
Groua "VAN Operations Division Department Section
--% e..
Nuclear Operations operataions Service$
Chemiitry and E"nvIronmental Protection i-
I-A
Social Security Numfber,
Pay Group or Schedule/Grade Pg Effective Date 1.0/1794 Incumbent's Signature Z
L Supervitsor' s Signature HRli/HRO'5 Signature G.
G.
jf'Y' Reports to (Title)
Manager.
Chemiltry and Environmental Protection Supervi sory
,,Approved 3ob 'Code:
2581 POSITION EVALUATION:
7 o13
_K-9 Slo10t 350 "K-H P ts Function Code:
L21.
EVALUATION DATE:
9/2119L E3 (38) 13Z P-S Slot P-S Pt:
E1P Acct Slot Schedule/Pay Grade:
PG-8 EC&R REVIEWER INITIALS:
TVAN/JEC 132 Acct P9s 614 "56-22-22 Total Pts Profile p.,.
TON PURPOSE:
Provide senior technical direction, support, and oversight to the TVAN chemistry and environmental protection programs. The incumbent serves as
.e primary liaison b-tte' the sites and TVAN corporate.
The incumbent mnages the implementation of directives. standards. -ind pol*,es and regulations.at all TVAN sites.
The incumbent is the lead individual for r
esuring that Mi.
n stan.srds are set and maintained at both corporate and the sites. His/her efforts are focused on astiblishing/maifltaininug a chemistry and environmental program that enhances the safe and reliable operation of TVAN sites.
DIMENSIONS:
Einoloyte:
hanagement/Professional/Techntic
- 0 Clerical/Technical Support M 0 TOTA:- 0 Operating - 0 Payroll
- 0 TOTAL - 0
/DOstribution:
Original - Hu.can Resources IiHcrorecords Unit, Knoxville CDOCCS0S Copy poration Organizaton/(as needed)
Copy-Central Off ike of Union Having.,.ur.i Copy - Employee i-__*IZA (6'&Eo-C?1-A 7-91)
C7-:913 Page 1 or'2 8447u 46 Exhibit 5 Location
.ja
iA1E Gary L. Fiser SSM EFFECTIVE OATE
__ _/__/
(First)_(?li ddlea (LAS t) 2RYN(TPAL ACCOtJ*&-t-
- 1. Provide trchnical and programnmatic expertise for Implementation of the TVAN chemistry and environmental protection programs at individual sites.
Provide direction as needed for project managers managing projects at his/her assigned site. Oversee the activities of other personnel assigned support functions for meeting the responsibilities of this -position.
- 2. Assist site management with intervretation of chemistr-and environmental policy: review and concur with site procedures and other IVAN documents that may impact the programs.
Promote optimum consistency among site programs.
- 3. $econfnend chemistryand environmental protection goals and specifications that are consistent with boist Industry practices, and assist with the implementation of actions to achieve them.
Cirect the performance of site evaluations of the chemistry and environmental protection programs to ensure consistency and compliance with established requirements.
- 4.
ODirect review and concur with root cauTe analyses for identified chemistry and environmental protection progr-am problemrs. direct the development of corrective action plans, and coordinate the implementation of approved corrective actions.
S. Direct the performnrince of regulatory and lIcenstin reviewi of chemistry and environmental issues, recommend TYAH rasponses or positions, and concur with responses to external organizations..
- 6. Ofre"C the development of chemistry and enviromnental protection training and qualification criteria.
Conduct specialized seminars on chemistry and environmental protection technical topics as requested.
- 7. Provide lone-term/large scope Proeect support to the plant sites for major chemistry and environmental
'projects. Provide short-term plant problem response to the sites as requested.
- 8. Perform long-terin data trendimn and assessment of key chemistry and environmental protection data.
Provide appropriate feedback and corrective action proposals as necessary.
Prepare an Annual Chemistry'and Environmental Protection Report; review for concurrence with site staffs and issue.
- 9. Function as a primary TVA representative to the EPRI PWR Primary Water Chemistry Comitteeo EPR./SGOG Chemistry Cormittee and EPRI BWR Owners Group Chemistry Cov=ittee and the appropriate environmental protection ccommittees.
Coordinate the release of chemistry and environmental data to outside organizations as authori zed.
- 10. Serve aT a chemistr-y and environmental oroatection special4ist or alternate dose assessor, or environmental assessor, in the event of a radiological emergency.
Remain on call 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day unless relieved by other approved personnel.
- 11. Actively encace in weecklv olant toura, personnel interviews, observation feedback and working meetings during routine operations and plant outages.
Coordinate with sites the preparation for INPO evaluations and t
)'esponses.
- 12. function as team leader and provide technical evpertise In support of the Quarterly Chemistry and Environmental Protection Team assessments for TVAH sites.
- 13. Chair working grouys such as radicanalytical working group, and analytical working group, the radiological assessment review committee.
- 14.
Develoo rysearch and development; prilect issuer and act as technical coordinator.
Compile data and research positions that support requests for systems specification changes and engineering design changes.
- 11.
~CDOOCSCG
-G~yL
,ie SSN EFETV DATE.
10174 Cirst)
(ttiidle)
(Las t) 7 't:
1;as a senior technical advisor and assist In carrying out site specific environment I Ptrwitting tasks
,uch as NPOES, NEPA. underground storage Links, asbestos, 404 Permits, landfill/disposal. mixed waste.
Material storage. stor= water.
- 2. Provide direction~ in the Implementation of site hazardous materials control plans, the proper handling and shippi ng of hazardous waste. mixed waste and solid waste.
- 3. Function as the TVAN senior technical expart to the sites in the arias of Chemical Traffic Control plans.
bulk chemical control. handling of spills, NWR and SWR operational chemistry control, laboratory QA/IIC.
radioactive effluents, deminralizatien. post-accident sampling requirements, and falled.fur-1 action plans..
- 4. Develop and interpret detailed data trending in the areas of primary and secondary chemistry for both RwR's and PWR's auxiliary and makeup sys-tems chemistry, radioactive effluents, site Oenvironmental discharges.
Provide specific feedback for improvement on aS routine basis.
- 5. Make recommendations to TYAJI sites on resin type for usage in all plant applications.
Assist the site in the development of resin specifications and analysis.
- 6. Understand the purpos.e and provide direction to TVAX site staffs in the Implementation of such programs as ETA/Boric Acid/Xolar~.ratio control, secondary PYR Chemistry Control,.IGSCC. mitigation. IIWC and Zinc injection programs for, MY's, zebra mussel/clam control In service water systems.
- 7. Function as the senior technical, expert and provide direction to the TYAN sites In allI aspects of 'PWmR steam generator chemis try/corrosion ca~ntral which Include hideout return evaluations, sludge lancing, chemical cleaning,and corrosion product transport minimizati on.
- 8. Function as the senior technical expert and provide direction to the TVAN sites in the areas of 0001 and radiological effluents managemen t.
Coordinate all regulator/ updates.
MINIMUM OUALIFICATTOHS:
nager should have a bachelo'rs' degree or the equivalent In chemistry, environmental sciences, or chemical tring, including formal training and experience in management.
The manager shall havi at least eight years
!essional experience in applied chemistry or environmental protection, with experience at an operating M1._.4r plant preferable.
The manager should have detailed kinowledge of modern analytical and radioanalytlcal
,equipment and methods used for performing all required chemistry, and environmental analyses at TYAN sites which includes equipment operation and capabilities.; He/she must possess a very good knowledge base in the areas of environmental regulations, PWR and MW chemistry control guidelines and permitting requirements.
An advanced degree and ten years experience at the professional or managerial level are desirable.
TVA lZA CC&ED-CPSA 7-91) C7-911 page 3 of 3o.... COS8G. 04191, 7/11/94 CDOCOSC7 I
-Na-me Position Title Location Organization Titles:
POSITIOa Chemistry Program Manager (PWR)
Chattanoooa PD NO.
960383 N DESCRIPTION Social Security Number Pay Group or Schedule/Grade PG-08 Effective Date Group "W'VA Nuclear Operations Nuclear Ooerations Division ocerations Suoport Corporate Radiological Control Department and Chemistry Section Incumbenrs Signature Supervisor's Signature HRMMHROs Signature Reports to (7fle)
Corporate Radiological Control and Chemistry Manaoer FOR COMPENSATION PLANNING AND ANALYSIS USE ONLY CP&A REVIASW:ER POSITION EVALUATION:
EVALUATION DA'TE:
7116/1H INITIALS:
JEC K-H Slot Approved Job
Title:
Organization Code:
ZZ;U u E3 (38) 132 E1P 132 K-H Pts P-S Slot' P-S PtS Acct Slot Acct Pts PROGRAM MANAGER 614 TotalPts-Schedule/Pay Grade:
PG-08 58-22-22
=
Job Code:
2581 Supervisory Code:
N Function Code:
120 POSITION PURPOSE:
Provide senior technical direction, expert support, ovrsight, and Program/Project management in the chemistry programs of the IVAN facilities. Develop programmatic requirements for chemistry management programs. The incumbent serves as the primary flaison between the TVAN sites and TVAN corporate. The incumbent manages the implementation of directives, standards, and policies and regulations at all TVAN sits. The incumbent is the lead individual for ensuring that high standards are set and maintained at both corporate and the TVAN sites. His/her efforts are focused on establishing/maintaining a chemisitruy program that enhances the safe and reliable operation of TVAN sies.
DIMENSIONS:
Typical size of projects - $10M - $10MM. Annual projects managed - 10 Other
- 1.
Incumbent acts as Manager. Radiological Control and Chemistry, in his absence with the signature authority and control of the budget ($3MM) associated with that position.
- 2.
Serves as Technical Contract Manager establishing, controlling, and maintaining multi-site chemistry services and material contracts. (Material and Services Annual Budget 310MM)
- 3.
Serves as Radiological Assessment Manager in the event of a nuclear site emergency.
Distribution:
Original - Human Resources Microrecords Unit, Knoxvile Copy - Operations Organiation (as needed)
Copy - Central Office of Union Having Jurisdiction Copy - Employee CDOOOSCS TVA 12A [HR 7-91] Page 1 of 2 960383.doc I
.I
POSlTI6tN TITLE:
Chemistry Proaram Manacer (PWRP NAME
-urr Maae*("
PD NO.
960383
.F
~ r J ( MiFa z te
)
(L a s t
S E F F E C T I V E D A T E
'IFUNCIPAL ACCOUNTABILITIER:
of ResDonsibilities
)N. WBN (PWR) Chemistry Program
=.ondary Chemistry Program Support fOr TVAN PWRs Post accident sampling systems Cooling tower chemistry 0
Software control program Analytical Working Group Management for all WvAN sites Multi-Site Technical contract Management such as Ecolochem. Dionex, PASS services for all TVAN sites
- 1.
Provide technical and proorammatic exoertise for implementation of the TVAN chemistry program at individuakites. Provide for project manager.s managing projects at SON and WBN.
Oversee the activities of er personnel assigned support functions for meeting the responsibilities of this position.
- 2.
Function as the WVAN senior technical expert to the sites in the areas of PWR Secondary chemistry control.
- 3.
Function as the W eAN'senior technical expert and provide direction in the jmplementation of such programs Molar Ratio Control. Secondary Chemistry Optimization. and
.znc injection.
Is
- 4.
Assist Management with interpretation of chemistry policy - review and concur with site procedures and other I documents that may impact the programs. Promote optimum consistency among site programs.
- 5.
Recommend chemistry program goals and specifications that are consistent with best industry practices, and assist with the implementation of actions to achieve them. Direct the performance of site evaluations of the chemistry -program to ensure consistency and compliance with established requirement.
S.
Direct review and concur with root cause analyses for identified site chemistry program problems, direct the development of corrective action plans, and coordinate the implementaUon of approved corrective actions.
- 7.
Direct the performance of regulatory and licensing reviews of chemistry issues, recommend TVAN responses or positions, and
.,:.concur with responses to external organizations.
S.
Develop and conduct specialized seminars on chemistry technical topics as requested and conduct periodic training related observatbonsJprovide recommendations for improvements as necessary.
S.
Provide long-term/large scope project support to WBN and SON for major chemistry projects.
Provide shortterm plant problem response to the sites as requested.
- 10. Perform lone-term data trending and assessment of key WBN and SON Secondary chemistry data.
Provide appropriate feedback and corrective action proposals as necessary. Prepare an annual WBN and SON chemistry report with review and "icurrence with site staffs and issue.
.otion as a TVAN representative to the EPRI PWR water chemistry committee. PWR Owners Group Chemistry Committee.
d appropriate industry and regulatory workshops/conferences/seminars. Coordinate the release of chemistry data to outside
- 12. Serve as a Chemistry specialist, does assessor, or RAC/RAM in the event of a radiological emergency. Remain on call 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day unless relieved by other appropriate personnel during emergency events.
- 13. Actively engage in plant tours, personnel interviews, observation feedback and working meetings during routine operations and plan' outages. Coordinate with sites for INPO evaluations and responses.
- 14. Function as team leader and provide technical expertise In support of the Quarterly Chemistry Team assessments for TVAN sites.
.S. Chair Analytical Working Group for all T-VAN sites and ERMI.
- 16. Develop multi.sfte contract technical soecifications and act as technical contract manager for applicable contracts such as makeup water. Dionex services. PASS services, bulk chemicals for all sites.
- 17. Act for the Corporate Radiological Control Manager in his/her absence.
- 18. Provide effective communications of the Corporate Chemistry Program to the TVA nuclear sites.
MINIMUM QUALIFICATIONS:
The Incumbent should have a bachelor's degree or the equivalent in chemistry, environmental sciences, or chemical engineering.
including formal training and experience in managemenL The incumbent shall have at least eight years of professional experience in applied chemistry, with experience at an operating nuclear power plant preferable.
The incumbent should have a detailed knowledge of modern analytical and radioanalytical equipment and methods used for performing all required chemistry analyses at "WVAN sites which includes equipment operation and capabilities. He/she must possess a very good knowledge base in the areas of PWR and BWR chemistry control guidelines requirements. An advanced degree and ten years experience at the professional or managerial level are desirable.
Incumbent in this position is subject to rotational assignment.
"1
[HR 7-91] Page 2 of 2 CDO008C9 S6_---.*.doc "
A..-
I PERFORMANCE REVIEW AND DEVELOPMENT PLAN (FOR MANAGERS AND SPECIALISTS)
(For COO & TVAN Use Only)
Name GARY L, FISER Position Senior Chemistry & Environmental Soeclalist Review Period 10/1/24 to 9/30/95 Date of Annual Performance Review Social Security Number A I
M_
Organization Chemistry 6 Environmental Protection PERFORMANCE RATINGS DEFINITIONS Exceeds Expectations Meets Expectations Meets Some Expectations Unacceptable 0
0 0
0 0
WVA Individual far exceeds expectations for this objective or expectation.
Frequently makes significant contributions well beyond Job responsibilities.
Individual consistently meets expectations for this objective or expectation.
Employee knows and performs the Job well.
May occasionally exceed expectations In some areas.
Fully competent and valuable employee.
Individual partially meets expectations for this objective or expectation.
Improvement in this area is necessary for the employee to fully meet expectations.
Performance does not Indicate successful completion of all assigned responsibilities.
Individual consistently below expectations and performance is unacceptable for this objective or expectation.
May require more supervision than expected.
Improvement required to meet expectations.
QUARTERLY REVIEW DISCUSSIONS 3ird IteIi dsie
$4 4th
- In ti I
Oa*Di scust a E2-95] I..... 30286 F
Ioi ti*F a -d-2nd cum.51soilf
PEF ODf I-
- 1) Meet the expectations of the Corporate Chemistry
& Environmental Protection (CSEP)
FY95 Business Plan. Management Expectations and Goals as determined by the Corporate C&EP Task List.
- 2) Maintain focus on C&EP/TVAN Top Ten priorities list.
- 3) Support adherence to the FY95 budget requirements
& continually look for effective ways to reduce costs.
ICE ES PERFORMlANCE OBJECTIVES Establish specific results or goals that this employee is expected to achieve during this rating period.
(Additional pages may be used as necessary).
Satisfactory results achieved.
Satisfactory results achieved.
Satisfactory results achieved.
Function as lead chemical engineer In support of Excellent effort; Gary played a key role in assisting WON site startup preparation.
site staff In addressing program deficiencies/solving problems in startup preparation.
- 5) Visit TVAN sites on a routine basis (consistent with REP responsibilities) and exhibit a high level of support for site activities.
Site badging to be accomplished as required.
- 6) Pursue a high level of technical capability by personal development and attendance at appropriate conference/meeting.
- 7) Manage Implementation of contract.
- 8) Assist in development of chemistry report for WeN reviews.
multi-site raw water monthly and annual and perform routine data the Excellent effort; Gary consistently exhibited a high level of support for site activities.
He was a key player in helping to address critical issues at all sites.
Satisfactory results achieved.
Satisfactory results achieved.
The annual chemistry report was completed.
Monthly reporting has started, but Improvement Is sti l needed to get a complete report Issued by the site staff on a consistent basis.
1AJiel It d%.%
r4 nt 1i
- 4.
1 a-PERFORMANCE
SUMMARY
Review performance against each objective.
Discuss results achieved, areas of success, and improvements needed.
Cite examples where appropriate below.
Then mark (X) In the column on the right which best describes the employee's performance.
15%
15%
5%
5%
15%
5%
5%
5%
X
/
EXPECTATIONS
-I U N
A C
C E
P T
A L
I S
S1 E E
E E
E X
C E
E D
X X
H E
E X
x X
X X
X T
S S
0 H Performance uObjectives -
1U Percent of Total Weight-------_
Tota W
E I
G H
T 4)
T 0
T A
L 45 45 15 20 60 15 15 15 0
)
h I
?
k I TA
%OO e-3 I
aJ
-Total
/ \\
PERFORMANCE BEHAVIORS BEHAVIORS PERFORMANCE
SUMMARY
EXPECTATIONS These behaviors come directly from TVA's workforce Review performance against each behavior.
3 2 -1 mission.
Employee and supervisor jointly decide Discuss results achieved, areas of success, U
which of these behaviors specifically apply for and Improvements needed.
Cite examples W
N the review period.
Choose up to six behaviors, where appropriate below.
Then mark (X) In the E X N
A with no behavior receiving a weight of less than 5.
column on the right which best describes the I
E C T
employee's performance.
G E
C 0
H E
T E T
T X
S P A
C H T
L E
E S A E
E 0
B D T HLl
- 1.
High Performance Sets clear goals for self and others; includes the needs of customers in setting these goals; shows persistence and dependability in accomplish Ing goals; looks for ways to make projects successful rather than finding reasons for failure; takes personal responsibility for ensur Ing results are achieved.
- 2.
Teamwork Shows a team orientation by placing team goals over Individual goals; effectively commun icates information needed for task completion; contri butes actively to group projects and meetings; develops positive and productive relationships with other team members; works to turn conflict Into "win-win" situations; looks for shared goals with other workgroups.
- 3.
Diversity Seeks and uses a broad range of experiences, backgrounds, and points of view to achieve organizational goals; treats co-workers with dignity and respect; encourages and supports actions to eosure a representative demographic mix in the workforce.
- 4.
Innovation Develops origihal, cost effective, and resource ful approaches to work situations; encourages and recognizes the Initiative and creativity of
) others; takes appropriate levels of action to
- =" get the job done right.
0 0 0
W L
Y3 OJ J Excellent effort; Gary has been very proactive in this area.
He consistently takes the lead in finding solutions to problems to make projects/programs successful and assumes personal responsibility.
Excellent effort; Gary Is a superb team player.
He Interacts well with peers and site counterparts.
He has worked well at all sites and has been Invaluable In keeping key programs moving forward.
He has often been asked to step Into crisis situations and has always met the challenge.
Excellent effort; Gary always looks for and pursues cost effective and efficient ways to complete tasks.
5%
5%
X X
X 20 20 if J Is 90 A
A-h 1%
n
BEHAVIORS These behaviors come directly from TVA's-workforce mission.
Employee and supervisor Jointly decide which of these behaviors specifically apply for the review period.
Choose up to six behaviors, with no behavior receiving a weight of less than 5.
5.. Continuous Improvement Determines customer expectations; Identifies strengths and weaknesses in present work methods; uses Quality problem-solving tools and techniques to develop new and more effective methods; creates a non-blaming atmosphere while exploring past mistakes and future methods changes; evaluates continuous Improvement for self, suppliers, and customers by:
determining performance benchmarks, setting explicit, measurable goals, and measuring progress toward goals.
- 6. Coaching and Developing Sets clear performance expectations with each employee; provides ongoing feedback; works with employees to prepare individual development plans; provides support and resources for implementation of development plans; evaluates performance based on established expectations.
- 7.
Leadership Consistently communicates a clear direction for the workgroup; gains commitment and participation by modeling actions necessary to accomplish the direction; Implements an organizational or cul tural change that gives action to organizational vision; recognizes and rewards others for their contributions.
0 0
0A Communication Sends and receives Information clearly, accu rately, thoroughly, and effectively; verbal, written, up, down, lateral, one-to-one, and group communication.
PERFORMANCE SUMIARY Review performance against each behavior.
Discuss results achieved, areas of success, and improvements needed.
Cite examples where appropriate below.
Then mark (X) In the column on the right which best describes the employee's performance.
I I
S E lI E I Excellent effort; Gary always sticks with problems until they are solved.
He has the ability to work with site counterparts in getting good solutions/fixes In place.
He always strives to seek a win-win situation.
Satisfactory results achieved.
IVP. qj
g-yj, LYJ q
lotal EXPECTATIO1 PERFORMANCE OR W
E I G H
T X
-2 M
E E
T S
.0 3
H E
E T
U N
A C
C E
P T
A 8
T 0
T A
L E
X C
E E
0 X
20 15 5%
X iIORS
/IORS IV#% ojo %I--yjJ L4-yDJ q tota l 1 3
NS
t r
FORMULA RATING Objectives Rating Total -
230 Behaviors Rating Total 105 Overall Rating Total 335 EXCEEDS MEETS MEETS SOME Divided by 100 -
3.35 UNACCEPTABLE Below TVA 4L
- 93) C2-95] 5 I
PERFORMANCE BEHAVIORS BEHAVIORS PERFORMANCE
SUMMARY
EXPECTATIONS These behaviors come directly from TVA's workforce Review performance against each behavior.
4 3
2 -1 mission.
Employee and supervisor jointly decide Discuss results achieved, areas of success, U
which of these behaviors specifically apply for and Improvements needed.
Cite examples W
N the review period.
Choose up to six behaviors, where appropriate below.
Then mark (X) In the E
X H
A with no behavior receiving a weight of less than 5.
column on the right which best describes the I
E C
T employee's performance.
G E
C 0
H E
T E
T T
X S
P A
C M T
L E
E S
A E
E 0
D D
T M L
S S E
EI
- 9.
Interpersonal Skills Interacts with others in ways that enhance understanding and respect.
- 10. Judgement and Decision Making Shows readiness to take action based on factual information and logical assumptions.
- 11. Planning and Organizing Satisfactory results achieved.
5%
X 15 Sets goals and develops 'strategies for meeting goals.
- 12. Technical Shows familiarization and utilization of tools, equipment, concepts, methods, and procedures which are discipline specific and necessary for professional excellence.
- Performance Behaviors - 30 Percent of Total Weight Total 15
-1 4iTVA 41
Ell Strengths:
C Cr AELOPMENTAL NEEDS (To be comoleted by supervisor with emu inout.
Ability to work effectively with site personnel: total team olaver: excellent understandina of site operational chemistry.
Overall Continue supoort of the WON startuo effort: continue to focus on getting a complete WON monthly chemistry reoort Issued on a Dew. Needs:
routine basis: continue to focus on work Rlannina/timelv task completion, CAREER OBJECTIVES (0 - 3 years)
Employee's stated Career Objectives:
(Priority order)
(1) Hanmoer. Chemistry and Environmental Protection (3)
(2)
(4)
INDIVIDUAL DEVELOPMENT PLAN AREAS FOR DEVELOPMENT ACTION TARGET List specific knowledges. skills, and behaviors to be List steps which can and will be taken to DATE FOR developed.
Indicate areas of current performance address these development needs.
COMPLETION COMPLETION which need to be develooed with an asterisk (0).
(12-18 mo.)
(X)
Develop computer based skills Attend MS Word Processing'Trng TOO Items could not be Develop computer based skills Attend Lotus Freelance Trng TOD completed due to work Develop computer based skills Attend MS Excel I and II Trng TOD scheduling changes Develop computer based skills Attend hS Project I and II TOD affected by the loss of Develop computer based skills Attend Harvard Graphics Trng TOD 2 group members this Develop computer based skills Attend HS Access Database Trng TOO review period.
Develop computer based skills Attend MS Power Point Trng TOO TVA 4535 (1-93) [2-951 6
1
OVEALL SUMMARy OF PERFORMANCE:
- GarV's overall performance continues to be very good. His acaressive approach toward his tob has been evident in the chemtry oroora turnaround at both WVN and SOU. He has worked very well with all site staffs and Is Yery dependable In the followuo of Items they request of him.
Ills indeoth knowledge and understanding of site operational chemistry has proven to be a key attribute for our staff in assisting the sites.
EMPLOYEE ACKNOWLEDGEMENT:
(My signature means that I have been advised of my performance)
Employee's Comments:
EMPLOYEE SIGNATURE:
DATE: ;
APPROVALS:
SUPERVISOR SIGNATURE:
d DATE:.
ER&D REVIEW:
DATE:
NEXT LEVEL SUPERVISOR 7
/
REVIEW AND ENDORSEMIENT:
9wt\\JKl.O--V,v DATE:
i/Jq 0
0 TVA 453w "'9:3) [2-95) 7
(
Indicate weaknesses that you need to address if you fill thbi position.
- 3)
.Part of the accounta'oilities for this position is that of assessments. How do you go about assessing the effectiveness of a program and then to develop corrective actions for weaknesses?
- 4)
- If in the process of seeking conisensus from the three sites, you have one site that disagrees wvith the others, how do you resolve the issue?
- 5)
How much time should the individual that fills the position spend at a site and why?
- 6)
One of the requirements of the position is the potential to rotate and be assigned to fill a site position. How do you feel about being assigned to a site temporarily or_
permanently?
JAVlS Describe 3 projects/prdgras you helped to initiate, develop, ana complete i ie
-m Chemistry areas.
Z?
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'b 4j*4.4.
- 8)
What do you see as the main role for this position?
Describe the level of responsibilit)thsp have -n
./nt
.*A..t
.,.,to-,
success of the site Chemistry proi g a nsd an*otw d'oe M
t o
- 10) What is your method of getting work accomplished for the sites (i.e., how do yoq go 1,
about working out solutions and ffixing problems)?
tl
-4.22 Describe at least 2 chemistry concerns of TVAN.
l 12 (D
fine teterm "dent'ing" and where nhwdeitocr6 13)-ý What is Hydrogen Water Chemistry? How would Hydrogen Water Chemistry benefit BFN?
,-t Y"
- 44)
If an INPO evaluation determined that a concern should be a finding and you "disagreed, how would you attempt to resolve the issue?
CD000817
- 1
A It QUESTIONS FOR PROGRAM MANAGER. CiHEMISTRY (page 1 of 2)
I *
(*
What strengths do you have that will benefit this position? )
5)
- r.
QUESTIONS FOR t; 4 PROGRAM MANAGER. CHEMISTRY
.4a (page 2 of 2)6 (i)Discuss the INPO Chemistry Index.' What is its significance'?
(i6) Discuss your specific management experience and training.
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