ML030900732

TVA - Staff Exhibit 52 - Rec'D 06/17/02: DOL Deposition of Ronald Grover, January 29, 1998

ML030900732
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
Byrdsong A T
References
+adjud/ruledam200506, -RFPFR, 50-259-CIVP, 50-260-CIVP, 50-296-CIVP, 50-327-CIVP, 50-328-CIVP, 50-390-CIVP, ASLBP 01-791-01-CIVP, CD000761, RAS 6160, TVA-Staff-52
Download: ML030900732 (57)

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UONKR; 2003 AR I1 A IIt,- 43 In The Matter Of: OFFICE U iHGf I N '~E RULEMAKINGS AND ADJUDICATIO?,4S STAFF In the matter of Gary L. Fiser v.

Tennessee ValleyAuthority Ronald 0. Grover January29, 1998 Hall. &Associates 104 Tremont Street Chattanooga, TN 37405 (423) 267-4328 OriginalFilegrover29.asc, 123 Pages Min-UScriptS File ID:1867117625 Word Index included with this Mmn-U-Script CDOo6i 11 II F-emplO+e SeG-1o4 -SEy- a.

- I ei :T - esse -V I At h o ia h I

, 2 - .- - " ", II ,-_

• Konaci (3. Gro'e.

- Tcennessee MalcqAuthorityi - - -- ~

' "' ' Jnuarya 29, 199k I,

Pagel II]

pl Pi BEFORE THE OFFICE OF ADMINISTRATIVE LAW JUDGES UNITED STATES OF AMERICA DEPARTMENT OF LABOR I] ?NDEX Page Page 2 m

143 R IN THE MATTER OF Deposilon of RONALD 0. GROVER GARY L FISER. 5141 Direct Examination by Ms. Jones. 4 Cross Exarailon by Mr. Marqusnd 103 Comanart.

133 VS. NO. 97-ERA-59 1pi EXHIBITS TENNESSEE VALLEY AUTHORITY. 17 No. Dscrhn Page Rnpondert.

Pl 1 Postion Descrption 12

[11]

January 29. 1998 Pl 2 Postion Description 22 1121 3 Pertormanca Review and Developmert 1133 DEPOSITION OF RONALD 0. GROVER 1 Phan for Gary L Fleer 14

[141 4 Questions for Program Manager APPEARING FOR THE COMPLAINANT: 1111 Chemistry 76 119' 1121 COLLETTE R. JONES, ESQUIRE

[IC) CHAMBLISS, BAHNER AND STOPHEL 1133 1000 TALLAN BUILDING 114]

[171 CHATTANOOGA, TENNESSEE 37402 1151

[is] APPEARING FOR THE RESPONDENT:

1191 BRENT R. MAROUAND. ESQUIRE TENNESSEE VALLEY AUTHORITY p0 400 WEST SUMMIT HILL DRIVE KNOXVILLE. TENNESSEE 37902 B121 Also Present: Donna Green 1211 HALL AND ASSOCLATES 1

FM 104 TREMONT STREET CHATTANOOGA, TENNESSEE 37405-4145 P1 PR 423-2674328 Page 3 I[I The depositon of RONALD 0. GROVER.

M oaled as a wnss I the stnce d the pl Complainprt. taken by agreement on the 29th day of 14I jamuay. 1998, I the Tennessee Vlley Authoty.

i1) 121 en Chestnut Streets. Chaftanoogs. Tennessee.

Pi STIPULATIONS a

1n Depostion b being taken byagromen of 13 counsel for the plaintif ed the defndant. It 19 ae tVW the depostion shel be taken I z 110 machine shorlhand by Cathy H. Kerley. Notary Pubtc I111 a]d Court Reporlr. VtW the signature of the I; I-1 1123winess to the comrreted depositon ISnot w Kd, j

uJ 1133end tha th wIess n"y be sworn by the said 0

wj 1143NotaryPublc.

151t Isb further agreed tVal formarlres 1162 as to caption, notice. certicate ed a de of Ir 1171transmission a wahked, and thal the deposlion Is 113 taken subed tOthe usual xeptlionsa to 4) 151 trrelevncy. Incorrpetency nd hImterility, which

-Sl 0q ate reserved to the hetrng of the cause. except as 121i to th form of the questin.

CD000762 I i P13 L S 0 I0 0 l PRI I

Hall- & Associates (423)267-4328 r4in-u-scripta - (3)PageI -Page

,In the matter of Gary IL Fiser v. Ronald 0. Grove Tennessee ~alley Authority, January 29, 199 i

Page 4 Page f RONALD 0. GROVER, ~Ij MR. MAROUAND: That's me.

Called as a witness at the instance of the pm A: Oh, I'm sorry.

4"~jComplainant, having been first duly sworn, was pi 0: That's your attorney sitting next to 14examnined and deposed as follows:

14you there.

pil DIRECT EXAMINATION ms A: Oh, I'm sorry. Okay. No.

BY MS. JONES:

mi 0: Did you review any statements that you p~0: Mr. Grover, can you please state your m~had given previously?

Is] full name and address for the record.

(al A: No.

ir A: Ronald 0. Grover m a: Are you -aware of any statements that lici you had given previously?

III? "ii A: Yes. I believe I spoke with pil a: And are you mnarried? 1122Mr. Marquand before when this first came up and p'l A: Yes. 113] Ms. Cathy Welch. I believe I talked with her I14] 0: And what is your wife's name? li'l somewhat during -

1151 A: Sharon. l151 a: And who is Cathy Welch?

lie) a: And do you have any children? vilS A: She w.as the FIR person, human resources p~ A: Yes. 1171person, that was researching the case at the time fill 0: Do they live with you or in this area? 1181that it occurrcd.And since - I'm sorry. I

[162 A: I have threec sons, two live with me and lis forgot your name.

rWvone is in college. pq] MS. GREEN: Donna Green.

12il 0: Okay. What are their names? rzij A: Yeah. Ms. Green. I'm sorry, Donna.

A: Ronald 0. GroverJr., Myron Grover and rzn Ms. Green has taken over - has replaced Cathy rnl Brian Grover. mi Wclch.And also I spoke with a representative from

-,41 0: Okay. Do you have any other immediate r24] the Department of Labor about it. So I think there rasi was three people.

I Page 5 Pago 7 tij A: In the area? jIj 0: And did the Department of Labor take a M~ 0: Yes, sir. pi statement' ri A: No. p] A: Yes.

14 0: Okay.What is your current Position at 1H] 0: Did Ms. Cathy Welch take a s~tatment m]TVA? (5 independently of that?

i62 A: 'Well, I'm classified as a senior [' A:Yes. She took notes.! don't know m~ manager in corporate nuclear enginecring.And I'm M~ whether she put it into a form of a written - I

[SI really in a transitional state right now. I just 18wasn't asked to sign a deposition from Cathy.

gMrecently was - returned from a temporary Ru 0: YOU anticipated my next question. Did tial assignment at the Institute of Nuclear Power lial you ever review anything and then sign Wt kill Operations in Atlanta, Georgia. 1wavs there for 15 piij A: No. as far as Irecall. Now,Irdon't p2) months.And I'm scheduled to undergo five months li'i recall signing anything from a legal staff 113 of operator type training at the Sequoyab plant [13] stadpoint or anything like that.

114] starting February 16th. [14] a: In preparation for your deposition, did IIQ~ So I'm really classified in lik a pqsyou review any of those notes that'had been taken p~in developmental status, senior manager, but I'm a 1162 about your prior interviews?

pi~part oftthe corporate engineering organization p~ A: No. No. I did not.

1112reporting - 11t) 0: When did you begin withTVA?)

1120: Corporate engineering did you say? 11,1 A: February - I believe it was February A: Corporate engineering reporting to Jack [20 the 28th, 1994. It was the last day of Februa.ry in K>Bailey. rzil 1994.1 believe it was the 28th.!I believe it 0: Okay. In preparing for your deposition rzz fell on the 28th of February.

rzMhere today, did you talk to anyone other than ra 0: Where had you been employed prior to p'i Mr. Marquand? 124l that. CDO00763 rz A: Mr. Marquand? 12s) A: NewYork Power Authority for Mixi-U-S cript (4) Page 4-Page Hall & Associates (423)267-4328 Hall (423)267-4328 Min-U-Scripte (4) page 4 -Page

iLn twe matter of Gary I.. Fiser v. Ronald 0. Grover Tennessee Valley Authority January 29, 1998

- I Page 12 3age 14.

til A: Correct. Iqone for all the PG-8 level positions and there was 0: Okay. 12 a separate one for PG-7 because you had - it was a' K C2(Tereupon, the position rP1different level position:-

description was marked 0: I undcrstand.Thank you for -

141Exhibit No. I to the s]A: But that was the direction we were deposition of Mr. Grover 16 given to go - combine it, develop one PD.-

msand filed herein.)

p~0: Okay.And did you sit on the selection

[6] BY MS.JONES:

M 0: Letme hand you adocument which has, pi' board for the people who had bid into that gsl been marked as P12intiff's Exhibit 1, which is a R position, the position of PG-8 I'm referring to?

E10 A: Yes, but not until a~fter - I'm trying ri position description for the chemistry and li enviom~ental protection operation services, and riij to recall.As I recall, the position I was vying liq ask you if you can identify that. v12 for had to be - you know, had to be resolved pial A: Oh, me? [13] first.And once you - once the manager's position 113] Q: Yes, sir. ii~j was resolved, then - since I was selected to itui A: Oh, I'm sorry. psisfulfill that position, then I participated on the tis] 0: If you need to take a few minutes to (IC] selection board of the other positions.'

liot look at it. Iq 0: Okay.And who was chosen for the newly p,~l A: Yes. I'm aware of it. liel created PG-B positions that are reflected in

[la) 0: Is this the position description for liuj Plaintiff's Exhibit 1?

(¶93the newly combined chemistr, environmnental manager 120 A: As Irecall, Gary Fiser, Sam Harvey, p20 that you have just described for me? 121] E.S. Chandrasekaran and Dave - I'm drawing a blank r2ij A: The - yes.That's for the program Mj here. Oh, boy. He was the environmental manager pm manager position, PG-8. n~ at the time.

M31 0: PG-8? r24] MR. MAROUAND: Is that SorrelP A: Right.And then there was -

rms A: Sorrell. I'm sorry.Yeah. David K..>0: And that would be the position held by Page 15 Page 13 11 Sorrell was the fourth individual for those four lqj Mr.Fiser as well as your other two direct reports?

• ] spots.

(2] A: Correc.And then wheiiweccombined -

(l see, we combined and we had a total of five *3 0: 0kay.Turn to Plaintiffs Exhibit 1 14 positions.When you combine - when we combined 14] and the principal accountabilities that are s*chemistry and environmental, we had a total of five *s reflected on page two and three of that document.

• s positions that reported to the manager of that *4 General~ly in what ways does this position m combined group, the chemistry and environmental

• description differ from thecprior job description

• organization. iC]that Mr. Fiscr held in his position? -

pi And as itworked out from a practical- R A: The main difference was the addition of lial standpoint, it was, you know,three chemistry and liaq the environmental function into this PD.That was itil two environmental basica~ll positions, but there [113ithe main - because basically we - you know, from

[¶2] was one position description written for all, but lizi a chemistry standpoint, they fulfilled all these (q3 there was four PG-8 level positions and one PG-7 pq requirements.Thcy met all these - you know, t,4 position that formed that organization. ii'] these tasks, accountabil~ity principal,

[15] accountabilities.

ps)j A: But they all had the same basic ligl 0: Would it be fair to say, then,they ti'l position description. cIq were doing everything they did before in chemis-try, lisl 0: Okay. ei~but environmental duties were added to that List?

liq~ A: Which can be chemaistry and 5 Eiv] A: Yes. Ithink that's afair statementID 07 120 environmental.

p20 0: AUlright.CD006 0: And that position description Is -

r211 A: And vice versa. I mean, if you were in l.lected in Plaintiffs Exhibit 1?

= the environmental group, you could say the same gM A: Correct.

rA thing because, now, you know, we're doing 1241 0: All right.

1241everything environmentally plus now we're doing -

125 A: But there was two PDs.Thcre was this r25] we got the chemistry functions added into that.

(6) pae12-PagC15 Associates (423)267-4328 Hall & -AsSociates HaU Min-U-Script Min-U-Scripts (6) Paee 12 - PaRe'l 5

Lu LIAC MaLLer ox wffary 1. U11Ser V. Ronald 0. Grover Tennessee Valley Authority January 29, 1998 Page 16 l Page 18 It) a: Okay. Excuse me for knocking feet here [II 0: During that time period was that m under the table. *2i cross-training or cross-assumption of duties, did m After this reorganization in I believe m it actually take place in your department' pi ud summer of '94 when Mr. Fiser was selected si P"1 A: Toward completion, no, it didn't.

I by the board on which you sat for the newly created *5 0: Okay.What, if anything, did occur?

e position that we've been discussing in Plaintiff's

• A: During that time period?

• l Exhibit 1, did he actually perform the m a: Yes, sir.

paenvironmental duties that are reflected in this q A: Well, we - one thing, I guess, that pi revised job descriptions Mukind of -

110 A: No.At the time the - the whole °l Q 0: And before you start, let me ask for (II] objective was to over time, and we're looking at, pil your favor here.You're talking to a nontechnical i'l you know, a couple of years, probably two years at 1121 person.

psI best, to transition into having everyone in the p3l A: Okay.

1u" organization competent enough to do environmental itj a: So you have to be very basic with me -

isi work as well as chemistry. In other words, you 11s5 A: Okay.

lgs got - you're merging a group and you got chemistry 11 0: - and specific about what particular Q.

cpi people that are specialists in chemistry and you've 1i71 jobs or duties do you recall your chemistry folks 115got people that are specialists in environmental. qi taking on that was an environmental responsibility

[to] The plan was or the objective was to 11a before.

pq combine the group and form one PD and over time pq A: Tbere were very little, if any. I'll pil because you're getting smaller, you have less rzil give you an example. I would ask the chemistry pq resources, but you still have to accomplish the r2Z folks to help out with chemical - what's called p same job load, so that the focus was or objective tz3i chemical traffic controlling. In other words, ra' was to get everyone, you know, up to speed to be rZE able to function in both arenas, if you wiLl Not 124controlling - control of the chemicals used at the E2] plants.That was a chemistry function at the

'<-4 Page 17 I Pawg 19 jII to say they've got to be environmental specialists III plants, but it was - in years past during this m and chemical specialists, but at least they could m time prior to me coming it was moved into the pq function in various - in both capacities. Same pl environmental organization as a responsibility at p14thing in the environmental people, you know, get 141 the sites.

M them more involved in the chemistry function. cq So I had the chemistry people because eq And we started to do that.We started pq they were knowledgeable in that area and on 1 to do some there. But basically when we started rl occasion I had some of our chemistry folks would II off at the time, I mean, the chemistry people pe help out in assessing that area and helping them p focused primarily on the chemistry tasks and the pl make sure they were meeting the requirements in the 1101 environmental people focused on the environmental CIO cherical.That's one example.

(1] piece with the idea that we started doing some of III) But there was very little as far as 1121 that cross-fertilization, you know, and we would be p* environmental.And one reason is because the CIIIable to assign some of the chemistry duties and cI31 workload was so heavy in the chemistry area.That 1141 some various tasks to environmental people. Cu] was our main focus.We had some issues and some 11SJ Conversely, some environmental things 1151 challenges we had to deal with.We had problems at 1iq we would be able to, you know, get the chemistry 1161two of the sites. So we had to put our main focus p7l people to help on based on what the nature of the 171 on chemistry. C 0 1151 task was. I1I1 And then-and, conversely.we had CD0006 Hiei 0: Let's focus on the next year and a cigiseveral chemistry things that I had to ask for the mq half.And by next I'm referring to about a year rM environmental people to do, but there wasn't a big q1]and a half after thatJuly reorganization in '94, 12 shift or major, okay, I'm going to break this

= taking us up until approximately the beginning of m environmental ongoing task over and I'm going to pM 1996, which, if I'm doing my math in my head in put it into -you know, I'm going to give this -

P4i correctly, is about a year and a half. r24 assign this to one of the chemistry guys and he has 25 A: Uh-huh. >q to do it on an ongoing basis. So that didn't TAIn-U-Scripft (7) Pase 16 - Page 19 Hall & Associates (423)267-4328

iii Lne matter ot Gary L- Fiser v. -Ronald 0. Grovex

- Tennessee Valley Authority f January 29. 199E Page 20 Page 22 V] occiur. ~ij chemistry function.They carried out the chemistry 14 The other thing I wanted to mention rM function.I

,_mthat kind of thwarted our efforts to move in that r3 Q: Okay. Could you assign a percentage l~ direction w.as the fact that we lost two of the - 141 figure to the amount of time that your chemistry M two of thc environmental people that hired in Msspecialists including Mr. Fiser performed any kind 16i during the merging found dther jobs. So Jim lsl of environmental responsibility.

pn Mantooth left shortly after the reorganization and m~ A: It would have probably been less than pi Dave Sorrel] left and took another position, you MI five percent. I mean, if you're talking about uj know, six months - several months after that. m]aggregate time and look at the numbef of tasks we tic] So - so we were - you know, because, wjq gave them -

uItyou know - those individuals were long-standing pii Q: Yes, sir.

1121specialists in the environmental area in the (12] A: - you know, you're probably looking at 113] five percent, less than five percent.

(13l corporate organization. So one of the things that 114] 0: AUl right.Thank you. Since we're 1143you need to make this type thing work is you've got uisi talking about position descriptions, let's go on to lis to have your expertise there so you can 116] the next position description that's going to be at lisi cross-fertilize. ci'i issue in this lawsuit.-

gii1 Okay. SO with losing that piecce,now [it] CThereupon, the position uita we had to bring in new people that didn't have - description was marked lip] maybe didn't have the level of experience that lID] Exhibit No. 2to the ra these individuals had, so - but you're set deposition of Mr. Grover 121] backwards because once you lose a person, you know, 120 and filed herein.)

lz2 you're talking six, eight months to try to fil 1211 , BY MS. JONES:

120 that position. rzn 0: Let me hand you a two-page document f241 So that effort was really thwarted, if pi that's been identified as Plaintiff's Exhibit 2,

. I1you will, to try to do that. So we pretty much - 12'] which is the PD-8 description for the chemistry 12sl programn manager and the initials are PWR and ask if Page 21 lil and that combined with the fact that we had some M mountains to climb to - you know, to tackle in i you can identify that.

p~l the chemistry arena, we had to focus - had to have 12 A: PWR? Oh, okay.Yeah.That's pi abbreviations for pressurized water reactor.Are-14 the chemistry people to focus on the chemistry

'14you asking am Iaware of this?

iq things to get - in support of the plants to get us pi 0: Are you familiar with this?

16]back - get us where we needed to be from a pi A: Yes.

m chemistry perspective. *i Q:Okay.Andisthistheposition -

'] 0: Let me make sure I understand your

• description that was posted in approxuimnitely June z answer herc.Would it be fair to say, then, that M,of 1996?

ISO between July '94 and January of '96, Mr. Fiser 1101 A: 'When you say - you said posted?

pqs performed and all your chemistry specialists before pi, 0: Was this a position that was - when I, 1121 performed essentially the same functions that they 1121use the word posted, I mean competitively bid for.

113] had performed prior to working under the new job In3] A: Well, I don't know.This was - I'm 114] description that is Plaintiff's Exhibit I? ii'] aware of - of - in context I'm aware of this its] MR. MARQUJAND: I object to that.Thatt ciss particular position description. I don't know 1'6] mischaracterizes the previous testimony. 116] whether this was the Latest vcrsion.You know, I p~ can't tell you whether this w.as the latest version 1,7 MS. JONES: I'm asking him if it's 115] that was used for the, you know, posting of the lit] fair. I

[IS] BY MS. JONES: l19] position and so forth. I mean, it's dated July the (20 16th, 1996.

oj 0: If it's not, please tell me how it is 1211 I can't recall whether, you kn'ow -

not. pm when I look at it, I'm aware of the information A: Well, the only thing I would add, like (23 there. It looks like there - you know, if this rz3] I said before, wams I did ask the chemistry people l24] wasn't the latest version, it was close to the 12'] on occasions to do some environmental function. r25] latest version; okay7

? CD00076 7 12s] But functionally, yes, they basically did the - I MAn.U-S crijtt (8) Page 20-Page 23 Hall & AssocIates (423)267-4328

&-Assokiates (423)267-4328 ' mift-U-S&ipft (8% Page.20-Page23

Ronald 0. Grover Tennessee Valley Authority January 29, 1993 I,

Page 24 page P-

~It Q: Okay. ili TVAN F-rdor technical expert to the sites in the p A: I mean, when it got to this stage, it r* areas c. PWR secondary chemistry control, okay, pj was either little small changes, pen and ink type pi which is different from BW1R chemistry control.

j4 things, you know, the typo, but the content - you i' Q: Okay.

cs know, the basic content was essentially the same.

• A: Now, that's where the steam generators

[8 0: Okay. Let's focus on tKat content. In *s come into play.That whole systm chemistry is -

pi ComparIng - taking that job description and I pi fits in under number two, whereas, you don't have

• comparing it, by that one I mean Plaintiff's cii steam generators in boiling water reactors.

pij Exhibit 2, in comparing it to Plaintiff's m 0: But in the prior job description that 110) Exhibit 1 - l10] is Plaintiff's Exhibit l, were those iiij A: Uh-huh. piii responsibilities included?

1121 0: - what are the essential differences 1121 A: Yes.Thcy'rc embedded in here, yes.

ciii in duties between those two position descriptions? (iil They were embedded in hcre.We didn't make the 114) A: Well, one of the main Changes was 1141 distinction in this one.Are you with me?

Its) the - the exclusion of the environmental piece out [153 0: Right.

lpj of the PD as it's written. Okay.That was lil A: You knowto give you an example here,

[17i basically the main difference here. [17l well, number one here, page two, provide technical

[is] That combined with we wrote two PI~s for [Iio and programmatic expertise for implementation of livi the two chemistry positions that were to remain, 1153the TVAN chemistry and envirornmental protection pqoone for BWVR, which is boiling water reactor, rm programs at individual sites. So we didn't make ai~lbecause TVA has two units - two unit boiling water r~il the distinction. It was all rolled into one pm reactors, and one for PWR, which is primarily rM statement.

iaii pressurized water reactor, which TVA has three pq 0: Let me make sure I understand you,

[241 sit es or actually two right now that function. rm then. So statement number one on page two of ia2j So the main difference was that you rgj Plaintiff's Exhibit I incorporates those duties I

Pago 25 Page 27

[Ill took the environmental piece back out of this, but [13 that you have identified as statement number two on pi essentially, you know, from an overall sense the maPlaintiff's Exh ibit 2, pi chemnist~ry functions in here, chemistry rgj A: Correct.

14 accountabilties, stayed the same. p41 0: All right. Is there anything else on ps Q: Okay. *I Plaintiff's Exhibit 2 that is unique to the PWR 18 A: But they were split somewhat between

• chemistry position?

[7 the PWRand the BWR. Someof the things that - rn A: No.The only difference is that we l8] you know, PWR or BWR focus we put in the BWR and m specify - you know, we specified the plants, the Mi then PWRs was like steam generators are systermlwisc M PWR plants, Sequoyah, Warts Bar. So you reference 11012 parrof the PWR, not part of the BWR.So thlt [10] those.And then the BWR ones you would reference

[11] control - that chemistr controlled that equipment Icilj the BWR, but the function stays the same. So, you

[123 built into this particular one. [121 know, the main difference is you got a different cis1 0: Okay. Now, atth c risk of being [13] chemistry program for FWRs than you do BWRS and p'l tedious because I'M, again, as I warned you, a 1141 that's referenced in the - you know, the secondary I153 nontechnical person - [151 chemistry control, but, again, it's - so fill A: Okay. (153 essentially they're basically the same except you

[173 0: - I'm going to have to have a little [17l just made specific reference to the PWR plant Itii bit of specifics on what you just told me so that I 1133versus the BWR plant because the chemistry program pwj can better understand what you mean by both of them [153 is a little bit different.

poj as they're applied in this position description. q Q: Okay. So then wouidIt be ftirto say

[213 For instance, can you tell me by pointing out on (2i that all of the chemistry responsibilities that are pm Plaintiff's Exhibit 2 which duties here are unique pq included in the job description on Plaintiff's A~ito a PWR position. r'3q Exhibit I included both the PWR and BWR r2,91 A: okay.Well, statement number or line lr2'1 responsibilities that were later divided - CD 000768

,43 item number two here on page two, function as the

~Iz A: correct.

I (cflav 2~4 PPave 21 HTal & Associates (423)267-4328 Min-U-Scrip" MnUSrp

in theinatter of Gary L- Fiser v. Ronald 0. Grover Tennesseec Valley Authority January 29, 1998 I

Page 28 Page 30 rII) a: - into two job descriptions? [1] correlation.

Z A: That's correct. rz4 0:!I didn't mean by my question to imply m3 0: So the only thing that was excluded pR that the words were the same.

l~from the two new job descriptions, and by new ones 141 A: Yeah. But fun ctionallyyes.

islImean PWR and BWR job descriptions,vwas the gj 0: Let me ask a follow-up question and M6exclusion of those cnvironrihental responsibilities iel make sure that -we have that clear. So functionally rv that were included in Plaintiffs Exhibit 1; is rn if you took - let me ask it this way: If you-took (I] that correct?

(8 all the responsibilities, chemistry gaj MR. MARDUAND: I'm going to object.! p*responsibilities, in the PWR, added it to all the lioj think that rnischaracterizes thectestimony.!also [10] chemistry responsibilities in the BWR job pilj think the documents speak for themselves. (an descriptions, Would that cover all the chemistry uial Q: You may answer. li2aresponsibilities that are included in Plaintiff's

~Inj MR. MAROVAND: You can answe-r. (13] Exhibit 1, which was the old job description?

114] A: I don't know how this is - (14] A: Yes.

gis] 0: This is a lawyer thing here. lis] 0: Thank you. Go off the record for a lis A: I don't know whether I'm supposed to, (16] minute.

p~you know - 117 (Thereupn, a brief recess was taken.)

l18] MR. MAROUAND: I'm making these [18] BY MS. JONES:

'19 objections for the record. [1o) 0: Mr. Grover, I'd lRe to turn our 120 THE WITNESS: Oh, okay.!didn't know r20] attention to the reorganization that occurred in pil~whether I'm supposed to stop or what. 1211 1996. How did you first learn about TVA's plans to pm MR. MAROUAND: You do stop when I start rm do a reorganization in '96 that would affect your pal to make an objection. Let me state it and then - n department t24] THE WITNESS: Okay.!didn't know 1241 A: Well, we had astaff meeting, an Iwhether!I had to - okay. Could you repeat the 12sl initial staff meeting. It was the March time I.

Page 29 Page 31 (1] question. I mean,!I forgot what - (13 frame.!I don't recall the exact date, but we rM MS. JONES: Can you read it back. M had -Tom Magrath called a staff meeting and he (8 (T'hereupon, the requested portion of (3] had discussed what the - that we were going to be 1'] the record was read back by the reporter.) 14doing a reorganization and It basically entails a M THE WITNESS: That's correct. In R5staff reduction, budget reduction basically, you pn addition to we tried to delineate more when we 16 know, and laid out some objectives that we'd have M split the two out in that We may have had a general m to look to accomplishing this reorganization.

ca)statement in the old one and we tried to delineate pq Q: And did he tell you what the -did he M more like you have to be a part of this working m give you some firm objectives that you were going lio group or this, that and the other. (10] to haVe to meetl

[113 So it's not a direct word for word (113 A: As I recall, we had to reduce our lqz parallel.You know, you can't take this one and, pial current budget/head count level by 40percent by l13] say, okay, I'm going to lay it beside this one and (13] the year 2000. Okay.And -

(14] it should be word for word except for (14] 0: So that was about a five year time (15] environmental.Therc was some rewriting or (IS] spin?

l15] rcengineering to be more specific on, well,!I have (16] A: Well, let's see, '96 to 2000.

(17] to participate in this user's group or!I have to (17] 0: Four yea~rs.

lit] do, you know, this. [is] MR. MAROUAND: This was for fiscal year tio] 0: Right. [19] '97. though.

. A: But it was all embedded in this one, A: Yeah. It was starting for '97, fiscal but yet it -was more general and it wasn't broken 1211year '97, through the year 2000.What, three -

ou401t. w three years? '97, '98, '99,2000. So four years.

(23] 0: Okay. = 0: Okay.Did you say-what was the p~ A: So I just wanted you to understand it's 124]percentage? I CDO00769 Msinot going to beCadirect word for word, you know, [25 A: Roughly 40 percent.

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• i Q: Okay. Did you have a short-term goal you know, a certain percent reduction.You know, I

• that you had to meet initially that was identified in my recollection, we may have been given a

• in this March staff meeting? certain percentage that we had to reduce by fiscal t~ A: Well, I'm not sure what you mean by year 1997. It may have been like 17 percent or

• 5 short terrm. I mean, I didn't have an immediate something like that.

• s goal like, for example, by the end of 1996 1 had to In fact, now that I remember it, it was

• 7 have reduced it down by - you know, achieve this some number, some intermediate number, like we want

• a budget level. to see a 17 percent for the first year, something Mu 'We - we were directed to come - to like that.

po develop a plan to - a proposed plan to get to that 'Well, the plan included - it met that liII end. Okay.That was the initial direction was to criteria because one thing we had - we had - we

[t~ develop a plan to get to that end. had one position that -wehadn't filled yet, so we 1123 0: At that time period. had one vacancy. So from a budgetary standpoint we p4 A: At that time period. were able to achieve that.

lisi Q: Okay. And then we looked at it and, you know, lie] A: And he would look at that and then, -you I had the team look at it and we - the team, my 117l know, we would try to work - you know, work it out group, we all kind of looked at it and we - we put CIII from there. together a plan to achieve that end of 40 percent pu Q: Okay.Was your understanding initially with intermediate reductions. Okay. So rz that you didn't have to make the entire 40 percent intermediate reductions were in that plan.We 1211cut in the next fiscal year? didn't just say) well, we'll stay like we are and pM A: That was the initial information that then at the year 2000, boom, we'll just reduce by jM Was put out and then we had a subsequent meeting 40 percent.

p4 and it was - it was discussed that your proposal 0: In that initial plan that you said that 1251would be reviewed and if it was saw fit that we can you discussed with your group members, did you -

I Page 33 Page 35 lil do it all now, you know - you knowTorn Magrath (1] Was Part at that changing the job descriptic mn that rAiwas the general manager of the department.Tom *2we've discussed at length already in creatin, g new MI said that's what I'll - you know, I'll make the 12 positions?

1'i decision and we'll do it. 1M1 A: No, not the initial one because Ms You know, so it was, well, if we can - *s initially Organizationally I looked at the M I'll look at the plan and we'll make a decision as *s chemistry and environmental piece and we tried to M to - based on how you've got it laid out.We may M look at it in a horizontal fashion.And then t]

rm get it.We may wait. It may go to 2000 or we may r'i other groups did the same thing, L~dChem and M do it soon'er. We mnay - you know, so it was - you lM training and, you know, the other organizati know, it was a management decision to change it or cta reporting under operations support at the idLme. So IqI move it up or that sort Of thing. pill I was just looking at between environmenta I-

~21 0: Did you submit an initial plan to 1121withini the environmental chemistry organi2tation how 231Mr. Magrath for his consideration that was less 113l are we going to achieve that.

than the 40 percent reduction in the next year for (14) 0: Okay. So in your initial plan, renin 51him to look at' ls3 this interim about 17 percent I believe you: said -

A: Yes.The original submittal was - was 1161 A: Right.

73 structured such that We would achieve the 40 117 0: - reduction, your ch emistry and percent in the year 2000. 1 believe it was 1999 - lita environmental managers would have stayed Iin the 93between 1999 -and 2000 we would - 1193position that they were in; is that right.'

0: Under that first initial scenario how rA A: Well, for the first-for the -

23did you envision

'3 staff cuts or meeting those goals 121] 0: For that time period. CDO 00770 in your department? A: For the flrst year.

A: Well, as I recall, the first submittal 121 0: That's right.

'I for 19 -1 know 19 - you know, if we're looking 1241 A: For th e first year. Obviously you through the year 1997*1998, we were able to meet, 122 couldn't - we couldn't maintain the same -

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In the matter of Gary L- Fiser v. Ronald 0. Grove Tennessee Valley Authority January 29. 2991

-I Page 36 Page 38 (1] because the problem is we didn't have a significant I1I particularly if it looks like there's going to be a amount of additional expenses over the overhead.

ri staf reduction, this, that and the other, my

-&The overhead meaning the individuals in the pl primary concern Was communicating to the people, 1j1 positions. Okay. Overhead was us. Okay.

14l letting them know as much as I knew that I could pi 0:Yes. I cs discuss with them, letting them know that here's pl A: So there w6asn't a lot df roorn above lsl what - here's the situation. Okay. Here's what

• overhead.You had some - some basic expenses that ri) we've been asked to do. Hecre's the objective of a*we had to, you know, carry, travel to the plant rsi this whole effort, okay, as far as I've been p*and some minimal things, office Support and that R5directed to carry out.

pol sort of thing, but there wasn't a lot of overhead.

C'oi Okay.And I always asked - I always fill So we - you know, and everybody III] advised or encouraged rather is a better word, I vsi realized that.You couldn't sit here until 2000

[15] always encouraged all the people in our u1s1 and think you got this - you know, you got a big In] organization, okay, look at - first of all, we ii~j chunk of variable costs that you can reduce down EU]1support - our number one objective is supporting

[IS] and that's going to give you 40 perccnt.We didn't tisi the sitcs.We basically work for the sites.

lisi have that luxury. So it involved - it was going peisOkay.

(17] to involve people.

u171 So the number one objective is - the

[is 0: Right. liel first thing I encourage all of them to do is go to pqg A: So Ithink the plan, if Irecall lie] your respective Sites and your counterparts and let pqj correctly, included maintaining the head Count at poq them know here's the situation because what - as 12il least through 1997, okay, before we hit our first 12i3 it boils down or when it boils down as this all rz4 reduction of the people that were already in these pZ shakes out, what's going to count is if the site rnl positions because WC - again, we had a position rn wants your particular position, your function,

'.41that we didn't have filled and we had some room to 1241they're going to stand - they have to want to reduce some of the other operating expenses. [25 stand up and say this is what we want.We don't

- - I.

Page 37 Page 39 til 0 : Okay. In this initial plan, was moving Ill want this.We want to maintain this particular p) Mr. Harvey to the - I believe it was to an on-site *2function. So that affects all of our organization pi1 location part of your initial plan? p* on an individual basis or a collective basis or j4) A: No. M41 however you want to look at ii.

RS 0: Okay. Was he transferred to - I PIj So the first thing I encourage them is 16 wanted to say Sequoyah, but I'm not sure if that's IUl to go talk to your counterparts and the RadChem (7 accurate. m chemistry managers and let them know what's going M6 A: 'Was he transferred? r* on.And if they sense a need that they need to M9 0: Yes. - p*keep your particular functions okay, now, We're tic] A: No, he wasn't transferred.At the time licq talking functions now, they need to feed that back p1] he wams working on a project in support of Sequoyah piij to organization.

p'l which we - which required that he work a 1121 Okay.And that's generally bow It pul considerable amount of time there, but, no. he 'was (151 goes, okay, when you go through reorganization.

141 never transferred to Sequoyah. 114] Okay.We need to look at everything. Look at 115] 0: Okay.Was there any action regarding (isj everybiody's function.What's everybody doing?

pol] Mrt. Harvey that you were going to take that would (16] What kind of support are we getting from (173 have taken him out of your budget and helped you (17 corporate? Let's feed that back. If we need this, pi meet your goals? (is] what can we do without? We still need this.You 1191 A: Well, th ere wats - there was something ltgl know, that's what - that's our goal. So I said w that came up.You know, let me preface this with p20you need to let them know that so if they want your

'his:You know, at the time when we've gone (213function, they need to feed that back. CD007

_.,-Y through this -and the peoplchere atTVA have im Okay.The seco nd thing I always m~ been through this before. (23] encourage them to do is look around, look for 'other' 1241 Okay. And I always took the position (24] options.Thcrc may be other positions that you asq that whenever we go through reorganization and (25] could - you could apply for because I don't know Mm-U-S cripti2 (12) Page 36- Page 3 Hall &

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III LUC matter or Ciary L- k1iSer V. Ronald 0. Grove Tennessee Valley Authorlty Janulary 29, 199.

I Page 40 Page A1 pI) how this is going to all shake out. Okay. I don't [11me how would I feel? Would I be opposed, this, m~ know how it's going to go, this, that and the M2that and the other.

(3J other. - pi And I expressed to him, I said, I'm not 14j I'm in the same situation, okay, [4i opposed to anyone, you know, looking at another msbecause my position is being phased out and merged *s opportunity or - you know, because you know what ceqinto one. So I told them I gou~ld be straight up *s we 're going through.And they were aware of it. I ri with them straight forward with them. *~mean, it was common knowledge what we were going p] And I encourage that because if these *, through. It was no secret.

Mj positions get redefined and re - you know, *q SolIsaid -I told them, Isaid, piol combined and they get reposted, this, that and the ciol I'm not opposed to anything. If any of the ciii other,you're not just interviewing back in the job pisj individuals - it didn't have to be Sam's p~l you had.There's other people that's going to (tal position. It could have been Gary position or 1131 interview. So you're competing against other p] Chandra's position or one of the sites had come to 114) people that weren't in this organization before. puj me and said we would - we would like - we would ci sl Now, oh, this is a new job, so I can come in and Ii.j wonder what you would think about this and would jtig compete, as well. 116] you support it, I would be all for it, you know, if gt71 3o there is no guarantee even if 117] the individual is for it.

list theree were three Slots left and you got three (is] And when they approached me with that, j131 chemistry people and we have to repast it. It's lisq the first thing I did, I went and talked with Sam.

r201 the same thing we went through in '94.You know, I poj 0:Okay.

rail had to interview with other - there were four or ia21 A: And I had a direct conversation with pm rive other candidates I had to interview with, you rm Sam and I asked Sam. I said, Sam, this is what they pl kno., and it worked out okay for me. Same thing rni asked me and you're probably aware of it because p~j with the other individuals. t241 that was his primary plant that he supported. So PMs So you're not just - you know, well, pA obviously if they're your primary plant, they're I

Page 41 Page 43

'ilwe're just going to - it's not just a paperwork til going to want to ask for you, I mean, if you're r4j dril. Okay. It's posted. It's an open

• doing a good job for them.

pi opportunity for everybody to - that's interested ia Okay. It was like the other -the 14j in that position. SO you're competing against

• other individuals.You know, I would expect the msother people. So I always tell them to look g* same type of relationship and same type of support 1si around, explore your options, you know. 1'1from the others.

M 0: Did Mr. Harvey do that? m So I asked Sam pointedly, I said, Sam, A:I - Iwou~ld think thatall1of them

• is - Iwill support thisif this is what you want looked at that and I think he did that, as weIll z* to do. I said don't get me wrong.There's nothing t10] you know. 1101 going on that's trying to force you out into

[III And to answer your question as a cl another position or this would alleviate the 1121follow-up, shortly after we had that - I think our ctai problem, this, that and the other because It ti~second meeting in the March time frame, I was out cpsi doesn't. I mean, you're welcome to - you know, pJIAat Sequoyah and Charles Kent, which is RadCherm [141 whatever spots is left, you'd be interviewing for gisi chemistry manager at Sequoyah, and Gordon Rich, (is] that. If you want to go out and pursue 2 position liej which is chemnistry manager, we were - you know, 11i1 out at Sequoyah, that's your choice.

1172 they approached me.We were talking about some 1172 I said you let me know what you want to cia] other matters, but they approached me and asked pol~ do and that's what I'Ll support, okay, because it's j13) that - Howard felt if they would request his (131 no pressure. It's not a directive I've been given pq position be transferred out at Sequoyah because at rm or anything like that, you know. CDQOC 2ilithe timelIthink they had avacancy because they 121 And that's - that was with any of

=a had a person left a year ago and they had a rg the people in the group. I - you know, I tried r22] Vacancy. pqz to work as much as I could to try to help people P4 You know, I didn't get into the p'i get - you know, may main objective wvas. that pmsspecifics of what they had 2vaiiablc.Tbey asked pqs everybody would have a job after all this. Okay.

I

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Ronald 0. Grov, Tennessee Valley Authority, .January 29, 191c I

- - Page 44 Page 4 miAnd I workied with other people in the organization, [Ul created is you've got a function that supported the r4 Dedra Smith and we had an intcrn,Trish Landers. rz site and you wanted to transfer that function to p] You know, I worked. I tried to call other people P1 the site, you would have to transfer that head i~i and we tried to work effectively to see whether j'] count and that budgeted piece to the site for that t there was other options in other organizations. i5] year.And then in subsequent years the site would gjQ: Okay. IC]have to agree to - you know, we'd be happy to add pM A: So, you knowcldidn'ztmean to belabor M it to their head -count and they would have to

[ithat. [B budget it into their proposed budget for the gj : No. I appreciate that.That's very gM upcoming year.

1102 helpful informnation.Thank you. [10] 0: Okay. I'm trying just to -

Itil A: But I just wanted to give you a pli A: So my understanding is it could have p2) background on that particular situation. p~been, you know, looked at in two different ways.

113 0: Yes.And I appreciate that. Let me Ina Okay.

p~ ask a question, though, so that I understand how lid] 0: Okay.

jis) this works.You'rc very familiar with how internal [is] A: But -

pes things work atTVA and I am not. [l, Q: And either way, however, it would have 1171 This position that Charles Kent and the [¶2] reduced your head count.

jiC other man out at Sequoyah approached YOU about that gis] A: Oh, correca.Well, in the standpoint pq they said, you know, how about this, how about If giel of - well1, if he was Vying for a position out pq we transfer Sam Harvey into this, would - [20] there and they had a position,!I would stil - the 1211 MR. MARQUAND: I'll object.That's a rzil first way if they had a position, vacant position,,-

rm mischara cterization of his testimony. He said r4 there at Sequoyah, okay, and they wanted to try to pl transfer Sam Harvey's position. p22 see if they could move him into that position, p~ 0: Transfer Sam Harvey's position. 124] okay, whatever the procedure was laid out by HR. if

,q A: Right. [25] it could be done, then the position would still I I.

Page 45 Pago 47 III 0:!I didn't mean to mnischaracterize. I gufunctionally stay - the position he would - he r2] think this is because I don't undersrandTVA's [2 would just leave -,leave out -ofthat position that pi procedures. rpl was at corporate.

14] A: I understand. Right. g' The position would still be there.

pl 0: If his position were transferred to gs Okay. It would be vacant until it's eliminated.

161Sequoyah, would that position stil be in your msOkay.And it would be, you know, if the rcorg m budget?7 rm eliminated that position, then it would go away.

Ir~ A: Well, it would have - it would have

• 0: But your dollar spent would go down MU depended upon how it,%was done. Okay. Now, I g*bemause the dollars spent for his salary would no t10] wasn't aware -'when they approached-me, they could [10] longer be attributed dto you.

fill have had a slot available for hm uil A: Correct. If they had dollars for that gial 0: Okay. If a slot were -available,would ciai position or if - if -if -well, either way it jisl it be in your budget? [i3l would go down. I would spend it if the dollar 114] A: Well, no, it wouldn't be in my - see, 114] stayed in my budget or if they needed the dollars jisl it was twowv2ys.They could have had a vacant lus] out there and we transferred it over to their

[IC position. Okay.That'S one thing.Thcy could giq budget, it would stil go'down.

ji~ have - it could have been -1I know they did [12] 0: Okay.!I just wanted to make sure I p132have - they had a position at one time and the gui understood that. Did you ever have a conversation liB] person left and they didn't fWi t. jg]ewith Mr. Magrath about this potential transfer of p I didn't know - I don't know and you'd pq0 Sam Harvey to Scquoyah?

have to talk with their human resource people r21] A: Yes. C O 07 wh ethecr that position was stil being carried in [2]0: TellMCeabout that. C O O7 their budget or not. I don't know that. Okay. rn) A: Well, this is nor a normal routine type ga'j If they didn't and then if you were [24] evolution.!I know it's - you know, I was aware m2Swilling to - the otherlway aposition would be [2s] that it's been done before.We move people from MLu-TJ-Scriptu (14) Page 44- Page' AssocIates (423)267.4328 Hall & Associates HaU (423)267-4328 min-u-sclipto - (14) Page 44 - Pagel

'ii Le mnater ot Gary L-Fiser V. Ronald 0. Grove Tennessee Valley Authorlty January 29, 199:

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Page 48 Page SC r'l corporate into site positions and we've transfcrred gin said he preferred Sam - you know, his choice was

• people from site into corporate positions. So, you r4 to have Sam down here fulfilling one of those -

j* know, to my understanding this has bcen done pj whatever position would be left, one of the i'i before. 141 positions that would be left.

153 And so Iguess Iwas thinking at the n~ And so Ididn't pursue it anymore.

15) time he approached Me and said, yeah, you know, I is, There was no need to - you know, I mean, that's m was thinking that the site would have to initiate mi what he had stated. So I didn't - you know, we pl this and request it and so forth, but essentially jai didn't get into a long discussion or I didn't try gu it got back because Wilson had approached me and Mgto challenge it or anything. I said, well, if lial said, well, you know, they're waiting on you to pol that's what you want, that's - you know, I said pij initiate this transfer. jaii okay.

lt2 And r said, well, I'm not sure how it's (izi You know, I just went back and (133 supposed to be done. So I went and talked with the lqs informed Charles Kent and Gordon Rich that - and ruj HR representative at the time, which was Ben lu] also Sam.!I said, wdll, you know, it's - there lits Easley, and said, well, Ben, this is what the site pis, was a - you know, I said basically, you knowTom lis, is requesting. How does this - you know, how do 11s, Magrath doesn't support proceeding in that way with Ii~l you do this, you know? gIr Sam's - you know, transferring Sam out to the site till And at the time he had mentioned that, piqabecause I had to get back to them because they were ligi well, you have to start with a request.A request 1191 asking me, you know, let's get it going.

pcq memnozandurn or request letter has to come requesting rMo 0: Sure.

r~i that this, you know, action be taken, okay, be [2ij A: So that's how it ended, you know.

rM initiated and then we'd work with HR and follow rz 0: Okay. Let me make sure I understand p23what the proper procedures are and this sort of rm~the time line.At the time you had this P4j thing. r241 conversation with Mr. Magrath about Harvey's p25 So I went and talked with Tom Magrath [25] potential transfer, had you submitted another plan "~

I Page 49 Pago Si

[1) about it because, you know, I had told him, I said, lij for the reduction in your chemistry department by

• z well, you know, this is something that the site M then that would have required a reduction of three pj asked Me about and they were interested in bringing pR positions to two?

F4Sam to the site. 14 A: We probably had. I mean, we - you 15 Okay.And I told him I had talked with msknow, you understand this kind of went back and

• s HR about it to get whatever the procedure was and a 1s, forth. It waS a number of - number of iterations,

• letter of - initiating letter, but the site, you m okay, and, you know -

rq, know, they wanted me to check and me to probably jM 0: When you say go backand for:h,you m run this by YOU and see if YOU are comfortable M mean between you and Magrath?

1101with it, you know, supporting this, this attempt or 1103 A: Well, yeah. Itwas-really we -at li il just - just what your position is.There's no [1i the time, you knowToin had mentioned, well, you Iszi need in us going through all the groundwork and, jtzj know,!I want you to - at one of the subsequent 1'3l you know, he wasn't supportive of it. In meetings I want RadChem and chemistry to basically 11uj So he, you know, responded to me and (143 combine - you know, combine this plan and send in lisl said that he didn't - he didn't support moving Sam [15] one plan. So that's what we did. We worked ps, Harvey to the site. lis, together with RadChem and combined it with the ptl Q: Did he tell you why? 1171assumption that - with the understanding that one pal~ A: Well, he just mentioned that he - he liss manager would be left and the organization would be 1191preferred that he keep Sam down at corporate in the l19] combined into one group. CD 000774

[20 organization to fill - fill a corporate function. rmo So I worked in conjunction with Wilson (213 Okay. So he didn't want him, you know, being r213and his organization and we went through several '-

[22 transferred to the site. rgl itelations. So it2S - thiSwa;Sa2part of i I rM 0: Okay. Did he say anything more about pi~ just can't say, you know, which iteration it was.

PA]3 that. r24 We must have went through, you know, six pRs A: No. He just -he -he -he just [r25]iterations, three to six iterations at that time or I

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Ronald 0. Grove Tennessee Valley Authority January 29. 199:

I Page 52 zvjsomething Lke that, you know, trying to get to the Page 54 Icl wanted to -,he specifically said that he wanted

,I end point ot where - because, you'knb'w, I'm sure Mzone BWR -you know, one BWR specialist and one PWR Tom was looking at the other organizations and (3] specialist tar the two remaining positions.

'- 14 looking at the total dollars and saying, well, I'] 0: Okay.

n~you're not there yet. I wanted this or I'd like to is9 A: Now, I'm calling specialists m see it -you have this muci.So you had i lot of 16 chemistry.You know, in other words, you - your m that going on in the process.-

mn specialty area is BWR chemistry and your specialty Ms Q: Well, I take it from your answer, then, pi area is PWR chemistry respectively.

R that the initial plan that we had discussed prior, 0: Did Mr.Harvey have expertise in BWR lico prior in your testimony, where you were going to giol chemistry?

1iiqget about a 17 percent reduction in the next fiscal ill] A: Hedid alittle. Heworked alittle p'l year was rejeccted by Mr. Magrath.

jii~ bit in the BWR side, but his primary expertise is 1131 A: Correct.

(133 in PWR chcmistry.Very little - he'd done - he's 114] Q: And so you had to come up with another (14] done some work at Brown's Ferry, but'very little.

lisi plan; is that right?

tisl But as far as from an expertise standpoint, his (16] A: Yeah.Well, at the time then he - he l16] expertise lied in the -

ji7j looked at it and he made a decision, well, I want (17 0: Primarily PWR?-

113] the entire - you know, we can get it down to 40 (18] A: Primarily PWR chemnistry.

volj percent now. uig] 10: And Mr. Fiser's expertise, how would w 0] : Now meaning thei next fiscal year?

(20 you characterize It?

121] A: Fight. 1997. Let's do that.You (21] A: It was primarily PWR.

rm know, he - he made the decision to eliminate the pa 0: Okay.-

123] environmental function completely out 'ofthe rm3 A: Again, he did probably comparative -

im organization.Well, at the time - you know, at j:24from a comparative standpoint, he did more on the the time we were going through this he'd say I want 125] BWR side, but his primarily expertise was PWR.

I Page 53 Page SS Iil to move all environmental functions and budgets to (I] 0: And Mr. Chandra? -

rA the sites.And so we don't need a - we don't have Vj A: He -he -he was -well,if I pR a need for the environmental function. pi correctly categorize him, he was proficient in-

~14 Q:Okay. 14] both, okay, but he - because of his extensive pl A: So try to get it down, force it down as 1q experience in the BWR side, he was more toward (6] much as you can for fiscal year '97. gMthe BWR. In other words, a11 BWR issues went (7 Q: So basically what he wanted was the m through - was really addressed by, you know, m6entire several year 40 percent reduction done mi pii Mr. Chandra as opposed to the others.That was M the next fiscal year? m his - his primary assignment was Brown's Ferry, (10] A: Yeah. I mean, that's - that's 110 which was a BWR plant.

(il) his - that's his prerogative. So he chose to, you liq 0:Did Mr. Magrath give you any (12] know - [¶2] explanation or share with you his reasoning in (1n] 0: Were there any other groups undeCr (13] wanting to divide the chemistry specialists into puj Mr. Magrath that were required to meet the 40 [14] PWR and BWR.7 t15] percent reduction goal in the next fiscal year? [15] A: Well, he just mentioned - he just (161 A: Not that I'm aware of. jig stated that that's what he felt that it should 1171 0: Okay. In order to meet this 40 percent p) be structured, Imean, to have one - ifwe're (181 reduction mandate'by Mr. Magrath. did you' have to p¶3]going down to two people, have one in the BWR side (16] reduce the number of positions, the chemistry piei and one in the PWR side, you know, just as 120 positions, to two from three? p20specialists. I mean, that's what he stated to me, A: Ycs. pq1he shared with me.We didn't get into a long, 0: Was Mr. Magrath involved in how those pm drawn out discussion or in-depth discussion on his 123] positions - the decision about how those positions rm3reasoning. CD000775 (24] would be defined? 124] Now, suppont-wisc, you know, it's not Z5] A: Well, he gave direction. I mean, he [25 balanced because you've got one BWR site and you've n-U.S cript1 C16) Page 52-Page5 Rafl & MS-Hall'& 0-clat -es(423)267-4328 AssocIates (423)67-4328 -min-U-Sclipte (16) Page 52 - Page 5 I

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Page 56 pa~e SE i'i got two PWR sites. So it wasn't a direct, you redundant.

• know, balance in workload, per se, from a site So we'll take that input, those p* standpoint. Okay. comments back, but as far as the technical content paj 0: Okay.Was Mr. Magrath involved in of it, we have to do that.

mi drafting the new job descriptions?) Now, they'll help us put us in a sq A: He was involved witli the reviewWe..- right - package it right so it - you know, it m we - well, our organization, our group, our entire makes sense and all, you know, the positions and

• mgroup, had input on the new PDs.Wc initiated the all this stuff is filled out correctly

• mchemistry PD.And also, you know, the 0: Let's take a step backward in time

('01 environmental piece that went over to Rad Waste, an prior to the creation of the position description j'i environriental person was able to review that and whatever input that Mr. Easley may have had in 112 portion of it, you know, that position description, that.Was Mr. Easley consulted about the decision Ini but we put it together and essentially, you know, to create new positions and to post theml?

gu41 submitted it for his concurrence. A: Yes. I'm sure. He ;wa very involved (153 Q: Okay.And so whcnyou said your group with all this - the entire reorganization effort.

iisj had input in it, then Mr. Harvey and Mr. Chandra And he's had - he had several conversations with 117 and Mr. Fiser also had an oppor-tunity to review the Wilson McArthur and Tom Magrath, you know, because g181 position descriptions? they have to work closely with the - with the p'iq A: Correct. responsible manager in this whole evolution to make rq 0: Okay.And they each had an opportunity sure - you know, and that's my experience from piji to offer input? before.!I mean, they work with them closely to pq A: Correct.AII of them had comments and make sure it's being done the right way.

p22 everyone submitted their comments and they were all Q: In this instance are you aware of any r24] incorporated. And we had - we've had - we had objections that Mr. Easley may have had to the psj several meetings on it and, you know, got process of posting this position to begin with? -~1J

-j Pago 57 1 Page 59 (13 everyone's concurrence that - you know, that (lA. Well, there was discussions on how to rA wanted input, you know, that had input.And *2 go about - the right way in going about pq everybody had some - you know, had - had some p*transitioning from where you are now to where 1'] comments. 14you're reducing to. Okay.And that - this is my r* 0: Was Ben Easley involved in the creation (9 understanding and what I've been exposed to in my

• or draru-ig of that position description? *~ experience here up to this point on how the process p* A: He wasn't involved in the drafting. He m should work from aprocedural stadpoint based on

• u was involved from a human resources standpoint and *s what you're trying to do.

• ~ he had to - you know, we had to submit the PDs PI You know, there's a- th ere's a (101 through HR and they had to review them and make (10l certain percentage. If you're creating a new pill sure thecy were consistcnt.YOU know, whatever HR's p ii position, there's a - there's abasis for saying (122 function. 1i2 that, okay, we're going to reorganize and we're (is1 Now, I didn't mean that in a negative (13] going to change some functions around.rbere's a ps'l sense. I mean, but they look at it and make sume (14] basis for when you have to create a new position jist we got the - like the dimensions right and the lis1 description, when you don't have to create a new lii purpose right and, you know, it's consistent. It's pqsposition description, when you - and as I gi~l not too wordy and we're - you know, we meet the jsl understand it, and I'm saying this to lead up to (is] formnat from that standpoint. cin your question, that when -sayif you're goingwt tp] And if there's something there that ciP change organization and you got five people in your p20they don't understand, they ask for clarification pq organization and you're going to reduce it down to (211 and they give us - you know, they provide good (213three, but the functions stay the same. Okay.

r= feedback if we're too wordy or we got too many =j Functionally they've got certain position rA accountabilities, we'll combine some of that. SO, rgzdescriptions, but you've just got to reduce two (241 no, they provide us good feedback on, you know, (243 people, CD000776 (253 well, you're kind of off base on this or this seems Mas Well, as I understand it, the way it's Min-U.Script (17) Page 56.Page5 Hall &

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gII supposed to work is if you're not changing the cI) significantly, then you don't you basically gm position description, you don't go through a M~don't - aren't required to post it and you go on P1 reposting or this, that and the other.You go on pI seniority.

141 seniority. Okay. M4i If the functions change significantly 0s: Is that called rollover? msand you rewrote the job description, then you post sjA: I don't know what the term is. lni the job and - and competitive bid it and so 7]0: All right. Go ahead. M forth. 0kay.That'Swhat his position was.!I pI A: But it's based on seniority because you pqImean, he was following what the guidelines - what m didn't change the - you didn't change the job. tol the guidelines were at the time. Okay.

liq You didn't change the job function, this, that and cwia Q: Did Mr. Easley conclude that this was a psil the other. (II job that did not have to be posted based on those 112] Now, if you combine several functions gi~l criteria?

113] and you redid the job description and if it changed (13] A: 'Well, I can only say that he voiced "14 by,!I believe, 15 percent or so to - you know, p~l sentiment in that direction. Now, again,!I don't In]j which is considered a significant amount or ~Isl know what the final conclusion of it for HR. Maybe li6] whatever, then if it's changed by a significant 116] he got with Tom Magrath and just - you know, an d Ii71 amount, now, they may be able to correct me on the gti7whoevercwas working with Magrath at the time or uisi percentage,!I believe it 'was 15 percent of the lisi whatever and they made that decision to go ahead liol original position description, then you're required lipj and pursuecthis and post it. Okay.! can only poj to post the position and rehire - and rehire in, pq0 follow what was decided and - to proceed on.

r~ij you know, bid it and rehire in. (211 0: Well, weknow what thecultimate rM 0: Okay. pm decision was.

M A: Okay. So there was some discussion I n A: I know he expressed sentiments that r24] know back and forth as to which category this f24 this should be - it should meet one category or r25 the other. So if it didn't change by 15 percent.

I, Page 61 Page 63 (I] would that fit into, you know.And so I know Ben ~Ij it should go on seniority. Okay.

M Easley had some discussion back and forth with Tom- 12 (ThereUpon, an off-the-record pi and this, that and the other. So it was pi discussion was held.)

yj discussions and it wasn't totally clear, at least 14 A: Did I answer your question?

sjto me at the time,!I mean, which way was the best M 0: You did.

16]way to go, but the decision was ultimately made t~o

• A: Okay.

1m modify the job description this way and repost the

• 0: Ithink. Did youcever havea2 gsI positions.- ru conversation with Ben Easley about his sentiment as m 0: Okay. Do you know what Mr. Easley's 12]you described it 110] position was on that? pinj A: Wetalked.!Imean, we talked allthe jIIj A: Well, his positionvwas that - like!I (11 time during this - during this - you know, during (12I basically said, his position was if - and he was 112] this period about-(13] basically going on the ]HR policy at the time.!!f pisl 0: So it's in those conversations that he (14] the - 114] expressed his sentiment that this may not be a tIS] 0: Let me ask you a more specific l1s] position that needed to be posted.?

1161question. 1161 A: Yeah. Now, I'm calling it sentiment, Ii7I A: Okay. 117] but he was expressing a requirement to rne.And he fit] MR. MAROLJAND: Well, let him finish. l1t] said based on his assessment of it, you know, lip] A: Yeah. CanI- let me - (19] that's the way he felt about it. And, you know, he 1]0: Go ahead. (20 doesn't have the final decision, but,!I mean -

A: His position was this:!!f the position 1213 0: Sure.

description for the new positions didn't change pm A: - that's the way he felt about it. CD 000'777 rzisignificantly by that 15 -!' believe it's 15 - rA Q: Okay.

12'] let's use 15 percent for working purposes now.!I 124j A: And so it may have been Tom Magrath's ps may be off on that. But if it didn't change 125] ultimate decision to which way he wanted to go on Min.U-S cr1pt (18) Page 60 Page 6 HaU &

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-- -- -.. ~& %Y.ZL 7 A- r.. C- V. Ronald 0. Grover Tennessee Valley Authority January 29, 1993 Page 64 Page 66 vij it this, that and the other, you know. So we lil background, engineering?

12jUSt - whatever decision was made, that's what we gaj A: Primarily engineering.

13 had to follow. M Q: Why -

i~ 0: Let's move forward a little bit more in 1Ml A: Now, I don't know - you know, I don't msthe process, then. Once the position is posted, *5 know whether he's - he had 2 degree. I can't tell rs then people, as you descrilied before, can *s you from an educational standpoint. I can only m competitively bid for it, be interviewed for it; is

• tell you what capacity he was functioning in at the m that right? II] timc.

mq A: Yes. M Q: Sure..Who would havebeen thecWatts voi 0: And a selection board is formed to ciol Bar representative had there been one on this p q interview the candidates; is that correct? 1111selection board.?

1123 A: Correct. 1121 MR. MARQUAND: Objection. Calls for 113] 0: Okay. Did you have any input into who 1131 speculation.

1141 was on that selection board? ["1l Q: If you know.

[153 A: No. lis, A: Well, if you wanted to - if you're fie Q: Okay. By that time, by the time that 1151looking at it from equal representation, you p17l selection board, and I'm referring to the selection li7l would - you would want the RadChem manager at fit] board for - ZiSI Warts Bar.That way they're all - you know, you ipsl A: For the - 1liJ got peers.You got like peers there.

pa, 0: - the position Gary Fiser bid for, of Wa Q: Who would that be?

2il course, had your position been eliminated?7 pij1 A

It would have been Jack Cax, but, you

M A

Yes. rm know, sometimes you can't - for various reasons, rM 0: Okay. pam for whatever in selection processes, that may not p~j A: Uh-huh. p24 always work out because of scheduling or wharevez=

pqs 0: Are you awamre of who was on the 125 so - but that's what you would like even if - you I.

Page 65 F)age 67 pi~selection board for Mr. Fiser's - lil know, when I sat in on selection boards, you know, ga A: Yes. 12 Ilalways tried to get -would ask forlikc 13 0: ADl right.Who made the determination pRrepresentation at lMklevels so that, you know, 1'1 of who was going to be on that board? 14 you get the same perspective and the same Ms A: I think it was, you know, between 151viewpoints.You know, you're looking at it from iqj Wilson McArthur and Tom Magrath.They made the MSthe same level and that sort of thing.

M decision on who they invited for the board process. mQ0: Okay. Do you know whethcrJack Cox g10: Who was it initially? M3was - it was ever discussed with him about serving

-A: If I recall correctly, Charles Kent, Muon the selection boardl glajwhich is Rad chemistry manager at Sequoyah:John cia, A: Yes, it was.Yeah, it was discussed.

[11] Correy, which is Rad chemistry manager at Brown's [ilqWilson McArthur had informed me that It was gial Ferry-,and they did not have a Warts Bar plant 1121discussed with him.You know, they had asked him3, luisrepresentative to my understanding.They had Rick Iq3 you know, about It.

liil Rogers, which was the - he was in the technical 1141 0: Did he have aconflict?

lisq support group here at corporate. I think he stood l151 A: Heapproached meand asked me- huh?

jig] in as the third member representative from the 1161 0: Did he have a conflict that day?

p171plant - for the plant's standpoint. 117] A: Yeah. I don't know what the reason 1111 0: 'Who - 1161was, you know. And we - in fact, we were up - he 1ie1 A: I believe Wilson sat in on it and I c¶,ohad asked -Ben was -Easley was -Ben and -

pq1 think Ben was a part of it, as well, Ben Easley. pqoBen and I were talking about something and Wilson pq1 0: Mr. Rogers' background, is he in p21called us over and said well, here. Here's the pz chemistry? Maselection process or his board lineup and for some pq A: No. He was in the technical Support. rm reason he couldn't get Jack Cox.And, you know, he 1241 He was in the maintenance technical support. 124had mentioned that to us while we were there ra,M 0: What would that have made his rz,q talking. CD00077S Min-U-Scrpt% (19) page 64- Page 67 HaU Hall & (423)2674328 AssocIates (423)267-4328

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Page 68I Page 70 gji 0: Did they attempt to reschedule it to ilTVA, but not that I waS aware of. Not since I've i~ accommodate Mr. Cox's schedule?

K)j 4 A: Not that I'm aware of. I don't know mbeen at TVA, no, they didn't.

ji 0: All right. If you want to take a break m what the conflict was or what. I - you know, I (41 so you can answer your page.

pij wasn't privy to that.YOU know, not to - not that Rs A: Oh, okay.

[SI I'm aware of. I know they Bad it scheduled and (63 (Tereupon, 2 brief recess was taken.)

• then the conflict camne up.And I don't know BY MS. JONES:

• s whether the urgency to proceed on with the 0: Before we leave the selection process

• j selection process had to take place or what.

Mi topic, there are a few fol~low-up questions I needed

wiv 0: Okay.Are you aware of any lial to ask you about procedure because you have both iti participation by Mr. Magrath in the scheduling or [113 interviewed With a selection board and been on a 1121composition of that board?

1121selection board in your experience atTVA; is that 1131 A:Well,2again, hemay haVe.I don't,you JIS] right?)

ju) know - ju A: Yes.

tis Q: I'm asking for your knowledge. liq~ 0: Is it your understanding that the (163 A: Yeah.Yeah. It wasn't - he didn't Iisi selection board is supposed to review the 1173communicate to ine dire ctly. He may have been rrnj candidate's most recent p erformance appraisals ais

's9 involved with it with Wilsoni.I don't know. l18] part of its determination7 l1p3 Q: Okay. Did YOU get any knowledge (193 A: The application for a position require's pqeindirectly about his participation in this rWcthat YOU attch the most recent service review to r2il selection or the scheduling of that selection (211 it. Okay.That's pan of the application riz board? rm process.And that package goes with the booklets p~l A: No. Other than he -you know, he cni made up for the selection process.

(243 wanted it to happen. He wanted it to move forward r24 0: Okay. So it's available to the board and happen as soon as possiblc.That's - you =25members.

I > I Page 69 Page 71

~iiknow, that's the only thing I heard through Wilson, m* A: Yeah.You have the application.You m you know, that he wanted to pursue it and move (2 have this - the person's most recent performance pi ahead with it, but other than that, no. pj review. So you have that basic information to

'~j Q: Now:,Mr. Charles Kentwe've tlked 14]review and, you know, you've got information on (SI about him before. He's the person who had Msthe - his educational background, what he's been 161approached YOU about getting Sam Harvey transferred (6l doing, his current position,-that sort of thing.

p3 to 2 position at Sequoyah; is that c orrectP p* So that's part of the basic information.

pj3 A: Yes. *a 0: And when you were on the selection R 0: Okay.And Mr. Correy, is that right:' g*board, did you review that most recent performance l103 A: Uh-huh. 11D]appraisal?

1111 0: Correy worked at Brown's Ferry.Was 1113 A:Ontheboardsthatl-(121 Mr. Chandr;, the principal person, chemistry 1123 0: On which you served.

j131 SpeCiiaSt 1131 A: Yes. tUh-huh.

(143 A: Yes. 1143 0: When the process is ended and all the lisl 0: - who helped him out - (15 numbers are tabulated and totaled, in the (tel A: Yes. 116] particular selecction that we'rectalking aboutbhere-,-

(il 0: -atBrown's Ferry? (173 Mr. Chandra came out the winner for both positions, (163 So there was fio'6he on the selection (Iti is that right, BWR and PWR?

liel board who had worked for any significant length of l193 MR. MARDUAND: I'm going to objectto (20 time with Mr. Fiser, was there? ro lack of foundation. Mr. Grover- and also- I MR. MARDUAND: Objection. lack of (21] mean~be's already said by the time the board met, oundation.You can answer, if you know. [M he wasn't in his job neither was he on the board.

MA

Not directlyno, unless they hadsome A23 0: Are you aware of what the end result of (243 prior work relationship that I wasn't aware of (243 the selection process was?CD0 77 (25 with, you know, Mr. Fiser prior to me comning to [23A: Yes. -D O-7 Min.U-Scriptm (20) Page 68- Page 72

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--  %.D".47 A-. A L-VCA V. R~onald 0. Grove Tennessee Valley Authority january 219, 199 Page 72 P8a00 7, VIj 0: Arc you aware that Mr. Chandra came out (¶3specific here.

R the high scorer for both the FWR and BWR positions? M A: Yeah.

pi A: Yes. pi 0: Are there still two chemistr 14 0: When that happens in a selection (43specialist positions in the combined departments?

• s process, is it your understanding that the *S A: Ycs.As far as I know, yes.

• candidate who is the winrfer may choose which of s 0: A-re they still denominated PWR and BWR?1

• those two positions he wants? mA: Yes.

pq A: Well, I don't know if there's a human ni0: Okay. And are there still only two?

pMresource direction on that. A: Yes.

wJIDQ: I'M asking for your understanding. (10l 0: Okay.

(1s3I A: As far aslI'M aware.

VI]j A: 'Well, I would think it would work ju Q: Right.That's aUl you can answer to.

II~l out - it would be based on the interaction between c13 And you were Mr. Fiser's supervisor zIni the hiring manager and the candidate.You know, (143 when his latest performance appraisal was done; is (U]q the hiring manager has a right if - the board may list that right? That would be '95.

'st select a certain individual and, now, if the hiring 1163 A: The last annual one Idid for him list manager doesn't want to hire that individual, then pci~ was - was, yes, 1995, fiscal year 1995.And we gioj the hiring manager says, well, I want to look at (182did quarterly reviews, as well. So the Last actual lpaj some more candidates or whatever. I think - you [193 assessment probably was the - what, the first -

ligi know, it's my understanding they have got that (20 probably the first quarter of 1996.1 think it was p20 option. (213 somewhere in that time frame.

921 So it's up to the hiring - you know, cm CThereupon, the gai the hiring manager's discretion whether they wanted Performance Review and rzi Development Plan for Gary pm to ask the hiring manager which position you wanted L. Fiser was marked 124 or I'm looking to get you to fill this - you know, (243 Exhibit No.5 to the pqs this particular position. deposition of Mr. Grover

[253 and filed herein.)

Paeg 73 VIj So I don't know what transpired between Page 75 M the hiring manager, which is Mr.Wilson McArthur, [13 BY MS. JONES:

rj and Chandra. I don't know, you know, whether, you [2 0: You've been handed a document that's know, he - I wasn't there when the discussion took P1 been labeled as Plaintiffs Exhibit 3 which is the 53place. (43 annual performance appraisal for Gary Fiser for the pi Okay.Again, Ionly was - Iguess i ni time period 10-1.94 to 9.30.95.Tumn to the last p* was - I had gotten feedback that, you know, he had

• page of that document where it asks for the 3] an option. Hie was given a choice. Okay.Again. I mn supervisor's signature. Is that your signature?

• wasn't there when it took place, so I can't say, m A: Yes.

M 0: Okay. Obviously this is a multi-page tic; you know,factualy that this, that and the other.

lia document with many entries, but overall would you piij That's the feedback I got.You'll. have to talk lit) rate Mr. Fiser as someone who was weak in

[¶23 with those individuals, but I would have had the 1123management or leadership skills?

1132understanding that he was given a choice between 1153 A:- No.

r14l the two positions. (i43 0: Would you characterize this perform~ance gi4 0: Okay. And obviously you've been away (153 appraisal as a good one?

liel for 2 while at INPO, but I'm sure have kept up with liel A: Yes. It was a good performance re-view p'l folks back here 2tTVA because you remained aTVA pil when you look at, you know, the overall rating.

lio employee that entire time; right? cari The way this is structurd on a point basis and

[191 discussion, it was a good review.

1192 A: Right. Right.

12 03 : Are you aware of changes in the p(20] : Okay.And, in fact~when you were out (213 on leave or had to be absent, you frequently pil chemistry department or however it's now called, appointed Gary aS acting manager in .=rmr

m chemistry RadChemn combined department, after this (221 isn't that right)'DJU 70 pm selection process was completed?

1243 A: Yes. Along with - you know, he wasn't t241 A: AM Iaware of any changes in the - (253 the only one that Was appointed. Chandra served in cj Q: Yes.Let mnebea2little bit more Min.U-Script (21) Page 72- Page 7 Associates (423)267.4328 Hall & AssocIates (423)267-4328 31in-U-Scripts (22) Page 72 - Page 7

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Page 76 Page7i jil that capacity and, I think, Sam served on one or p~MR. MARQUAND: I think the testimony

'21 two maybe occasions or - but he was - yeah. He was he had input.

m served frequently in that capacity. ~iA: Yeah. I had input. I don't - and I 14 0: And by he then you're referring to 43don't -

• s Gary.

c~0: Do you remember specifically what you

• c A: Gary Fiser, yes. 1c, suggested to be asked?

• 0: Did you help put the questions together mA: No.

tai that would be asked of all the candidates in the m9selection process? 06: All right.

1101 A: I'mntrying to think whether I was- c~A: No.

111 I didn't physically put the questions together. If 1103 0: All right.

1121 I -you know. I'm going on recollection here. I 1113 A: But I can look at here and tell you (13] think I was asked to review or Wilson had asked me p2] what - you know, there's obviously others on here 1141 for some questions that would be good questions to 1i31 that I didn't specifically, you know, request to be lisi ask, if I recall correctly. Okay. But I never did (141 asked.

jlis review the entire list or give a sign Of 2pprovl. [IS] 0: Sure.Thc position that's being

[17l that sort of thing. If I recall correctlyWilson cici interviewed for requires a fair amount of iIII did ask for my input on what would be some jul7 expertise, would youagree, in radloanalyticaI jiv] questions to ask.

cisl chemistry?

120 Crhcreupon, the Que stions 1161 A: Say that again. -

for Program Manager p20 0: Certainly.

r21] Chernistr~y was marked 1211 A: Can you repeat that question.

Exhibit No. 4 to the raaM deposition of Mr. Grover 0: The position that is being interviewed and filed herein.) 12]for and these questions are being asked of the r24] candidates, that that position requires expertise 1253in radioanalytical chemistry;, is that correct?

BY MS. JONES:

jai 0: You have been handed a two-page Page 79)

Peigo 77 ', A: Correct.

1i] document which are the questions that have been 0: What questions listed here on r4 produced to us by Mr. Marquand as those being asked p, Plaintiff's Exhibit 4 pertain to radioanalytical (31in this selection proccss.There are a lot of j41 chemistry of the, let's see, 16 typewritten 141handwritten notes here by whoever took these notes, cMquestions and then there's one identified as 17 Msbut I'm most interested in focusing in on the cci that's handwritten? -

Mcquestions that were asked. So I'll give you an

• A: There aren't any questions here that m opportunity to review those right now.

1' specifically that - that is specifically M A: Okay.

pM 0: Do you see any of your questions there?

• directed at a radio chemistry subject arca.You (103 know, there's no question that's pointed l101 A: Well, 2again, I - you know, I don't (112lspecifically recall putting together, you know, 1112l specifically toward a radio chemistry subject area.

(121 these and, you know, say, okay, I submit these four 1121 or interest or, you know, isse.

1131questions here, this, that and the other. 1131 Okay.They're more global in natur.

1142 Onecthing I- I -there would be - p"I And, you know, you could get into that based on the lisj there are questions - I would say that there ame list discussion. How the discussion went on the list questions on here that I would - you know, that I (is] selection process, I don't know. I vwan't aware of p~would see - could see asking of the candidates. 1172that. But there's not one specifically as I read gim1 0: Okay.That wasn't my question. [18] this - CDO00781 11g] A: Would you -do Isee - 1191 0: Okay.

poj Q:My question isdo you -you had 1203 A: - specifically targeted toward that.

indicated before that you made a few-suggestions of 1213 Ql: Are there any questions here that would K p23 questions -

A: Eight.

rvM elicit a candidate's experience in that kind of rzij radiological data interpretation?7 rpci 0: - to Wilson McArthur, is that right?

124 A:Well, Icould seecsix ifyou know -

psq A: Right.- (2s1 or 16, discuss your specific management experience Min-U-Scripte MnUSrpi - (22) Pa2e 76 - Paee'7 Hall & Associates (423)267-4328 -

in me matter or Gary L- Fiser v.

Ronald 0. Grovw Tennessee Valley Authority January 29. 199 I

Page So 11I and training, if it would come out in that Pago R'.

it) Okay. And others talk. I mean, the pi particular - under that particular question, but.

rci other - well, they say, you know, well, here's P] again, it more management oriented.

pi what he went through, this, that and the other. So lHI Q: Bu, the question isn't directed toward 141it was mostly input from the work force and, you msthat subject area.

A: No.You would have to - like I said, smknow, what had transpired, this, that and the msother.

• you would - it would have to come out, you know, rfl Again. I have no file case or written,

• s as one of these -as part of one ofthese

• you know, deposition or something. I didn't read

• questions here.

• up on it. Ididn't -it wasn't a case file or a lial 0: Okay. And, similarly, that's hard to pqa case history that I pulled off the shelf and read piij say that word, are there any questions here that Iiij up on it.

(12l would specifically elicit experience or expertise 1¶23 Q: Yes.just general talk?

(133 in radioactive effluencc or failed fuel analysis?

~In] A: Yeah.And I didn't - I didn't discuss juq A: Indirectly. I mean, say, number three (u] it with Gary. Imean, we -xIknew it was a.-.you (1s3there, it would have to come out - you know, it lisl know, he had went through this, that and the other, jg)swould have to come out as part of one of these jig) but I just felt it wasn't my place. I mean, that ji~ questions here. I mean -

[i~l happened before I come here and it's really - you lial know, it's irrelevant to what - what goeCS on now, uto] A: - you know. number three says part of liv] I mean, you know, from that point on.

pq the accountabilities for this position is that of r~q 0: From your point of view in managing i21] assessments. How do YOU go about assessing the 121]hint.

22meffectiveness of the program and then to develop ir, A: Yeah. Ihad no -yeah. Itwas not..-

ral corrective actions for weaknesses? So if you used 1233I felt it was not my place to get into that, what

m'] that as an example, you know -

12'] happened in the past, I mean, you know.

MS 0

So the candidate would have to (aSI 0: But the person who informed you of this II Page el

¶ilvolunteer that. Page 83

~ijwas Wilson McAxthur; is that right?

M2 A: The candidate - the candidate would m A: Well,Wilson and othcrs.Wilson had pj have to, like I said, bring that up or it would m1mentioned it to me because I worked for him and 14 have to be a fol~low-up question from one of the 1H1 he gave me some background on what - you know, sj board members to say, okay, here's an examrplc.You M what - you know, because I didn't know what was r* had indications of -what would be your (63 going on and, you know, why the position - because m indications Of afailed fuel condition from a m I thought we were going to post the position and r chemidstry standpoint? So it's not a- you know, p* move forward or go look outside and that sort of g~it's nor a direct question in that area.

• ' thing.And he mentioned to me what was - you fbit 0: Okay.Were YOU aware that Mr. Fiser itciknow, what was in process and what was being worked pili had filed a complaint in 1993 with the DOT, which Itiil out, that sort of thing.

r'al is,of course, prior to your employment with TVA, 1123 Q: How about Mr. Magrath, did you and he (133but I'm asking were you aware that he had this (13] ever have a discussion about Mr. Fiser's prior (U]j prior complaint?

(14] whistle blower complaint?

Iiaq A: Yes. (153 A: No.

lisj 0: Did you and he ever discuss that? us]3 0: Did he ever indicate to you that he was (17] A: No. 117]aware of that?

[,e 0: How did you become aware of it? (1s] A: No.

ZiUI A: Well, it's just discussions.Wben I jig, 0: Let's look at the knowledge of the r20 hired in, you know, I was told, you knowWilson rMoselection board folks. Did you ever have a 1211and several others, that, you know, this individual [2ij conversation with Charles Kent or otherwise aware.

is coming back. He went through this ordeal, this rz of any knowledge he may have had of Gary prior (2]complaint and so forth, and it's been - you know, rqcomplaint? CDO00"78 2 (241 it's been settled and the individual is coming back (24] A: No.

(25 to this particular position. (253  : How about john Correy?

ir.,ll #. Ac,.~o.I.,$jmc f(L121)4t7A2,'1 %X:_ V'r V%--- On n--- C

I

- -A..1.ILA- VJL '..rAry J. riser V. Ronald 0. Grov Tennessee Valley Authority January 29, 19:

'ijA:No. ~ij A: That he had filed a complaint?

R Q: Rick Rogers? rA 0: Yes.

p] A: No. p] A: No.

• 0: At the time the selection board met - (4] MR. MARQUAND: Other tha counsel and

• let me back up a momnent.When did you become aware is]the people you've -

• 6 that Gary Fiser had filed a second complaint? ~j A: And, again, counsel and HR they talked pj A: Itwas -ifIrecll correctly, itwas rpl to me, but I don't know -

• like right around that time frame or right after [i0: Oh, I know there's an investigation

• the board met. I can't recall the exact, you know, later,but -

(to] date when - you know, when I became aware that he l101 A: But, see,!I don't know whether - see,

(¶1]ldid file, you know, a complaint on it. [11) I don't know the time. I don't know whether- you pij Q: Do you remember how you became aware of (12] know, he didn't give me the paperwork he sent in to 113]it? 113] file the complaint. So I don't know whether he had 1141 A:Well, we -itrmust havebeen in one of` [ia] discussed it with personnel and personnel came and list our discussions. I mean, we discussed it. l15] discussed it with me and the complaint was jig) 0: From Gary himself.? liel offlcially filed.!I don't know.

ui'l A: Yeah, from Gary hisself.You know, he 1171 I'm just - it may have been - they

[ial had voiced a lot of concerns and, you know, he had lial may can tell you exactly when and the sequence of r'9] stated that he's proceeding on with filing a l19] events, but, you know,!I just didn't want to

[20 complaint, you know-And so that's each pqj mislead or give you the wrong information that I l~ij individual's right and prerogative. r~il knew the exact time and date that he did that.?

tr4 0: Sure. So this was when you were still pj 0: Oh, no.No.I didn't mean to imply pl there in a managerial position with him, is that r23]that.

1241 right- 124] A: All right.

-sjA: Well - pms 0: About when did you leave TVA to go to I.

Page 55 Page a'

[1) 0: - that he let you know that he was [1l work for INO?

pi Upset and he was going to file a complaint? pM A: September 30th, 1996. I reported to R A: Yeah. But,!rmean,2agin, itwas - p] INPO on - yeah.!I reported to INIPO on the 30th of p]j and I can't with all this - you know,!I can't 14]September.

~j remember the time - the exact time frame, you *5 Q: And Ithink you said at the very jg] know.!I probably wasn't in that capacity to be - j* beginning of this deposition that you were there rpl I wasn't his direct manager at the time, you know.

• for about 15 months; is that right?

isi I'm thinking it happened around that selection Ms A: Correct.

Rsprocess, that sort of thing, you know, right p] Q: During the time period that you were

[10] afterwards and, obviously.Wilson-was the manager (10] there, were you aware that Mr. Fiser had applied piil of the organization at the time. So I knew it was- Iril for employment with INPO?

uiz somewhere in that time frame, but,!I mean he - 112] A: Yes.

(¶3] expressed his concerns and sentiments,-you know. 113] 0: Okay. Did you talk to Mr. Fiscr about 1141 0: Did he make it generally known in the (14] that application for employment?

(IS] workplace that he had filed a complaint? l15] A: Yes.-

iisj A: Not that I'm aware of.!I mean, he (11] 0: Okay.Were there any statements made

[17] didn't go around broadcasting it.-You know, he [17] internally at MNO about his application?

1132didn't put it on the Internet, you know. So!I [16] A: Well, yourmean statements like -!

119] don't think he did, you know. j19] mean, we had talked and, you know, he had asked (20 me.And he's got other individuals at INPO that he r;q Q:Didyouever-

' A: AndlIdon't know who -who he (21) talked with.And, obviously, I was a loanee.!I 1 discussed it with.!I know he discussed itvwith me pq wasn't a permanent employee there. -CD000783 ra and I kept - you know,!I always kept those type of 123] And we just talked in general. He p'] things confidential. 1241thought what about - you know, what did he think r25] about - what I thought about INO b~ecause I was pqs 0: Did anyone else discuss it -with you?

Kin-U-S&ipta (24) page 84 - Page I Hall & Associates (423)267-4528 MnUSrpi

wLLuc matter of Gary L- Fiser v. Ronald 0. Grove Tennessee Valley Authority January 29, 199 Page 88 Pago of nji down there and my perspective on ita a5potential vij guess a comment was made that Gary was involved g*place to work.And he had talked to others there m with a - let me see if I can remember this pj that be know - you know, that he had long-term P1 correctly. Something wras made to the effect i4j relationships with. 14i that - something was made to the effect that Gary si And, you know, I told him, you know, if ms was having problems writh TVA and he had - he was

• the department manager from the chemistry isi in the middle of 2 case or something, some type of rq standpoint, if he talks to me, you know, if he m employee's - filing employee's concern, that sort pqjwants to talk to me about you, you know, I'll be jai of thing. Something to that effect, you know.

m' more than happy to tell him our relation - you M So maybe that - you know, that l10] know, discuss our relationship, working p10] feedback, you know, and it was to the point where I li1( relationship, we've ha d, that sort of thing pVil had heard - you know, one of the other, I guess, pil because, you know, that's what they do. p~l employees in the group had said I had heard that 1g31 They talk to - they try to get input [13] he's - you know, he's got some problems up there (143from other sources on the candidate that - such (14] and he's - you know, he's got an employee's 1isj that they can get some different perspectives, that ci si concern in process or something like that,.

lis, sort of thing, to make a determination of whether l16] employee's complaint.

c¶~] they want to call him in for an interview. 1171 And so I think, you know, decisions l183 Q: AUl right. Did you ever relate to (18] were made, well, let's - you know, we need to back gie] Mr. Fiser any statements that you had heard that [ipi off. Probably the decision. I'm not saying nobody pq0TVA had made about Mr. Fiser? pqocame to me and told me that, but I'm thinking a

[211 A: Well, the -he put in the p21 decision was made to back Off and not pursue him as

[22 application. It was looked at.Thcre were some - pm a potential candidatc.That's what I suspect.

Mzwhat I got - I got - iaitially got some feedback p231Okay.

ja~q that they were going to call him in for an (241 Q: He never got an interview, did he, at

[25 interview. [25] INPO?

I, Page 89 Page 91 (i And then I - then I received feedback [1I A: No.AgainI wasn't tying topush him later that he had tried to call and find out when rz in the intcrview.That was strictly the pj they was going to schedule it. I got feedback - [3] departmental mranager's - he called me and asked me

'41 the department director - the departmental manager 14what I thought about him and he talked to three or Mstold me they were going to call him in for an ES]four, five other people.

6]interview. M I gave my input and that was -you mYou know, I said, well, that's great, M know, I tried not to get involved. I told him -

82you know, fine. m8you know,!I told him specifically, you know, this pj He had asked me - you know, asked me m is - that's - that's your proccss.You know, I'm

[101 for some input for Gary. He was looking at some p10l independent of that.You make your own decisions.

(iq other candidates, as well. He told me that. He pitj You're looking at other candidates. So don't think (i~ said that - he had told me that he had performed t123 I'm h ere trying to influence you one way. I'll In sevemra- we're going to call him in for an 113] just give you what I know, you know, about the (141 interview. ri4] individual.

(115 I said, well, that's - that's great, (153 0: What was the name of the department V[16you know. (16] manager you're referring to here?

117j Then sometime later nothing Iq A: Chris Hobfoster.

[12 transpired. I guess Gary hadn't heard anything. [18 0: Chris?

li And then it didn't takeplaCC afld- andI ad -I (153 A: Hobfoster. CD000784 p20had asked one of the other permanent employees (20 0: Hobfoster.

p213 because I know they had worked together for a long [21] A: Hobfoster.Again, that feedback I got t23period Of time and that sort of thing that he had pm was - like I said, that was - you know, it wasn't heard anything or had something happened or this, rz~ directly from an individual or the source or it was p243that and the other. r24] just feedback I got from the other people that (25] worked there.

p25 And basically I heard that the - I

-I (94'1 1D.2,ve R -- pmenP.

Hall & Associates (423)267-4328 yKin-U-Scriota

__ _ _ - ... , %6 Y A- ribCr V. Ronald 0. Grovt Teninessee: Valley Authority January 29, 199 Page 92 Page9 gi :QI understand. III organization for a while.

Mi A: So I - you know, don't quote me is M I'm sure their process entails getting il saying, you know, the personnel manager told me p; the candidate to talk - you know, lining him up jqthat that's why they didn't do it.That didn't j4 to - setting him up to talk wi~th some of the mi happen. Okay. is) employees that -are long standing.

M 0: Sure.And this what ybu're calling the 0 : Sure.

M feedback, this information that Gary was involved rn A: You knowand the department head gets ci in some sort of an employee dispute, who told you ci; that feedback and be makes the decision based on pthat? Mgwhat he's talked - you know, what his impressions (iC] A: Aguy by the name ofJimnBates had licl are and also any other people that have talked with liiq mentioned that to me. cI'jI himn, he gets that input and he makes the decision.

1121 0: Is hie Still2 tINPO? [12 0: The position that Gary was applying cq A: Yes.' p¶3]for, would he have reported to Jim Corbit?

tidI 0: Is he one of those loaned employees? iii] A: No.

lisl A: No. He's a permanent cmployee.And, cis] Q: Okay.Who would he have reported to?

JIG] again, that's feedback he had gotten and so, you. [16] A: It would be Chris - the department iIm know, he just shared it with me that that's what he [171 Manager, Chris Hobfoster.

li't had heard. Okay. Now, he didn't say - C's; 0: Does Jim Corbit report to Chris

[lo 0: Did he share with you who he had heard lis Hobfoster?

pq it fromL M A: Oh, yes. Uh-huh.

pil A: Well1, he didn't say that b~CaCUSC Of (21] 0: Okay.

J:.M that information, they made a decision not to bring M A: Now, again, let me state that's only M him in. He said I had heard that that was some cp; input that I received. Now, it could have been J:24 negative - some negative information that - that 124] some other reason why. I don't - you know, I

,came out. rps don't want to say that L I don't want to be on I I Page 93

-11, 0: I understand. Did he say who he had ~Ij record as saying that because they got this M heard it from? information, they made that decision.They made pA: Yes. He said who he had heard it from. rp the de'cision.

1H1 0: And who was that? 14] It could have been some other reason.

• A: Jim Corbit. z* They looked at other candidates. I don't - you

• i Q: Who is Jim Corbit7

• know, I'm just giving you what -

• A: He's an employee there at the - he's

• 0: What you know.__-

• an evaluator there in'the chemistry departiment. a (3 A: -was given to me. So Idon't p; permanent employee. cu want you to - I don't want anyone _'to draw the ti 0I: You say evaluator. Is that a2 iol conclusion that because someone said this or pil A: That's the position titie.You're an I(1I that niegative input, that was the reason why. I li cv-aluator.That's what you - you know, that's rti can't -Icahn't attest to thatthat that was the p] what you prima~rily do.That's the position title, r~ case or not.

1141 evaluator. Jul 0: Well,when you asked or were talking to ViS] 0: Job description?, lis] Jim Bates about, you know, basically what's the pal A: Yeah.Yeah.That's what it's called.. Jul status with Gary, other than this information we've l171 You know, like you're a chemist or a chemical (17] already discussed, did he give you any other (Iis engincer.You're an evaluator. [18] information about Gary?

iw91 Q: Would Jim Corbit be ione of the people jigI A: No. He just said that was the only -

pq making an employment decision for the kind of gpo that was the negative thing he had gotten back tPosition GMr 'was applying for? r~ij about the whole thing.

~~A: Well,hewould -he may have been 0: Okay. He didn't give you any other pM asked to talk with the person, to talk with the pi negative things; did he? CDOOO~ ~855

[24] candidate, I'm sure. He's a senior level person. 1241 A: No. No. So Ijust -

ns He's the senior person there and been in the J:s 0: Did he give any other positive things?

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...- t.A kr.yd) J.. riLSer V. Ronald 0. Grovei Tennessee Valley Authority January 29, 1L99k Page 96 Pape 'Q jaj A: Well, you know, the context of t~he mi are?

gm conversation, I just asked him had he heard pM A: Yes.

M anything.You know, did something go on or did - ni 0: Okay. Let's move back in time.

14] you know, did he hear anything' Was there a l4j A: Okay.

m problem because Gary hadn't becn contacted.) ms 0: Back to the - prior to the creation of q 'Well, I take that back. Griry was rq the selection board for the position that Crary lost m contacted by the HR people and they went to - they M out on. Did you ever get any information that Sam pj were going to - see, that's what the question gpjHarvey was preselected for that position?

pj was.That's what was puzzling me because they did mu A: Wel, whenyou saydid Iget any lpoj go ahead and contact him and said we're going to jiol information he was pre - I didn't get anything in g'aj set you up for an interview, going to bring you in piii writing that said that he was - no one came to me c'2) for an interview. [123 directly and said that Sam is going into that aag 0: Okay. r'sz position, no. Not from that standpoint, no, I (14] A: And then like more than a week [1A3 didn't get any information.

zasi transpired and he hadn't heard anything. So he (isi 0: Nothing in writing, nothing directly last said, well, Ron, is there - what's going - you !lpo from any person.Anything indirectly that would

[173 know, is there something going on or this, that and gij indicate that Mr. Harvey had been selected or liii the other? liaj designated as the winner prior to the selection lip] I said I don't know. I just said I - jig] process even taking place?

zac you know, I can call up Jin and find out whether pq A: Well, itpwas something that was - it l213 he's heard anything, this, that and the other [213 was a conversation that I had with Dave Volar. I rm because they usually - you know, when they r4 think I mentioned this to you - I think 1 p22contacted him, they said we're going to bring you r23] mentioned it earlier in our discussion.

pil in, you know, here shortly. We'll be contracting Pq) And I don't - again, I don't know how Msyou. [2S this transpired, but what was told to me by Dave 4

Page 97 I Page 29 gaj But, as I said, they did make contact. [13 Volar was the fact that Sam had went up there at pmAs Gary explained to me, they did make contact with zasome point in time and said -

njlhim and said they were going to bring him in for an pi Q: Sam Harvey?

141intervieW. (41 A: SamnHarvey went upand had alittle M 0 : Okay. Rsmeeting session with Dave Volar and, I guess, in g A: And then the decision was made not to. the course of the conversation told Dave that he mSo 1-that's the reason why I just - he asked me mwas up here because he wanted to, you know, kind pq and I said, well, let me find out from Jim because Msof get reoriented with Dave because he's going to M Jim is alongtime employee. He knows how - I mjbe - you know, once this reorgnization Is jig don't know how the process works or whether it E~iq finished, he's going to be working directly for -

piij takes a month after they say they're going to bring [113 supporting Dave and words to that effect, that

[123 you in for an interview. [123 basically he'll be - you know, he's looking to be 1131 You know, so I just asked him what's [133 in that position and so forth.

ctil the status or have you heard anything or how long tI41 And, I gues, they had discussion back c'st does this take or was there a problem or a glitch? [IS) and forth and Dave didn't know, well - you know, tig You know, that's the reason why I - I just asked jig, you'll have to talk to Dave Volar to find out the j17l him because Gary asked me. I said, man. I thought 1173 aCtual words that was said, but to the effect -

(I11that they were going to contact you by now, you jgu 0: And I plan to, but what I'm asking for liol know. lie) right now is your memory of what Mr.Volar told pq 0: Where is INPO located? r20 you.

pil A: Atlanta, Georgia, the corporate - you r213 A: Well, and then Dave was concerned and gIm know, the mnain headquarters. rM~ he called me. I was CD 00 8 rzm 0: Is that where you were? pm 0: Why was Dave concerned? C008

[243 A: Yes. J243 A: Well, he was concerned from the l~s 0: Is that where Jim Bates and Jim Corbit rsq standpoint, well, he thought they was going through (17'f P2nrvoF00 - P!20& 0a Hall & Associates (423)267-4328 min-U-Scr-l""

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A" Lc Dauler 01 Lary L- Fiser v. Ronald 0. Grovc Tennessee Valley Authority January 29, 199 I

Page 100 Page Io:

iII a selection process. I mean, just Sam would have Q: Did You ever tell anyone else that he rA to go through a selection process just like had?

p] -everybody clse.And I guess he's gotten -- he's A: What, said that you have to make -

1g1getting input that, you know, this was already things -

ps made - you know, the decision was already made. 0: That.

0s: A done deal. A: Not that I recall, no.1I didn't - I pjA: Yeah, So we had talked because, you didn't - you know, I've just tried to repeat -what-pl knowlIhad heard feedback and then wewere trying wams said to me at face value, you know.Y6u know, pMto get - so he called mne.And I can't remember. that he expressed his sentiments and kind of the licj We're missing - playing phone tag or whatever, but way he wanted to go with this and that's fine.!I gi q he called me, I called him or I can't remnember who didn't argue with him or we didn't get into a long.

112] got ahold of who first, but he had stated that this drawn out discussion.

[12] was what transpired. You know, he'sthermanager and if 114] And I said, Well, as far as I know, that's the call he wants to - you know, the lisj Dave, you know, they've got - they're still going direction he wants to go, then that's the way!I tisl through the selection process unless somebody made looked at it. He expressed his - you know,-he was gi~i a decision and didn't tell Me about it, you know.. pretty clear about his sentiments. So I didn't see fill] So I wouldn't - you know, I wouldn't any need to pursue it further.

[lq personally put stock in it from the standpoint of MS. JONES: Okay. Give MC just about p it's a done deal and ihe decision was made to go ten minutes to review my notes.!I think I'm pretty 1211 another way.We still - as far as I know and as close to done.-

pm far as the FIR people told me, we're still going (Thereupon, a brief recess was taken.)

pi3 through the process. - BY;MS.JONES:

p241 So I told him that that's the way I'm 0: Mr. Grover, you just had a lengthy s) proceeding with this as far as my participation is conversation out here in the hail with

. I, Page 101 Page 103 112concerned.And I can't - you know,!I can't attest Iij Mr. Marquand. Do you need to change the answers to gMto what - that statement he made to you, you rm any of your questions, any of the questions IPvc p; know.You know, unless something - some decision masked you?

141was ma de that I wasn't aware of, this is the 141 A: No.!I think, Brent, you wanted to just Msdirection we're still going with this. *s clarify.

t6] 0: Well, it was your feeling from talking g* MR. MARCUAND: No. If counsel has got m to Mr.Volar that Sam Harvey had led him to believe m any more questions, go ahead.

Is otherwise. *' A: No.!I didn't want to change any M A: Correct. 9]answers.

lio 0: Okay. Let's move even further back in [10], MS. JONES: Allright. Ihavecnothinig 1111time to the discussion we had talked aboutcearlier- 1iifurther.!Ipass thecwitness.-

lial where we talked about the potential transfer of Sam 112] CROSS EXAMINATION 1131 Harvey to the Sequo)-ah plant prior to the posting 1131 ~BY MR. MAROUAND:

[14] and selection process that happened 12ter.Arid you gp4] 0: Mr. Grover,!I have a few' questions.

1151had related to me the conversation, to the best of lisj Counsel asked you earlier about the amount of l]s your memory.,! think, of Mr. Magrath about how he liS] time - let me see the exhibits.

11¶1 had disapproved of that idea, transferring him out 1i73 A: Okay.

iiil there. [I]0: Referring to Exhibit 1, that's the -

ligi A: (Witness moves head up and down.) ligl chemistry and environmental protection senior tM0 0: Do you recall Mr. Magrath telling you, 120 program manager position. C 008 Ron, sometimes you just have to make things come - 121] A: Okay. - C 00 8 1- )4outthe way you want) rgz 0: And you testified that, in fact, that cm A: No. r23] Mr. Fiser and his peers who had been chemistry 1241 0: Did he say anything similar to that? 1241program managers when they were in this new siA: Not that I recall. i2s1 chemistry and environmental position spent a small Min-U-ScriptT (28) Page 100 Page 10

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- - -- - I - -- = *. rnonaia. u. tyrove3 Tennessee Valley Authority January 29, 199E Page 104 Pago 106 (13 portion of their time doing environmental types of II] A: Yes.

[2] functions. *~ 0: You're not claiming to be well vered pq A: Correct. *~in TVA human resource policy and practice.

i~i 0: AU right.When you review the written 141 A: It depends on what you mean by well

• s position description, which is Exhibit 1, is there csj versed. I feel like I've been -

si a very - is less than five percent of the paj Q: Do you feel -

m~functions - are less than five percent of the M A: I feel like I've got a little handle on functions environmental functions in the written [aj it with all that we've gone through, but I don't r~position description.) m claim to be the specialist. I think, you know, paq A: No, because it was written,you know, l103 after working with Ben Easley for a time period, I (113I on a balance - the attempt was - like I said 1111Ifelt at least we had a -

[12l before, a balanced PD to combine chemistry and 1123 0: Comfortable.

[12] environmental. So on paper it should be a (13] A: It was my responsibility as a manager

[143 balance.

1143 to have a good working knowledge of what could be 115] You know, ideally we were shooting for [isI done and what can't be done. So I felt pise an individual could - could spend half of his time (16] comfortable. Now, I'm not sitting here claiming

[17l with the chemistry, half of his time with (17l that I w.as the expert in all the nuances of what aiaenvirornmental, 60/40 or whatever the need is for l153 the policy was, but I felt I had a good working ligq the plant. So it wasn't limited to just five p~l understanding of what the policy was.

poj percent, you know. r~q 0: There waS a discussion about your nij1 It wasn't intended for the chemistry 1213 understanding that if job functions changed by more rm people with the chemistry expertise just to stay = than 15 percent. then new positions - then any new rn)211al chemistry and just do a little bit of p22position descriptions which were rewritten are (243 environrmental.Wc were trying to cross-fertilize 124] required to be posted. Do you recall that 12S) and get everybody up expertise-wise. ~tsl testimony?

I Page 105 Page 107 111 0: AslIunderstand it, your intent was pjI A: Correct.Again, I don't know if that's 912that over time people would pick up the expertise

• fact or not.We'd have to talk with the HR people,

[33 in the othecr area and work into a more balance.

• but I believe it was around 15 percent.

14 A: Correct. 141 Q: But at some percentage there's some Is Q: Okay. *s sufficient dissimilarity that they're required to Me A: Yeah, but that didn't happen.That was *s be posted.

M our objective, but it didn't happen in the time (7 A. Correct.

M frame we're talking about. l Q: Now, do you know, in fact, if the i'l 0: AUl right. Now, later counsel asked m policy is to compare the written position (1i3 you about your understanding of the consequences of l103 descriptions or the jobs that are being performed.?

p11 reorganizing and eliminating positions and there (113 A: Well, the way it's supposed to be, the 1121 was a discussion about whether or not positions (12] way it's supposed to work is the jobs that you're psl were similar or dissimilar and what the [13 actually performing should match the position (143 consequences would be. Do you recall that? (141 description.

1153 A: Yes. (153 0: Right.

(16) 0: Where did you gain those types of (16] A: So there shouldn't be a disparity in pil understandings about the personnel consequences? [17] your position description with what you say you do piuq A: Talking with the 11T human resources, [iing on paper and what you actually do. If there is a liq you know, specialists involved and particularly 1193disparity, then it should be rectifled. So it pqo primarily Ben Easley at the time.We worked - he [201 really starts with the position description, which 1213was assigned to our organization, so we did all our 2,1]is what's written.

q you know, really conversing with him. pm 0

Okay.So they compare position CDOOO7b"-

q 0

Did you rely on the human resource r223 descriptions?

(241 specialist and Mr. Easley to tell you what the r243 A: Right. Now, if there was some reason pms human resource policies and practices: were? r253 why you can't do everything in the position I

Hall & Associates (423)267-4328 manuscripts MnUSrp (29) page 104 - Page 20',

AAA L-ur- 1L11LLte1 01 (3ary L- FiSer 'V. Ronald 0. Grover Tennessee Valley Authority, January 29, 199E

- - -- I PsIgo 1 08 IPage 110 lil description, it should be understood, and I think I on the environmental side, but chemistry, that was m in this - in our particular case it w.As, you know, rm one of those tasks where we actively - chemistry p3 what we were trying to get to, that sort of thing. -

pi people had expertise and they actually helped out.

141 Q: AUl right.You're familiar with both ['I 0: In fa ct, it's not -oyuknwf gjPlaintiff's Exhibit I and Plaintiffs Exhibit 2. lq it's TVIA human resource policy that an individual pl A: Right. *6has to, in fact, be doing all of the specific M Q: just looking at the position

• assignments or that they can just be assigned some iii descriptions, are they similaror dissimilar? jai of the specific assignments consistent with a M9 A: Arecthey similar or dissimilar? 1' position description?

liio Q: How much -are they substantially- - ciol A: Well, if you look at it - you know, pili A: Well,they'recdissimilar because you've [11 1'll call it - use this, coin a phrase, letter of p2] got the environmental piece. 112]the law, I mean, from HR, again, you're supposed to I13] 0: Okay. [13] be performing - you're supposed to be actually giaj A: But in actuality, I mean, you know, [143 doing what the position description says you do, jis] from an actual standpoint or a practical 1153you know.That's the purpose of the position l193 standpoint, you know -you know, klkeIsaid lis] description.

117) before, the chemistry people did the same thing (173 0: Your manager can assign you any of lisj functionally in one that they did in the other. 1151these things.

[lo] Q: Now, you told us that you had a number, [191 A:- Your manager has that flexibility, rWcof people reporting to you.You had Mr. Fiser, pqo but his intent is to have you do what's in the-1211Mr. Chandra, Mr. HarveyAllcn Sorrell. 1212otherwise, you have the wrong position M A: Right. No. David Sorrell. description.

M 0: David Sorrell.And what job 0: Okay.

124j description did David Sorrell have? [:243 A: You know, so you should be right in -

-iA: He had the same description as this P1) 12:1the position description should be developed based-J Piage 109 Paeg Ill gil dated 10-17-94. lil on what you actually do and - lunless we were 0: But he was performing primarily rz trying to 2cco'mplish something different in this Pienvironmental functions? p3 case and that's'what we stared out with the 14I A: Correct.And we had another 1i' objective of doing.

rsj individual.Jim Mantooth, who was in the PG-7 pi2 0: In fact, you were trying to accomplish le] position. Primarily same - same basic position 162something different rpl description, but it was PG-7 instead of PG-8 leveL. p~A: Well, that's why we laid out the QI: So under this position description. - 'jaobjective, but we didn't get there, but, i which is Exhibit 1, an individual could perform any M functionally - you know, I'll be honest with you, 1101oftthese functions consistent with that position l10] functionally the chemical guys still did the sm 111qdescription; is that correct? pisj thing.The environmental guys still did the same 1122 In other words, if you had ain l123 thing under the existing PD.'Wc didn't get there 1i31 indivi~dal who was working as a senior technical p13] yet, you know.

114 adviser on specific environmental permitting 1143 Because you change it on paper doesn't 1'51 tasks lis] mean you have the ability from a humnan standpoint, 1162 A: Correct. l163 from a personnel standpoint, to go right in it, but 1,7 Q: - that's the type of thing that 1173if YOUgot aplan to try to transition into it,'

liel Mr. Sorrell and Mr. Mantooth were working on? l163 which we did that's What weC waIs tying to do.

pis A: Correct. p193 0: You said that Mr.'Easley express ed some

'j 0: And at the same time you would have 123sentiment about not posting for competitive bidding individuals suchas Mr. Harvey or Mr. Fiser who r21 the new chemistry program manager PWR specialist were working as TVAN senior technical experts in rcz position. Do you recall that testimony? D008 FZ]chemical trafflc control? A: Correct.

124] A: 'Well., let's use anothecr example, lab 24] Q: Do you know if, in factat Some point

[2si QAQC, because chemical traffic control was really [291 in time he did compare Exhibit 1 with Exhibit 2 to Mm-U-S cript (30) Page 2.08 Page 111 Hall & AssociatesAssocIates (423)267-4328 (423)267-4328 Min-U-Scripft .(30) Page i08 - Page Ill

Ronald 0. Grover Tennessee Valley Authority, Januar'y 29, 199f I.

Page 112 Page 114

[11determine if they were substantially dissimnilar so Ill 0: Well, do you know that they interviewed m as to require that the position be posted? m2people for the BWR chemistry program manager pi A: I'm sure he dlid.You know, he didn't ( position.?

pi sit down with Me and say, Ron, let's go through 14 A: Well, yeah.The PW and BWyeah.Yes.

• Sthis line by line, but he had all the PDs. He was 5]Yes.

• Sreviewing it.He has to make the determination. 0 : Do you know that they interviewed r* The organization has to consult him, pi people for the environmental - I guess it wasn't

• his organization.The operating organization1 you

• envionenta; was it?

• know, the responsible organization that is doing

• A: Well,theRidvwastecenvironimental liq the change, making the change, has to consult the p10position, they combined that function.

piij human - that's the way it's supposed to work. un 0: That wvas interviewed on the same day?

p~ They're supposed to consult the human resources p~l A: I don't know whether that was the same pisj personnel, the appropriate personnel, and decide [12] board or they interviewed - they may have. I 1114and with them get the right way to do this. [14] don't know. I don't recall.

gisj Here's what we're trying to do.Advise l151 Q: Now, you, in fact - you earlier piq~ us as to how we're supposed to, you know, PSietestified as to the individuals who were on the p1] procedurally do it in the right way. (i~ selection board, Mr. Kent, Mr. Correy and Pick

[is) 0: And the advice you ultimately got from ciat Rogers.

liol human resources was that you needed to post th~at [193 A: Yes.

Wq position for bidding, the position in - 1201 0: Do you know, in fact, who chose them to ail MS. JONES: Objection. Leading and [211 sit on that selection board or is that something im mischar-acterizes his prior testimony. ra you just have an understanding about through the M A.~ Well, I wasn't - again, I wasn't - 12A grapevine?

gm) Q: Okay. W2' A: No.1I don't know who made the final.

p k-in this process directly. My A. I12S] selection. I know Wilson McArthur was involved

- --- I Pae. 113 Pagla 115 li conversations with Mr. Easley were that he *i with that. I mean, he shared that with me, but -

pi expressed concern, sentiments or whatever you want

• 0: He was the selecting official PI to call it that it looked like on - based on the pi] ultimately, wasn't he, for the positions?

1'j way these were written, there was that 15 percent 14 A: Right. But he was also involved

• or greater change functionally in what they did. pi with selecting the people on the board.!I

• s Okay.And he understood it because he was with us mudon't know whether he came up with the names and p* with this whole process in developing it and so mn Tom Magrath approved it, but I know he had

• forth, you know. Now, again, I wasn't in that involvement because he - you know, he discussed

• loop. Okay. that with me. He said, you know, he was involved 1101 Q: Okay. (10] with that.

(113 A: Because I wams basically, you know - [113 0: 'The day they interviewed people for the 1121 0: You were a bystander. [¶2] PWR chemistry program position, did you witness who 1ps A: That's right. So he - but I tried to [12] was, in fact, present for the interview?

liq help.And Wilson asked me. well, can you give (14t] A: No.1I wasn't. you know, aware of -

lisqcomments on this and this, that and the other. So [15] 0: Of who was actually involved in the -

1ps)I tried to help as much as I could.Although, I liq A: Right.This was only feedback I p~ wasn't in the process, I still tried to help, you [17] received of who was actually on the board from -

pi] know, take - you know, with this transition. pist you know, the candidates mentioned who was - who pq 0: Now, when the interviews were - I want [19] sat on the board to me. rDOOO79O pqto change the subject 2gain.When the interviews gmj And I may have been in error because I 1211were done for thec PWR ch emistry program manager, on 1211want to correct that if!I had stated that, YOU gm the day they were done, that selection board also ;M know, Ben Easley was - was on the board. I know rim interviewed people for a number of other positions; r231 it Was an HR representative.!I may have said Ben 12'] didn't they? 12'] Easley. I think I understad from you that may pqS A:-I don't - Idon't recall. 125] have been an error and it was another -

I Hall & Associates (423)267-4328 MnUSrpt Min-U-Scripft (31) Page 112 -Page ll5

In thie matter of Gary IL Fiser v. Ronald 0. Grover

-Tennessee Valley Authority Taflhl-r J QI QQ.1

.I ll0:'!I can't testify. Pg 1 Page 118

• 1 outside.We were going to canvas outside.

A: Oh, okay. But I just w.ant to let you

• 2 0: So the explanation was to you as to why

.aI know I - this was feedback I got and I may have pj it wasn't necessary to conduct -

t~ been in error in that, but there was an HR.

j~A: Correct.

• s representative on the board.

0: - a search or even a bidding or rs Q: You earlier testified that, of course, whatever.

• obviously you came to TVA after Mr. Fiser's p~A: Correct.Because initiallywhen Icome

• I previous DOL case had been filed.

9]A: Correct.

s*to the position, I mean, we were going to look for

• 2 candidate to fill the position. So I was taking l1010: And you said that you were told by j10] action to do that.And then,!I guess, the tiij Wilson McArthur that Mr. Fiscr had a previous DOL j11 settlement was reached and then we were told, well, 112z case.

l12] let's all stop and this is what - how it's going In2] A: Correct.

jal~ to tanpir.

1141 0: What wAs the context of that

[143 0: Okay.There was some discussion in lisi conversation?

j1s] your previous testimony about Mr. Fiser applying liq A: Well, he had mentioned to me - you

~Inj for a job at INPO and comments that you heard, ls7 know, he had discussed with me to an extent that it I17input that you heard, about Mr. Fiser being lisj was - it was really tying into the vacant position IISJ involved in the middle of a DOL complaint with lio that the decision was made with the settlement that 19] TVA.

120 Mr. - you know, Gary Fiser would be returning to p20 A: (Witniess moves head up and down.)

[213 TVA and would work back - would come back to the 3211 0: And you said you heard that frornJim rn chemistry organization and would fill that t=2 Bates, who is a-n INPO employ ee.-

rn position. [23 A: Right.

-"4 And that's when he said, well, you 1241 0: And he expressed or he had heard 1know, it was part of a complaint that was fiLied and [25] something along those lines frornJim Corbit, I

Page 117 Page 119

[13 a settlement was reached and that sort of thing.

lil another lN`PO employee.

rM So it was tied into -it was tied into -because m A: Correct.

p] he explained to me because I didn't - obviously pi 0: Okay.

141 I'm new and I've got a vacant position and I'm t4] A: Now,!I don't know whether he heard it

[5] thinking, wel~l, we need to go ahead and follow the

• 3 directly or he heard that he'd stated that.Again.

Muright procedure in getting it fllled. So he

• I'm just giving you what I heard from Batcs.That

[73explained to me the background and why Gary Fiser

• was the only negative that came up - issue that M was coming back into the position. pii came up that may have had an impact on him not pl 0: Okay. SO to summarize or rathcr for me m9being interviewed.

t101 to restate that, you were the manager of that l1010: AndlIthink you said that Jim Bates pill vacant position.

j11 knew Mr.Fiser?

gia1 A: Right. [isl A: Yeah.Yeah.T`hcy -they -yeah, Ijaa 0: And you were sitting there thinking i1ai recognizing that they had been in the industry a 1141 I've got to go through whatever the proper 1141 long time.They worked together in the pant and he l1s] procedure is to fill that position. l15] knows - Gary Fiser knows Jim. And, you know,

[161 A: Correct. jigu] they've been at the plant, so they know all the 0: And Dr. McArthur told you that we are 1ji1 117] long-term employees like Bill Nestel. CD 000791 piS] putting Gary Fiser in that position as part of the [la] You know,!I mean, they've either lip) settlement of his previous DOL complaint. jiv worked together or because of evaluators, they've e~~A: That's correct. poq known each other over the years. So all the 0: Okay. r211 permanent people there, long-standing permanent A: Now -and, you know,!was informed of rg people, basically the industry knows, but Gary pn that right before he - he returned because I was ziji has, you know, the opportunity to - he's worked 324] taking steps at the time to go ahead and try to i24 with them as well as been on - you know, been p2s] fill the position because we're going to look 325] evaluated at plants that he's worked at, that sort Hall& Asoc~tes 423267-328Min--Scipt~(32 Pag 11:Pag 11 HaU & Associates (423)267-4328  ?&n-U-Scripte (32) Pagell,--Pag-eI19

4 .. - ALACC4C1 IA "a y I- ritser V. Ronald 0. Grove Tennessee Valley Authority January 29, 199l Page 120 Page 121 of thing. (1) WITNESS CERTIFICATE MR. MARQUAND: That's all the questions I have. 1.RONALD 0 GROVER. do hereby certfy:

MS. JONES: Nothing further.

FURTHER TIS DEPONENT SAITH NOT. That I have read and axamined the 4l cordernts of the foregoing pages of record of testmnony as gNven by me at the tinm and plaice

[ heretn aforemernloned; q And that lo the best of my kinowbedge and beliel the foregolng pages are a corplete and

[71accurate record of a&the testirnony given by me at aid time, except as noted on the errata sheet (el axtached hereto.

I have or have not made corrections to be arlachad

[to) tII) 1123 RONALD 0. GROVER

[13) STATE OF TENNESSEE )

114) COUNTY OF HAMILTON 1[S] 1. Notary Puilc for the Courty od Stat of

[is) hereby cerlty:

[17) Thai the herein above named personaly appeared before rne this day df tq 1998, and that I personaly winesed the execution of this document for the hIents and purpose hereh

[tsq above descrtoed

[20 Swom to and subscrbed before me this dayof .t998.

[211 _j NOTARY PUBUC My commission expirs:

124)

R1P Page 122

[l) The winess. RONALD 0. GROVER.

M requests the foDowirn changes to be nade In the M transcrit of the depostion which was taken on 14)January 29. 1998.

s PAGE LINE CHANGE "3

In M

PI) 12 1131 114) 116 11)

E13 RONALD 0. GROVER

[21)

Notay Pubic CD00079 2 124] My cormission spires:

M)

I -

Hall & AssociateS (423)267-4328 Min-U-Scripft (33) Page 120 - Page 22

-A LA; J+/-LULLCX 01 LtarXy L. klSer V. Ronald 0. Grove Tennessee Valley Authority January 29, 199:

Page 123 Vi] REPORTER'S CERTIFICATE STATE OF TENNESSEE:

K, COUNTY OF HAMILTON:

1,Cathy H Kerley the ofiter tq before whom the foregoing deposhion was taken. do hereby certfy that the witness whose testimony (7] eppears in the toregoing depostion was duly swwm by rne; That the testImony of sald wttness was

[, taken by re In machine shorthand and thereutter reduced to typewriting. that the said deposilion Is

[1i] a true record of testirnony gIven by sald wtnesw:

t1i That I am neither counsel for, related to. nor erployed by any of the parties to the

[22 action in which this deposition was taken, and further that I am not a relative or errployee of any p3] attorney or counsel employed by the parties hereto.

ror financially or otherwtse hnerested hIthe 114] outcome of the action:

1151 Thal the saJd deposion ha Inno manner been changed or altered since same was given sie6by said wttness, but that the same has remained in rmy possession up to the time of delvery.

[171 In witness whereof, I have hereunto set IS rrnyhandthis dayt t998.

fll) 121] CATHY H KERLEY, Regislered Prolessional Reporter.

Notary Public In and for the K State of Tennessee at Large.

My commission expires June 23. 1M.

124]

ZE CD000793 Mm-Ti-S cripti (34) Page 123 Page 12 AssocIates (423)267-4328 Hall & Associates Rail (423)267-4328 Min-U-Scripte (34) Page 223 - Page 22

Lawyer's Notes CD000794

In the matter of Gary L- Fiser v.

Ronald 0. Grovc Tennessee Valley Authority

-9 I'nur -Q 97 31:19,20, 21, 22: 53:6 ahold 100:12 attest 95:1-2, 101:1 115:22,23 98 31:22 Allen 108:21 attorney 6:3 beside 29:13 99 31:22 alleviate 43:11 attributed 47:10 1 12:4,8;13:22, 14:19. 9920 4:9 Along 75:24; 118:25 best 16:13; 61 :5; 101:1 5 15:3; 16:7; 21:14; 24:1 0; Authority 7:25 better 25:19; 38:11 26:10,25; 27:23; 28.7; already 35:2; 36:22; available '41:25; 45:11, bid 11:18S.20; 14:8; 23:1 30:13; 103:18; 104:5; A 71:21; 95:17; 100:4,5 12;70.24 60:2 1;62:6:64:7,20 108:5; 109:9; 1 11:25 Although 113:16' aware 6:9; 12:1'7; 23:4, always 37:24: 38:1 0, 10, .14,14,22;42:6,23; 45:10; bidding 11 1:20: 112:20-.

10-1-94 75:5 abbreviations 23:3 12;39:22:41:5; 66:24; 47.24; 53:16; 58:23; 118:5 10-17-94 109:i ability 11 1:1 5 67:2; 8 5:23 64.25; 68:3,6, 10; 69:24; bIg 19:20; 36:13 11 8:1 able 16:25; 17:13,16; amount 22:4; 36:2; 70:1;71:23; 72:1; 73:20, Bill 119:17 15 5:1 1; 60.14, 18, 61:23.- 33:25; 34:14; 56:1 1; 60.17 37:13; 60.15, 17; 78:16; 24;74:1 1;79:16; 81:10, bit 25:18: 27:19: 54:12; 23,24; 62:25; 87:7; above 36:6 13,18; 83:17,21; 84:5, 10, 106:22; 107:3; 113:4 103:15 64:4; 73:25; 104:23 absent 75:21 12: 85:16; 87:10, 101:4; 16 79.4,25 - analysis 8:11;80:13 blank 14:21 Academy 8:8 115:14 16th 5:14; 23:20 annual 74:16; 75:4 - blower 83:14 accommodate 68:2 away 47:7; 73:15 1734:4,8:35:15; 52:11; accomplish 16:22; anticipated 7.9 board 14:8,16; 16:5; 79:5 111:2,5 anymore 50:5 64:10o,14,17,18; 65:1,4.

19 33:24,24 accomplishing 31:7 anyone 5:23; 42:4; 85:25; B 7;66:1 1; 67:9, 22; 68:12.

1993 81:1 accountabilities 15:4, 95:9; 102:1 22; 69.19; 70:11,12,16, 1994 7:20,21; 11:1 15; 25:4; 57:23;80:20 application 70:19,21; back 10:4; 21:6; 25:1; 24;71:9, 21,22;72:14; 1995 74:17,17 accountability 15:14 71:1; 87:14, 17; 88.22- 292.24; 39:10, 17,21; 81:5: 83:20; 84:4, 9; 98:6.

a ccurate 37:7 applied 25:20; 87:10 40.1 1; 48:9; 50:12, 18; 11i3:22; 124:13,17,21; 1996 17:23; 23:9, 20; 51:5,8; 58.3; 60.24; 61:2; 30.21; 32:6; 74:20,87:2 achieve 32:7; 33:17; apply 39.25 115:5,17,19,22; 116:5 73:17;81:22, 24: 84:5; 1997 34:4; 36:21; 52.21 34:14,18,35:13 applying 93:21; 94:12, 90:18,21:95:20:96:6; boards 67:1; 71:11 1997-1998 33:25 acting 75:22 118:15 98:3,5; 99.14; 101:10; boiling 24:20,21; 26:8 1999 33:18, 19 action 37:1 5; 48.21; appointed 75:22,25 116:21, 21; 117:8 boils 38:21,21 118: 10 appraisal 71:10; 74:14; background 8:12; 44:12: booklets 70:22 actions 80:23 75:4,15 2 actively 110:2 appraisals 70:17 65:21; 66:1:71:5; 83:4; 117:7 boom 34:22 both 16:25; 17:3; 25:19; actual 74:18; 99:17; appreciate 44:9, 13 backward 58:9

>2 22:19, 23; 24:9; 2 5:22; 27:23; 55:4; 70:1 0; 71:17:

108:15 approached 41:17, 18; backwards 20:21 27:2,5; 108:5; 11 1:25 72:2; 108:4 actuality 108:1 42:18:44:18; 45:10; 48:6, 6Bailey 5:21 2000 31:13, 16, 21, 22; 9, 67:15; 69:6 boy 14:22 actually 16.7; 18:3. balance 56:2; 104:11,14; 33:8,18,19.34:22,36:12 24:24; 107:13, 18; 110:3, appropriate 112:13 break 19:21;70:3 105:3 28th 7:20,21,22 13:11I1:1; 115:15,17 approval 76:16 Brent 103:4 balanced 55:25; 104:12 add 21:22; 46:6 approved 115:7 Bar 27:9; 65:12; 66:10,18S Brian 4:23, 3 added 15:18, 25; 30:9 approximately 8:1; 9:9; 10:25: 17:22; 23:8 base 57:25 brief 30:17; 70:6; 102:22 addition 15:9; 29.6 based 17:17; 33:7; 59:7; bring 20:18;81:3;92.22.

3 74:24; 75:3 additional 36:2 area 4:18; 5:1: 19:6,8, 13; 60.8; 62:1 1; 63:18,72:12; 96:11, 23; 97:3, 11 30th 87:2,3 address 4:8 20:12; 54:7, 8; 79:9, 11; 79.14; 94:8; 110.25; 11 3:3 bringing 49:3 80:5 81:9; 105:3 basic 13:16; 18:14; 24:5; 37363 4:10 addressed 55:7 broadcasting 85:17 areas 26:2 36:7; 71 :3,7; 109:6 374 4:10 advice 112:18 broken 29:21 arena 21:3 basically 13:11; 15:11; Advise 112:15 Brown's 54:14;55:9; arenas 16:25 17:7; 21:25: 24:17; 27:16; 4, advised 38:11 adviser 109:14 argue 102:11 31:4,5; 38:15; 50:15; 65:1 1; 69:11, 17 around 39:23; 41:6; 51:13; 53:7;61:12, 13; BS 8:10 4 76:21; 79:3 affect 30:22 59:13; 84:,8;85:8, 17; 62:1: 89.25; 95:15; 99:12; budget 31:5; 32:8; 37:17; affects 39.2 107:3 113:11:119:22 45:7, 13,23; 46:8,8S; 40 31:12,25: 32:20; 33:14,17; 34:18, 23; afterwards 85:10 assessing 19:8; 80.21 basis 19.25; 39:3, 3; 47:14, 16 again 25:14; 27:15; assessment 63:18; 59:11, 14;75:18 budget/head 31:12 36:15; 52:18; 53:8 14,17 36:23; 54:23; 62:14; Bates 92:10; 95:15:

74:19 budgetary 34:13 97:25; 118:22; 119:6, 10 69 68:13; 73:6, 8; 77:1 0; 78:19; 80:3; 82:7; 85:3; assessments 80:21 assign 17:13; 19:24; became 84:10,12 budgeted 46:4 86:6;91:1, 21,92:16; become 81:18;84:5 budgets 53:1 22:3; 110:17 60140 104:18 94:22; 98:24; 107:1; begin 7:18; 58:25 built 25:12 110:12; 112:23; 113:8, 20; assigned 105:21; 110.7 -

assignment 5:10; 55:9. beginning 17:22; 87:6 SW 114:4 119:5 9 against 40:13,41:4 assignments 110:7,8 belabor 44:7 BWR 24:20; 25:7, 8,8, IlCk believe 6:11, 13;7:19, 21, 26:3; 27:10,11,18,23; aggregate 22:9 assumption 51:17 21; 16:3; 33:18; 35:15; 28.5; 30:10; 54:2, 2,7, 9.

9.30-95 75:5 ago 4 1:22 Atlanta 5:1 1:97:21 37:2; 60:14, 18; 61:23: 12,25; 55:5,6,6,10,14, 9 48:14; 9.4; 16:4; 17:21; agree 46:6; 78:17 attach 70:20 65:19; 101:.7; 107:3 18, 25; 71:18:72:2;74:6; 21:10,40:20 ahead 9.25; 60.7; 61:20; attempt 49:10;68:1; Ben 48:14, 15; 57:5; 61:1; 114:2 95 74:15 62:18; 69:3; 96:1 0; 103:7; 104:11 63:8; 65:20,20; 67:19, 19, BWRs 27:13 96 21:10; 30:22; 31:16 117:5, 24 attention 30:20 20;'105:20; 106:10; bystander 11-3:12

- ;- P - - - r.Tf0O1079S . . -

in wec matter of Grary L- Fiser v. Ronald 0. Grovc Tennessee Valley Authority January 29, 195c Charles 41:14; 44:17; 57:4; 583.3 113:1 5; 118:16 Conversely 17:15; 19:18 decision 9:13; 10:2,8; C 50:13; 65:9; 69:4; 83:21 common 42:7 conversing 105:22 33:4,6, 10; 52:17 check 49:8 Corb It 93:5, 6, 19; 94:13. 53:23; 58:12; 6' it communicate 68:17 Ca 11 :14; 44:3; 88: 17, chemical 8:16, 18, 19, communicating 38.3 18; 97:25; 118:25 24; 89:2, 5, 13; 96.20; 90:19, 21; 92:22, 17:2; 18:22, 23; 19:1 0; Company 8.2 corporate 5:7, 17, 19,20; 102:14; 1101I1; I113:3 94:8, 11;95-2, 3; 97:6; 93:17; 109:23,25; 11 1:10 comparative 54:23,24 8:16,17; 10:23; 11:5,6; 100:5, 17,20; 101:3; called 4:2, 10:16; 18:22; chemicals 18:24 20:13; 39:17; 47:3; 48:1, 2; 116:19 31:2; 60:5; 67:21; 73:21; compare 107:9, 22; 49:19,20; 65:15; 97:21 chemist 93:17 111:25 decisions 90:17; 91:10 91:3; 93:16; 99:22; 100.9. corrective 80:23 11,11 chemistry 8:17, 18; comparing 24:7,8,9 Dedra 44:2 10:19, 20, 23; 11:2,6; correctly 17:24; 36:20; calling 54:5; 63:1I6; 92:6 compete 40:16 55:3; 58.8; 65:9; 76:15, 17; defined 53:24 129.919; 13:5,7,10,19; Calls 66:12 15:12,17,25; 16:15,16, competent 16:14 84:7;90:3 definition 11:15 came 6:12; 37:20; 68:7; 17; 17:5, 8,9, 13,16; competing 40:13; 41:4 correlation 30:1 degree 8:9, 10; 66:5 71:17; 72: 1; 86:14; 90:20; 18:17,21,25; 19.5,7, 13, competitive 62:6; 11 1:20 Correy 65:1 1;69:9, 11; Delaware 8:3 92:25; 98:1 1; 115:6; 17,19,24; 21:3,4,4,7,11, competitively 23:12; 83:25; 114:17 delineate 29:6, 8 116:7; 119:7, 8 23; 22:1, 1,4,24; 24:19; 64:7 costs 36:14 denominated 74:.6 can 4:7; 9:20; 12:1 1; 25:3,3 11; 26:2, 3,6, 19; Complainant 4:3 13:19; 20:15; 23: 1; 25:19, couldn't 35:25,25; Department 6:24; 7:1; 27:6,13,15, 18,21; 308.8 complaint 81:11,14,23; 21; 28:13; 29:2; 32.25; 36:12; 67:23 11:4; 18.3; 30:23; 33:2,2:

10, I11; 35:6, 12. 17; 39.7; 83:14,23; 84.6, 11,20; 33:5; 36:14; 39:18S; 40:15; 40:19; 41:15, 16; 51:1, 13; counsel 86:4,6; 103:6, 51:1;73:21, 22; 75:22, 85:2, 15; 86:1, 13,15; 15; 105:9 88.6; 89:4; 91:15; 93:8; 52:18; 53.6; 61:19; 62:13, 53:19; 54:6,7,8,10,13, 90:16; 116.25; 117:19; 94:7,16 19; 64:6; 66:6; 69.22; 70.4; 18; 55:13; 56:9; 65:10, 11, 118:18 count 31:12; 36:20; 74:12; 78:11, 21; 86:1 8; 22; 69:12; 73:21, 22, 74-3; 38:22;46:4,7, 17 departmental 89:4; 91:3 88: 15; 90:2; 96:20; 110:7, completed 73:23 76:21;78.18, 25; 7,9:4,9, counterparts 38:19; departments 74:4 17; 113:14 completely 52:23 39.6 11; 81:8;. 88:6;.93:8; depended 45:9 candidate 72:6, 13; 103:19, 23, 25; 104:12,17, completion 18:4 couple 16:12 80:25; 81:2,2; 88:14; composition 68:12 depends 106:4 21,22,23; 108.17; 110:1, course 64:21; 81:12; 90:22; 93:24; 94:3; 118.9 2; 11 1:21; 113:21; 114.2; concern 38.3; 90.7, 15; DEPONENT 120:5 99:6; 116:6 deposed 4:4 candidate's 70:17; 79.22 115:12; 116:22 113:2 cover 30:11 candidates 40:22; 64:11; children 4:16 concerned 99:21,23,24; deposition 5:22; 7:R. 14; Cox 66:21; 67:7,23 12:4; 22:19; 74:21 72:18,76.8; 77:17; 78:24; choice 43:16; 50:1;73:8, 101:1 89:1 1; 91:1 1; 95:5; 11 5:1 8 Cox's 68:2 82.8; 87:6 13 concerns 84:18S; 85:13 canvas 118:1 create 58:13; 59:14, 15 described 12:2 choose 72:6 conclude 62:10 capacities 17:3 created 14:18; 16:5; 46:1 64:6 chose 53:1 1; 114:20 conclusion 62:15; 95:10 creating 35:2:59:10 description 12:3,9, 18; capacity 66:7; 76:1,3; chosen 14:17 concurrence 56:14; 57:1 85:6 creation 57:5; 58:10; 13:12,17,21; 15:7,7; Chris 91:17,18; 94:16, condition 81:.7 98:5 16:9; 21:14; 22:16, 18,24; carried 22:1; 45:22 17,18 conduct 118:3 23-8,15; 24.7; 25 20; 26.9, carry 36-8; 38:9 Creek 4.-9 chunk 36:14 confidential 85:24 27:22,30:13; 35:1; 56:12, case 6:17; 82:7,9, 10; criteria 34:1 1; 62:12 57:6; 58:10; 59:15, 16; claim 106:9 conf lict 67:14, 16; 68:4,7 90.6; 95:13; 108:2; 11 1:3; CROSS 103:12 claiming 106:2.16 conjunction 51:20 116:8, 12 cross-assumption 18:2 62:5; 93:15; 10-4:5,9; clarification 57:20 consequences 105:10, 107:14, 17,20; 108:1, 24, categorize 55:3 cross-fertIlization 17:12 clarity 103:5 14,17 25; 109:7,8, 1; 10:9,14, category 60:24; 62:24 cross-fertilize 20:16; classified 5:6,15 considerable 37:13 104:24 16, 22, 25 Cathy 6:13,15, 22; 7:4, 8 consideration 33:13 clear 30:6; 61:4; 102:17 cross-training 18:2 descriptions 11:13; certain 34:1,3; 59:10,22; 22:15; 24:13; 28:1,4,5; climb 21:2 considered 60:15 current 5:4; 11:16; 31:12; 72:15 30:1 1; 56:5, 18; 59.23; close 23:24; 102:21 consistent 57:11, 16; 71:6 Certainly 78:20 109:1 0; 110:8 106:23; 107:10,23; 108:8 challenge 50:9 closely 58:18, 21 cut 32:21 consult 112.7,10, 12 designated 98:18 code 4:11 cuts 33:21 challenges 19:15 consulted 58:12 determination 65:3; Chandra 55:1,8S; 56:16; coin 110:11 70:18S; 88:16; 112:6 contact 96:10; 97:1,2,18 69:12; 71:17; 72: 1; 73:3; collective 39:3 contacted 96:5,7,23 D determine 112:1 75:25; 108:21 college 4:20; 8:5,7 develop 14:6; 32:10,12.

Chandra's 42:13 combine 13:4; 14:6; contacting 96:24 80:22 content 24:4,5,6; 58.3 data 79:23 Chandrasekaran 8.25; 16:20; 51:14, 14; 57:23; developed 110:25 60:12; 104:12 context 23:.14; 96:1; date 3l:1;84:10; 86:21 14:21 dated 23:19; 109:.1 developing 113:7 change 33:10; 59:13, 19; combined 11:2,8, 10; 116:14 Dave 14:21; 20.8; 98:21, Development 74:23 60:9, 9, 10; 61:22,25; 12:19; 13:2, 3,47; 21:1; control 18:24; 25:1 1; 24:18S; 40:10; 51:16, 19; 26:2,3; 27:15; 109:23,25 25; 99:5, 6,8,11, 15,16, developmental 5:1' 62:4, 25; 103:1, 8; 111:14; 21,23; 100:15 73:22; 74:4; 114:1 0 controlled 25:11 differ 15:7 112:10, 10; 113:5, 20 combining 11:12 controlling 18:23, 24 David 14:25; 108:22,23, difference 15:9; changed 60:13,16; 24 25; 27:7,12 106:21 comfortable 49:9; conversation 42:21; 106:12,1i6 day 7:20; 67:16; 113:22; differences 24:12 changes 24:3,14; 73:20, 47:18; 50:24; 63:8; 83:21; 24 coming 10:4; 19:2; 69.25; 96:2; 98:21;99:6; 101:15; different 14:3; 26:3; 81:22,24; 117:8 102:25; 116:15 deal 19:15; 100:6, 20 27:12,19; 46:12; 88:15; changing 35:1;60:1 comment 90:1 conversations 58:16; decide 112m1 111:2,6 characterize 54:20; dimensions 57:15 comments 56:22,23; 63:13; 113:1 dec ided 62:20 75:14 rf M~

.In the miatter of Gary L- Fiser v. Ronald 0. Grove Tennessee Valley Authority January 29. 1C9c)1 DIRECT 4:5; 8:23; 11:25; DuPont 8:2 12:10,19,13:5,7,11,20; expert 26:1; 106:17 20, 72:24; 116:22; 117:15 13:1; 29.11,25;42.21; during 6:14; 18.1,6; 19:1; 14:22, 15:10, 18,22; 16:8, expertise 20:15:26:18, 25; 118:9

__56: 1; 8 1:I9; 85:7 20-6;63:11,~fi, i1;87:9 14,18,17:1,4,10,10,14, 54:9, 12, 15,16, 19, 25; filled 9.2,6; 10.16; 11:7;

'" ilrected 32:9; 38:9; 79:9; duties 15:18; 16:8, 17:13; 15; 18:18; 19.3,12,20,22; 78:17, 24;80:12; 104:22; 34:12; 36:24; 58:8; 117:6 18:2,17; 24:13; 25:22; 20:5,12; 21:24; 22:6; 105-:2; 110:3 filling 10:5 26:25 24:15; 25:1;26:19; 28:6; expertise-wise 104:25 32:11; 53:25; 62:14; 72:9; 29:1 5;35:6,11,12,18; final 62:15; 63:20, 114:24 experts 109:22 find 89:2; 96:20; 97:8; 101:5; 102:15 52:23; 53:1,3: 56:10,11; directive 43:19 E 103:19, 25; 104:1,8, 13, explained 97:2; 117:3,7 99:16 18,24; 108:12; 109:3, 14; explanation 55:12; 118.2 fine 89:8: 102:10 directly 9.1; 68:17; 69.23;,

91:23; 98:12, 15; 99.10; E.S 8:-24; 14:21 110:1; I111:1 1; 114:7, 8,9 explore 41:6 finish 61:18 112:25; 119:5 each 11:9,24; 56:20; environmentally 15:24 exposed 59:5 finished 99:10 director 89:4 84:20; 119:.20 envision 33:21 expressed 42:3;62:23; firm 31:9 disapproved 101:17 earlier 98:23; 101:1 1; equal 66:16 63:14;85:13; 102:9,16; first 4:3:6:12:8:13; 103:15; 114:15; 116:6 equipment 25:11 111:19;113:2;118:24 14:13; 30:21; 33:20,23; discretion 72:22 Easley 48:15; 57:5; error 115:20, 25; 116:4 expressing 63:17 34:8; 35:20, 22,24; 36:21; discuss 38:5;79:25; 58:11, 12,24; 61:2;62:10; essential 24:12 extensive 55:4 38:13, 18: 39:5;42:19; 81:16;8S2:13; 85:25; 88:10 46:21;74:19, 20; 100:12 63:8; 65:20,67:19; essentially 21:12; 24:5; extent 116:17

'discussed 10:13: 31:3; fiscal 31:18,20; 32:21; 32:24; 34:25; 35.2; 52:9; 105:20,24; 106:10; 25:2; 27:1 6; 48:8; 56:13 34:3; 52:11, 20; 53:6, 9, 67:8,10,12; 84:15; 85:22, 11 1:19; 113:1; 115:22, 24 Easley's 61.~9 evaluated 119;25 F 15; 74:17 22; 86:14, 15:95:17; evaluator 93:8, 10,12, 115:8:116:17 educational 66:6; 71:5 Fiser 9:7,14: 10:4: 13:1; 14,18 face 102:8 14:20; 15:8; 16:4; 21:10, discussing 16:6 effect 90:3,4,8; 99:11,17 evaluators 119:19 fact 20:4; 21:1; 34:6; 22:5; 56:17 6.4:20:69:20, discussion 50:8; 55:22, effectively 44:4 even 40.17; 66:25; 98:19; 67:18; 75:20; 99:1; 25; 74:23; 75:4, 11:76:6; 22; 60.23; 61:2; 63:3; 73:4; effeactiveness 80:22 101:10,118:5 103:22; 107:2,8S; 110:4,6; 81:10,84:6;87:10,13; 75:19; 79:15, 15; 83:13; eff luence 80:13 events 86:19 111:5, 24; 114:1 5,20; 88:19, 20; 103 :23; 108:20, 98:23; 99:14; 101 :11; 115:13 109.2 1;I16:11, 20,117:7, 102:12; 105:12; 106:20, - effort 20.24; 38.8: 58:15 Everybody 11:14, 18; 36:1 1; 39.15; 41:3; 43:25; factually 73:10 18; 118:15, 17; 119:11,15 118:14 efforts 20:3 57:3; 100:3; 104:25 failed 80:13; 81:7 Fiser's 10.1 5; 54:19; discussions 59.1;61:4; eight 20:22 65:1; 74:13; 83:13: 116:7 81:19;84:15 - either 24:3; 46:16; 47:12; everybody's 39:15 fair 15:16,19; 21:9,18; Everyone 11:20; 16:13, 27:20,78:16 fit 32:25;61:1

• sparltyl07:16,19 119.18 fits 26:7 elicit 79:22; 80:12 24:56:23- familiar 23:5; 44:15; K.~,~ispute 92:8 everyone's 57:1 108:4- five 5:12; 8:5:13:3, 5; dissimilar 105:13; 108:8, eliminate 52:22 22:8,13,1I3; 31:14;40.22; everything 15:17,24; family 4:25 9, 11; 112:1 eliminated 47:5, 7;64:21 59:19; 91:5; 10-4:6,7, 19 39:14; 107:25 far 7:1 1; 19:1 1; 38:8; dissimilarity 107:5 eliminating 105:11 54:15; 58:3; 74:5, 11; flexibility 110:19 evolution 47:24; 58:19 distinction 26:14,21 else 27:4; 85:25; 100.3; 100:14,21,22,25 focus 16:23; 17:19; exact 31:1;84:9;85:5; divide 55:13 102:1 86:21 fashion 35:7 19:14,16:21:3,4; 24:6; divided 27:24 embedded 26:12,13; favor 18:11 25:8 exactly 10.25; 86:18 document 12:7; 15:5; 29:20 focused 17:9, 10 EXAMINATION 4:5; Feb~ruary 5:14;7:19,19, 22:22; 75:2,6, 10;77:1 employed 7:23; 8:2 103:12 20,22; 9:3 focusing 77:5 documents 28:11 employee 73:18; 87:22; examined 4:4 feed 39:10,17,21 folks 18:17, 22; 19.7; DOL 81:11; 116:8, 11; 92:8, 15; 93:7, 9; 97:9; feedback 57:22,24; 73:7, 73:17; 83:20 118:22; 119:1 example 18:21; 19:10;,

117:19,118:18 26:16; 32:6; 80:24; 81:5; 11; 88.23; 89:1,3; 90:10; follow 48.22,62:20; 64:3; dollars 47:8.9, 11, 13. employee's 90.:7,7.14, 109:24 - 91:21, 24; 92:7, 16; 94:8: 117:5 14; 52:4 16 100:8; 115:16; 116:3 follow-up 30:5; 41:12,;

except 27:16; 29:14 done 45:9; 46:25; 47:25; employees 8.20,89:20; feel 42:1; 106:5,6,7 70.9; 8 1:4 90:12: 92:14: 94:5; 119:17 excluded 28:3' 48:3,13:53:8; 54:13,14; feeling 101:6 following 62:8 employment 81:12; exclusion 24:15; 28:6 58.22; 74:14; 100.6,20, feet 16:1 follows 4:4 102:21; 106:15,15; 87:11,124:93:20 Excuse 8:12; 16:1 fell 7:22 force -43:10;53:5.82:4 113:21.22 enco urage 38:18; 39:5, ExhIbit 12:4,8S; 13:22:

14:19; 15:3; 16:7; 21:14; felt 41:19; 55:16; 63:19, forgot 6:19: 29:1 Donna 6:20,21 23; 40:8 22:19,23; 24:9, 10:25:22; 22; 82:16, 23; 106:11,15, form 7:7: 16:20 down 32.7; 36:14; 38:21, encouraged 38:11,12 18 26:10, 25; 27:2, 5, 23;, format 57:18 21:47:8,13,16; 49:19; end 32:6,11,12; 34:18:. 28.7; 30:13; 74:24: 75:3; Ferry 54:14; 55:9; 65:12; formed 13:14; 64:10 50.2; 52:18; 53:5,5; 55:18; 5 2:2; 71:23 76:2 1;79.3; 103:18S; 69:11,17 59:20; 88:1; 101:19; forth 23:19,48:8:51:6,8; ended 50.21;71:14 1104:5; 108:5,5; 109:9; few 12:15; 70:9; 77:21; 60:24; 61:2; 62:7; 81:-23; 112:4; 118:20 engineer 93:18 111:25,25 103:14 99:13, 15; 113:8 Dr 117:17 engineering 5:7,17,19, exhibits 10)3:16 f igure 22:4 forward 40:7;64:4;

'4rafting 56:5; 57:6,7 20;8:1 1,16,19;66:1,2 exist 11:18 - file 82:7,9:84:11:85:2; 68:24; 83:8 iw 95.9 enough 16:14 existing 111:12 86:13 fossil 8:18 Qawing 14:21 entails 31:4; 94:2 expect 43:4 filed 12:5; 22:20; 74:25; fou nd 20:6 drawn 55:22; 102:12 entire 32:20; 52:18; 53:8; expenses 36:2,7, 25 - 76.22; 81:1 1; 84:6; 85:15; foundation 9:17, 22; drill 41:2 56:7; 58:15;73:18;76:16 experience 20:19; 55:5; 86:1,16;116:8,25 69:22; 71:20 Drive 4:10 entries 75:10 58:20: 59:6; 70:12; 79:22, filing 84:19;90:7 four 9:9:13:13: 15:1; duty 4:3 environmental 11:3,6; 25;80:12 fill 20.22;45:19;49:20, 31:17,22; 40:21;77:12; P7,21 A. Acn-1.topC 4749 CD000797 f-% 11%r"Ire-r

In the matter of Gary L-Fiser v. Ronald 0. G-7ove Tennessee Valley Authority January 29, 199 91:5 great 89.7,15 helping 19:8 Individual's 84:21 50.8:51:19; 55:13,21:

fourth 15:1 greater 113:5 here's 38-5, 6,6,7,20; individuals 8:25; 20:1 1, 61:1;64:13;79:1' 3 67.21;81:5;82.2; 112:15 20; 36:3; 40:24; 42:11; 98.12; 102:1 1; I fra me 31:1; 41:13; 74.2 1; GREEN 6:20, 20, 21, 22 11 1:17; 116:18; 2, 84:8; 85:5,12; 105:8 herein 12:5; 22.20; 74:25; 43:4; 73:12; 87:20; groundwork 49:12 investigation &,

frequently 75:21;76:3 76.22 109.21; 114:16 group 8:16,17,18; 11:2, high 72:2 industry 119:13, 22 Invited 65:7 Frost 4:9 3; 13:7; 15:22; 16:16,20; 29:10,17,34:17,25; himself 84:16 Influence 91:12 Involve 36:17 fuel SO: 13; 81:7 fulfill 14:15 43:22; 51:19.56:7,8, 15; hire 72:16 Information 23:22; involved 17:5; 36:16:

65:15; 90: 12 hired 8:15,24; 9:10; 20:5; 32:22; 44:10; 71:3, 4,7; 53:22; 56:4,6; 57:5,7,8; fulfilled 15:12 86:20; 92:7,22,24;95:2, 58:14; 68:18; 90:1: 91:7; groups 35:8; 53:.13 81:20 fulfilling 50:2 16,18; 98:7,10,14 92:7; 105:19; 114:25; GROVER 4:.1,7,9,22,22, hiring 72:13, 14,15,17, full 4:8 Informed 10:3; 50:13; 115:4, 9, 15; 118:18 23; 12:4; 22:19; 30:19; 21,22, 23;73:2 function 15:10; 16:25; 71:20; 74.24; 76:22; 67:1 1; 82:25; 117:22 Involvement 115:8 17:3,7 18:25; 21:24;22:1, hlsseif 84:17 102:24; 103:14 Initial 30:25; 32:11, 22; irrelevant 82:18 2; 24.. 4; 25:25; 27:1 1; history 82:10 33:12,20,34:24; 35:4, 14; guarantee 40:17 Issue 22:17; 79:12; 119:~

38:23; 39:2.9,15. 21; hIt 36:21 37:1,3; 52:9 46:1, 2; 49:20; 52:23; 53:3; guess 18:8;48:5;73:6;- issues 19:14; 55:6 Hobfoster 91:17, 19,20, Initially 32:2, 19; 35:5; 57:1 2; 60: 10; 114:1 0 89.18; 90: 1, I11; 99:5, 14; item 25:2 5 100.3; 114:7; 118:10 21; 94:17,19 65:8; 88.23; 118:7 functionally 21:25; 30-4, hold 10:22 Iteration 51:23 guidelines 62:8,9 initials 22:.25 6; 47:1; 59:22; 108:1IS; honest 111:9 Iterations 51:6,22,25, guy 92:10 initiate 48.7, 11 11 1:9, 10; 113:5 horIzontal 35:7 25 guys 19:24; 11110,11 Initiated 48:22; 56:8 functioning 66:7 Howard 4 1:19 Initiating 49:.7 functions 11:12; 15:25; HR 6:16; 11:15;46:24 Ink 24:3 21:12 25:3;39:10; 53:1; 59-:1? '-1;60:I2;62:4; H 48:14,22; 49:6.57:10; INPO 10.24; 73:16; 87:1, 61:13; 62:15; 86:6; 96:7; 3,3,11, 17,20,25; 90.25: Jack 5:.20; 66:21; 67:7,23 104:2,7,8,8S; 106:21; 100:22; 105:18; 107:2; 109:3.10 hadn't 9.2; 34:12; 89:18; 92:12; 97:20; 118:16, 22; January 21:10 96:5, 15 110:12; 115:23; 116:4 119.1 further 101:10; 102:18; Jim 20.6: 92:10; 93:5, 6, half 8:3 17:20,21,24; HR's 57:11 input 56:8, 16,21; 57:2,2; 19; 94:13, 18; 95:15; 103:1 1;120:4. 5 104:16,17 huh 67:15 58:2, 11:64:13; 76:18S; 96:20:97:8,9,25, -

hall 102:25 human 6:16; 45:21; 57:8; 78:2,3; 82:4; 88:13; 89:1 0; 109:5; 118:21, 25 G hand 12:7; 22:22 72.8; 105:18,23.25; 91 :6; 94:11, 23; 95:11; 15 handed 75:2; 76:25 106:3; 110:5; 111:15; 100:4; 118:17 job 11:20:15:7;1I.- - .4;3 gain 105:16 112:11,12, 19 Instance 4:2; 25:21; 21:13; 24:7; 26:9; 27:22; handle 106:7 Gary 9:7; 14:20; 42.12; 58:23 28:1,4,5:30:10,13; 35:1; handwritten 77:4; 79.6 64:20; 74:23; 75:4, 22; happen 68:.24, 25; 92:5; I1 Instead 109:7 40:11, 15; 43:2, 25; 56:5;.

60:9,10,13:61:7; 62:5,6, 76:5,6;82:14; 83:22; 84:6, 105:6,7 Institute 5:10 16,17; 89:10. 18: 90:1,4; Intended 104:21 I11; 71:22; 93:15: 106:21; happened 82:17,24; Idea 17:1 1; 101:17 108:23; 118:16 92:.7;93:21; 94:12; 95:16, intent 105:1; 110:20 18; 96:75, 6; 97:2, 17; 98:6; 85:8; 89:23; 101:14 ideally 104:15 lobs 11:19,19; 18:17; happens 72:4 Identified 22:23; 27: 1; Interaction 72:12 20.6; 107:10,12 116:20; 117:7, 18; 119:15, 22 happy 46-6; 88:9 32:2; 79:5 Interest 79:12 John 65:10; 83:25 gave 22:10:53:25; 83,4; hard 80:10 Identify 12:11.23:1 Interested 41:3:49:3; JONES 4:6,9:24:12:6; 91:6 Harvey 8:24; 14:20; 37:2, Immediate 4:24; 32:5 77:5 21:17,19; 22:21;29:2; general 8:1 1; 29.7,21; 16; 4 1:7; 44:20; 47:20; Impact 119:8 Interim 35:15 30:18; 70:7; 75:1: 76:24:

33:2; 82:12; 87:23 49:16; 54:9; 56:16; 69:6; Implementation 26:18 intermediate 34:7, 19.20 102:19,23;103:10; Generally 15:6; 39:12; 98.8,17; 99:3, 4; 101:7, intern 44:2 112:21; 120:4 Imply 30:2; 86:22 85:14 13; 108:21; 109:21 Internal 44:15 Jr 4:22 Impressions 94:9 generators 25:9; 26:3,8 Harvey's 44:23,24; Internally 87:17 July 10.25; 17:21; 21:10.

50:24 in-depth 55:22 23:19 Georgia 5:1 1;97:21 Included 26:1 1; 27:22, Internet 85:18 gets 94:7. 11 head 17:23; 36:20; 46:3, Interpretation 79:23 June 10:.25; 23:8 7,17; 94:7; 101:19; 118:.20 23; 28.7;30:12;34:10; g1v4 -7, 10; 14:6; 34:2; 36:20 Interview 40:13, 21, 22; 43:. .8, 13; 95:8 headquarters 97:22 hear 96:4 Including 22:5 64:1 1: 88:17,25; 89:6, 14; K Incorporated 56:24 90.24; 91:2; 96:11,122; glitch 97:15 heard 69:1; 88:19; 89:18, 97:4, 12; 115:13 Incorporates 26:25 keep 10:14; 39:9; 49:19 23,25: 90:11.12; 92:.18, Interviewed 64:7,70:1 1; global 79:13 19, 23; 93:2,3396:2, 15, independent 91:10 78:16, 22; 113:23; 114:1, Kent 41:14 44:17: 50:13; goal 32:1,6; 39:19; 53:15 21;97:14; 100.8; 118.16. Independently 7:5 6,11, 13 115:11; 119:9 65:9: 69:4; 83:2 1; 11 4:17 goals 33:21;37:1 8 17,21,24; 119:4,5,6 Indicate 83:16: 98:17 Interviewing 40:.11; kept 7 3 :16 ; 8 5:2 3 .7' goes 39:13; 70:22; 82:18 heavy 19:13 Indicated 77:21 43:14 kind 18:9:20:3::

good 43:2; 57:21, 24; held 12.25; 15:8; 63:3 Indications 81:6,7 Interviews 7:16; 113:19, 75:15,16,19; 76:14; 20 79:22: 93:20: 99:.7:&-

help 17:17; 18:22; 19:8; indirectly 68:.20; 80:14; I1D614, 18 43:23; 58:5; 76:7; 113:14, 98:16 knew 38:4:.82:14: 85:1 1; Into 7:7; 11:8,10,18,20; Gordon 41:15; 50:13 16,17 14:8; 15:10, 25; 16:13; 86:21; 119:11 IndivIdual 15:1:26:20; gradua-~5:9 helped 37:17; 69:15; 39:3;42:17:72:15,16: 19.2,23; 25:12: 26.6,21; knocking 16:1 graduated 8:10 110:3 81:21,24; 91:14,23; 28:1; 40:6; 41:24; 43:10; knowledge 42:7; 68:15, helpful 44:10 104:16:109:5,9,13: 110:5 44:20; 46:8,23; 48:1,2; 19; 83:19, 22; 106'14 grapevine 114:23

7,I

- v v J3 A. A A V.

Ronald 0. Grovs Tennessee Valley Authority 1. ,, , 'I ".

Janluaryv 29, 199,,

January 29. 199k knowledgeable 19.6 loaned 92:14 103:20; 106:13; 110.17, memorandum 48:20 63:15; 70:9; 112:19 known 85:14; 119.20 loanee 87:21 19,111:21; 113:21; 114:2; memory 99.19, 101:16 negative 57:13; 92.24, knows 97:9; 119:15,15, located 97:20 117:10 24;95:11,20,23; 119:7 22 mention 20:2 location 37:3 manager's 14:13;72.22; mentioned 48:18;49.18; neither 71:22 long 50 8;55:21-89.21; 91:3 51:11; 55:15; 67:24; 83:3, Nestel 119:17

\ L 94:5;97:14,'102:11; managerial 11:7;84:23 9,92.11; 98:22,23; New 7:25; 11:19,19, 119:14 managers 11:9;35:18; 115:18; 116:16 20.18;21:13;28:4,4; 35_2.

L 74:23 long-standing 20:11; 39.7; 103:24 -- merged 40:5 40.15; 56:5,8:58:13; lab 109:24 119:21 managing 8i2:20 merging 16:16; 20:6 59:10,14,15;61:22; labeled 75:3 long-term 88:3; 119:17 mandate 53:18 met 15:13; 34:10;71:21; 103:24; 106:22,22; longer 11:17,18;47:10 Mantooth 20.7; 109:5,18 84:'4,9 111:21;117:4 Labor 6:24;7:1 longtime 97:9 newly 12:19; 14:17; 16:5 lack 9:16,21; 69.21; many 57:22;75:10 middle 90:6; 118:18 71:20 look 12:16; 22:9,23:22; next 6:3; 7:9; 17:19,20; March 30:25; 32:3;41:13 minimal 36:9 22.16; 32:21;33:14; laid 31:6; 33:7; 46:24; 31:7;32:16;33:6,15; marked 12:3,8;22:18; minute 30:16 52:11,20;53:9,15 111-7 34:16; 35:7; 38:13; 39:4, 74:23;76:21 minutes 12:15; 102:20 14,14,23,23; 41:5; 57:14; nobody 90:19 Landers 44:2 Marquand 5:24,25;6:1, mischaracterization 72:17; 75:17; 78:11 -83:8, nontechnical 18:11; last 7:20; 74:16,18; 75:5 12; 9:16,19;'14:24;21:15; 44:22 25:15 19; 110:10; 117:25; 118:8 later 27:24; 86:9; 89.2, 28:9,13,18,22;31:18; mischaracterize 45:1 normal 47:23 looked 34:15,17;35:5; 44:21;61:18;66:12, 17; 101:14; 105:9 41:9,46:12; 52:17; 88:22; mischaracterizes 21-16; 69:21; 71:19; 77:2;78:1;- notes 7:6,15; 77:4,4; latest 23:16.17,24,25; 95:5; 102:16; 113:3 28:10,112:22 102:20 74:14 86:4; 103:1,6,13; 120.2 looking 16:11;22:12, mislead 86:20 nothing 43:9;:89:17; law 110:12 33.24; 35:11; 42:4; 52:3,4; married 4:12 missing 100:10 98.15,15; 103:10,120:4

- lawsuit 22:17 66:16; 67:5;72.24; 89:10, match 107:13 nuances 106:17 modify 61:7 lawyer 28:15 91:11;99.12; 108:7 math 17:23 nuclear 5:7,10; 8:17 moment 84:5 lay 29:13 looks 23:23; 38:1 matter 10:13 number 10:13;22:9; month 97:11 lead 59:17 loop 113:9 matters 41:18 25:24,25;26:7,17,24; lose 20:21 months 5:12,12; 20:9,9, leadership 75:12 may 9:17; 28:12; 29:7; 22;87:7 27:1; 34:7,7; 38:14,17; Leading 112.21 losing 20:17 33:7,8,8,8,9,34:2,4; 51:6, 6; 53:19; 80:14, 19 39.24; 58.11,24; 60:17; more 17:5; 29:6,9,16, 108.19,113:23 learn 30:21 lost 20:4; 98:6 21;49.23;54:24; 55:5; least 17:2;36:21;61:4; lot 36:6,10,52:6;77:3; 61:25; 63:14, 24; 66:23; numbers 71:15 61:15; 64:4;72:18;73:25; 84:18 68:13,17;72:6,14; 83:22; i  : 6:11 79.13;80:3; 88:9;96:14; 86:17,18;93:22; 114:13;

,Iceave 47:2, 2; 70:8, 75:21; luxury 36:16, 115:20,23,24; 116:3; 103:7; 105:3; 106.21 0 86:25 119:8 most 70:17,20; 71:2,9, led 101:7 left 10.23; 20:7,8,40:18; AM maybe 20:19;62:15; 77:5 mostly 82:4' 0 4:1,9,22 76:2; 90:9 Object 9.16; 21:15; 28:9; 41:22; 43:14;45:19; 50 3, McArthur 10.3; 58:17; mountains 21:2 44:21;71:19 4; 51:18 Magrath 31:2;33:1,13; 47:19,48:25; 50:16,24; 65:6;67:11;73:2;77:24; move 20:3; 33:11; 46:23; objecting 9:21 legal 7:12 51:9,52:12; 53:14,18,22; 83:1;114:25;116:11; 47:25; 53:1; 64:4; 68:24; objection 9:20,28:23; length 35:2; 69:19 55:11; 56:4; 58:17; 62:16. 117:17 69.2;83:8; 98.3; 101:10 66:12; 69:21; 112:21 lengthy 102:24 17;65:6;68:11;83:12; mean 15.21;17:8;22:8; moved 19.2 objections 28:19; 58:24 less 16:21;22:7,13; 101:16,20; 115:7 23:12,19,24:2,8; 25:19; moves 101:19;118:20 objective 16:11,19,23; 33:13; 104:6,7 Magrath's 63:24 28:5; 29:1; 30:2; 32:4,5; moving 37:1;49:15 38:7,14,17; 43:24; 105:7; 42:7;43:1,13;44:7;45:1: much 20:25, 38:4; 43:23; letter 48.20,49:7,7; main 15:9,11; 19:14,16; 111:4,8 110:11 50.6; 51 4,9; 53:10,25; 52.6; 53:6; 108:10; 113:16 24:14,17,25; 27:12, 55:17,20; 57:13,14; objectives 31:6,9 letting 38:4.5 43:24;97:22 - 58:21;61:5;62:8;63:10, multi-page 75.9 Obviously 35:24;42:25; level 13:13; 14:1,3; maintain 35:25;39:1 20; 71:21;80:14,17; 82:1, must 51:24;84:14 73:15;75:9;78:12; 85:10; 20:19; 31:12; 32:8; 67:6; maintaining 36:20 14,16,19,24;84:15;85:3, Myron 4:22 87:21; 116:7; 117:3 93:24; 109:7 maintenance 65:24 12,16;86:22;87:18,19; - occasion 19:7 levels 67:3 major 19:il 1- 00:1; 106:4; 208:14; occasions 21:24;76:2 lied 54:16 110.12; 111:15 115:1; occur 18:5;20:1 makes 58:7;94:8,11 118:8; 119:18 limited 104:19 - making 9:19,28:18; occurred 6:18;30:20 meaning 35:14;36:3; name 4:8,14;6:19; line 25:24; 50.23; 112:5.5 93:20; 112:10 52:20 91:15; 92:10 off 17:8; 30:15; 57:25; lines 118:25 man 44:18;97:17 names 4:21; 115:6 61:25; 82:10;90:19,21 means 9:25 off-the-record 63:2 lineup 67:22 management 33:10; meet 31:10; 32:2; 33:25; nature i7:17;79:13 lining 94:3 75:12;79:25; 80:3 offer 56:21 37:18; 53:14,17; 57:17; Naval 8:8 list 15:18;76:16 manager 5:7,16;8:15; 62:24 Navy 8:4 office 36:9 -

'"ted79.2 10.18, 20,21,23; 11:5,6, meeting 19:9; 30:24,25; official 115:2 7; 12:19,22; 13:6; 14:22; necessary 118:3 le 18:20; 19:11;24:3; 31:2;32:3,23;33:21; need 12:15;20.14;39.8,,- officially 86:16 22:25;33:2;41:15,16;

.,:17; 27:19; 54:11,11, 51:18; 58:19,65:10,11; 41:13;99:5 8,10,14,17,18,20,21; old 29:8; 30:13 13,14;64:4;73:25;99:4; 66:17;72:13,14,16,17, meetings 51:13;56:25 49.12; 50:6 53:2,3; 90:18; on-site 37:2 104:23; 106:7 23; 73:2,75:22; 76:20; member 65:16 102.18,103:1;1-04:18; once 14:13,13;20:21; live 4:18,19 85:7,10;88:6;89.4;91:16; members 34:25;70:25; 117:5 64:5; 99:9 load 16:23 92:3;94:17; 102:13; 81.5 . - needed 21:6; 47:14- one 4:20; 11:8,10; 13:12, Hall & Associates (423)267-4328 - I C'r'l'i

-.-_?4in-U-S . aft CD000799 .cn'onvledeeable- one

In thle m~atter of Gary IL Fiser v.

Tennessee Vafley Authority, Ronald 0. Grovc January 29, 199 13; 14:1,2,6; 16:20,18:8; 19:22; 36:2; 47:15; 56:10; 14,16 19.10.12,24; 20.13; 24:8, 67.21; 105:2; 119:20 pointedly 43:7 preparIng 5:22 14,20,22; 25:12; 26:14, performed 21:11,12,13; pointing 25:21 overall 25.2; 75:10, 17 22:5, 89:12; 107:10 prerogative 53.-

17,21, 24; 29.8, 12, 13. policies 105:25 overhead 36:2,3,4,7, 10 preselected 9 20; 34:11, 12,13; 35:4; performing 107:13; policy 6 1:13; 106:3, 18, 38:14,17; 40.6;42:13; own 91:10 109:2; 110:13 present 151 45:16, 18; 50:2,3; 51.12, 19; 107:9; 110:5 pressure 43:19 period 18: 1,6; 32:13, 14; 15,17,19; 54:2,2,2; portion 29:3; 56:12; pressurized 23:3; 24:22-55:17, 18, 19,25; 62:24; IP 3 5:21: 63:12; 75:5; 87:9; 89:22; 106:10 104:1 pretty 20:25; 102:17,20 66:10; 69:18; 74:16; permanent 87:22; 89:20; position 5:4; 8:13,21; 75:15,25; 76:1;77:14; package 58:6; 70.22 9:11,14; 10:5,15,16,22; previous 21:16; 116:8, 7-9:5, 17;80:'8,8, 16; 81:4; 92:15; 93:9; 119:21, 21 11; 117:19; 118:15 page 15:5; 25:25; 26:17, 11:8, 13,16; 12:3,9,18, 84:14; 89:20; go:1I1; permitting 109:14 22,25; 13:12,14, 17,21; previously 6:7, 10 24; 70:4; 75:6 91:12; 92:14; 93:19; person 6:16,17; 18:12; 14:3,9,9,11,13,15; 15:6, primarily 17:9; 24:22, Paper 10-4:13; 107:18; 98:1 1; 108:18; 110:2 20:21; 25:15;41:22; 8; 16:6; 20.8,23; 22:15, 54:17,18,21,25; 66:2, 111:14 ones 27:10; 28:4 45:19; 56:11;69:5, 12; 16,18; 23:7,1II, 15,19; 93:13; 105:20; 109.2, 6 paperwork 41:1;86:12 82.25; 93:23,24,25; 98:16 24:13; 25:20,23; 27:-6; ongoing 19:22, 25 prImary 38:3; 42:24,25; only 21:22,27:7; 28:3; parallel 29:12 person's 71:2 34:12; 35:19; 36:23; 54:12, 55:9 62:13,19; 66.6; 69. 1; 73:6; part 5:17; 10:10; 25:10, personally 100-.1 37:24; 38.23; 40:5; 41:4, principal 15:4,14; 69:12 74.8; 75:25; 94:22; 95:19; 10; 29.9; 35:1; 37:3; 51:22; personnel 86:14, 14; 20; 42:12, 12,13; 43:1 1, 65:20, 70:18, 21;71:7; prior 7:16,23; 8:1,4,5; 15:16; 119:7 92,3; 105:17; 111: 16; 15; 44:17, 23, 24; 45:5, 6, 80-8,16, 19; 116:25; 16,18,22,25; 46:19, 20.

15:7; 19:2; 21:13; 26:9; Ooltewah 4:10 112: 13, 13 52:9, 10; 58:10; 69.24, 25, open 41:2 117:18 perspective 21:7; 67:4; 21, 21, 23, 25; 47:1, 2,4,7, 81:12, 14;83:13, 22; 98:5, participate 29:17 12; 49: 11; 50.3; 56:12, 18; operating 36:25; 112.8 88:1 18; 101:13; 112.22 participated 14:15 57:6; 58:10,25; 59:11, 14, operation 12:10 perspectives 88:15 16, 22; 60:2, 19, 20; 61:10, Privy 68:5 Operations 5:11;8:11; participation 68:11,20; pertain 79:3 probably 16:12; 22:7,12 11, 12,21, 21; 62:7; 63:15; 35:10 100:25 PG-7 13:13; 14:2; 109:5,7 64:5,20,21; 69:7; 70:19; 42:23; 49:8; 51:4; 54:23; operator 5:13 particular 18:16;23.15; 71.6; 72:23, 25; 78:15, 22, 74:19,20; 85:6; 90.19 25:12; 38:23; 39:1, 9; PG-8 12:22,23; 13:13; opportunity 41:3; 42:5; 14:1,9,18; 109.7 24; 80.20; 81:25; 83:6,7; problem 36:1; 43:12; 44:12; 71:16; 72:25; 80:2, 84:23; 93:1 1, 13,21; 56:17,20; 77:7; 11 9.23 phased 40:5 96:5; 97:15 2; 81:25; 108:2 94:12; 98.6,8, 13; 99:13; opposed 42:1,4, 10; 55:8 phone 100:10 problems 19:15;90i,.13 particularly 38:1; 105:19 103.20,25; 10-4:5, 9; option 72:20,73:8 Pass 103:11 phrase 110:11I procedural 59:7 106.23; 107:9, 13, 17,20, options 39.24;41:6;44:5 physically 76:11 procedurally i past 19:1; 82:24; 119:14 22,25; 108:7; 109:6,6, 8, ordeal 81:22 pick 105:2 10; 110:9,14,15,21,25; procedure 46:2,,.

PD 14:6; 15:10; 16:20; order 53:17 piece 17:1 1; 20:17; 111:22; 112:2, 20, 20; 70:10; 117:6, 15 24:16; 56,9; 104:12; organization 5:17; 8:19; 108:25; 111:12 24:15; 25:1; 35:6;46:4; 114:3,10; 115:12; 116:18, procedures 45:3; 48:23 11:9,10; 13:8,14; 16:14; PD-a 22:24 56:1 0; 108:12 23; 117:4,8,11, 15,18, proceed 62:20; 68:8 19.3; 20:13; 35:12; 38:13; Place 18:3; 68:9; 73:5, 9; 25; 118:8, 9 proceeding 5o:16; PDs 13:25; 24:18; 56.8; 39.2, 11; 40:14; 44: 1; 82:16,23; 88:2, 89:19; posItions 10:13, 14; 84:19; 100:25 57:9; 112:5 49:20; 51:18,21; 52:24; 98:19 11:8; 13:4, 6,11, 13; 14:1, process 11:11; 52:7; 56:7; 59:19, 20; 85:1 1; peers 66:19,19; 103:23 16,18; 24:19; 35:3; 36:4, Plaintiff's 12:8; 13:22; 58:2 5; 59:6; 64:5; 65:7; 94: 1; 105:2 1; 112.7, 8,8, pen 24:3 14:19; 15:3; 16:6; 21:14; 23; 39:24; 40:9; 48:1, 2; 67:22; 68:9; 70:8, 22, 23; 9; 116:22 people 6:25; 11:15; 14:8; 22:23; 24:8,9; 25:22, 50:4; 51:3; 53:19,20,23, 71:14, 24; 72:5; 73:23;-

organizationally 35:5 16:17,18; 17:4,5,10, 14, 26:10,25; 27:2,5,22, 23; 54:3; 58:7, 13; 61:8, 76:9; 77:3; 79:16; 83:10; organizations 35:9; 17; 19:5,20; 20:5, 18; 28.7; 30:12,75:3; 79:3; 22,71:17; 72:2,7; 73:14; 85:9; 90:15; 91:9; 94:2, 44 21:4, 23; 36:17, 22; 37:22; 108:5, 5 74:4; 105:11,124 106:22; 97: 10; 98:19; 100:1, 2,16, 52:3 oriz -1ted 80:3 38 3,12; 40-12, 14, 19; plan 16:19;32:10, 10,12; 113:23; 115:3 23; 101:14; 112:25; 113:7, 4 1:5; 43:22, 23; 44:1, 3; 33:6,12; 34:10, 18, 20,24; Positive 95:25 17 original 33:16; 60:19 45:21; 47:25; 48:2; 55:18; 35:14; 36:19; 37:1,3; possible 68:25 processes 66:23 others 43:6; 55:8; 78:12; 59:19,24; 64:6; 86:5; 91:5, 50:25; 51:14, 15; 52.9,15; Post 58:13; 60:20; 62:2, 81:2 1; 82: 1; 83:2;.8:2 24; 93:19; 94: 10; 96:7; produced 77:2 74:23; 99:18; 111: 17 5,19; 83:7; 112.19 proficient 55:3 otherwise 83:21; 11:8; 100:22; 104:22; 105:2; 107:2; 108:17,20; 110:3; plans 30:21 posted 9:11, 12, 11:19; Program 10:18, 20, 21; 110:21 113:23; 114:2,7;11 :5, p la nt 5:13; 8:2,27:17,18; 23:8,10, 12; 41:2; 62:1 1; 11:9; 12:21;22:25; 27:13, out 13:9; 18:22; 19:8; 42:24,25; 55:10; 65:12, 63:15; 64:5; 106:24; 22:1; 24:15; 25:1, 21; 29.7, 11; 119:21, 22 18; 76:20; 80:22; 103:20, 17,101:13; 104:19; 107:6; 112:2 24; 111:21; 113:21; 114:2, 22; 31:6; 32:17,23; 33.7; per 56:2 119:16 posting 23:18; 58:25; 115:12 37:17; 38:9,22; 40:1, 5, percent 22:8, 13, 13; 23;41:13,20; 43:10, 15, 31:12,25; 32:20; 33:14, plant's 65:17 101:13; 111:20 programmatic 26:18 16; 44:18; 46:19,24; 47:2, 18;34:1, 4,8,18,23; plants 18:25; 19:1;21:5; potential 47:19; 50:2 5; programs 26:20 27:8,9; 36:8; 119:25 88:1;90:22, 101:12 15; 50:17; 52:23; 55:22; 35:15; 36:15; 52:1 1,19; proJect 37:1 58:8; 66.24; 69:15; 71:17; 53:8,15, 17; 60:14, 18; play 26:6 Power 5:10; 7:25 proper 48:23; 11-72:1, 12; 75:20;SO: 1,7, 61:24; 62:25; 104:6, 7, 20; playing 100:10 practical 13:9; 108:15 15,16; 83:1 1; 89:2; 92:25; proposal 32:24 106:22; 107:3; 113:4 please 4.7; 21:20 practice 106:3 96.20; 97:8; 98:7; 99:16; percentage 22.3; 31:24; proposed 32:10; plus 15:24 practices 105:25 protection 12:10; 26:19; 101:17,22; 102:12,25; 34:3; 59:1 0; 60:18; 107:4 point 52:2; 59:6; 75:18; pre 98:10 103:19 110:3; 111:3,7 perform 16:7; 109:9 82:19,20; 90:10; 99.2, preface 37:20 provide 26:17; 57:21, 24 outside 83:8; 118:1,1I performance 70:17; 111:24 preferred 49:19; 50:1 pulled 82.10 over 6:22; 16:11, 20; 71:2,9; 74:14,22; 75:4, pointed 79:10 reprainn 7:14 purpose 57:16; 110:15

- -- - -. '.'- - - 7 A. AZ QL+/- V. Ronald O. Grovel Tennessee Valley Authority - , . , '4 January 29, 199E purposes 61:24 111:22; 113:25; 114:14 35:10, 108:20 21; 57:1 5, 16; 58:6,6,22; selecting 115:2,5 pursue 43:15; 50:5; received 89.1; 94:23; reports 8:23; 11:25; 13:1 -59.2; 60.7; 64:8; 65:3; selection 10:10; 14.7,16, 62:19;69:2; 90:2 1; 102.1 8 115:17 69:9;70:3, 13; 71:18; 64:i0, 14,17,17; 65:1; repost 40:19; 61:7 push 91:1 recent 70.17,'20; 71:2,9 72:14; 73:18,19,19; 66:11,23;67:1,9, 22; reposted 40:10 jput 7:7; 9:13; 11:14; recently 5 :9, 74:12, 15; 75:23; 77:7, 23, 68:9,21,21; 69:18,70:8, reposting 60.3 ~24, 25;78:B, 10,80:18; 19:16,23; 25:8; 32:23; recess 30:17; 70:6; 11, 12,16, 23;71:8, 16, 34:17; 56:13; 58:5;76:7, representation 66:16; 83:1; 84:8,8, 21,24; 85:9; 102:22 67:3 86:24; 87:7; 88:18; 99:19; 24; 72:4; 73:23; 76:9; 77:3; 11;85:18; 88:21; 100:19 79:16; 83:20; 8.4:4; 85:8; recognizIng 119:13 representative 6:23; 103:10; 104:4; 105:9; putting 77:11; 117:18 98,6,18; 100: 1,2,16; recollection 34:2; 76:12 48:14; 65:13, 16; 66:10; 107:15, 24; 108:4,6,22; puzzling 96:9 110.24; 111:1 6; 112:14, 101:14; 113:22; 114:17, record 4:8; 9.20; 28:19; 115:23; 116:5 21,25 PW 114:4 29:41;30:15; 95:1 request 4 1:19; 48.8, 19, 17; 113:13; 115:4,16; PWR 22:25; 23:2; 24:22; 19,20,78:13 117:6,12,23; 118:23 send 51:14 25:7,8, 10,23; 26:2; 27:5, rectified 107:19 senior 5:6,16; 26:1; requested 29:3 risk 11:14;25:13 9, 17, 23; 28:5; 30:9, 54:2, redefined 40:9 93:24,25; 103:19,109:13, requesting 48:16,20 Rogers 65:14,21; 8.4:2; 8,13,17,18,21,25; redid 60:13 114:18 22 55:14,19; 56:1;71:18; reduce 31:11; 34:3, 22; require 112.2 seniority 60:4,8; 62:3; 72:2; 74:6; 1 11:21; required 37:12; 51:2; rolled 26:21 36,14,25; 53:19,59.20,23 rollover 60:5 63:1 113:21; 115:12 'reduced 32:7;46:17 53:14; 60:19; 62:2; 106:24; 107:5 Ron 96:16; 101:21; 112:4 sense 25:2; 39:8; 57:14; PWRs 25:9, 27:13 reducing 59:4 58:7 requirement 63:17 RONALD 4:1,9, 22 reduction 31:5,5; 33:14; room 36:6,24 sent 86:12 requirements 15:13; Q 34:1; 35:17; 36:22; 38:2; 51:1,2; 52:1 1; 53:8, 15, 18 19:9 Roughly 31:25 sentiment 62:14; 63:8, 14,16; 11 1:20 requires 70:19; 78:16,24 routine 47:23 QAQC 109:25 reductions 34:19,20 sentiments 62:23; 85:13; reschedule 68:1 run 49:9 quarter 74:20 redundant 58:1 102:9,17; 113:2 reerigineerlng 29:16 - researching 6:17 quarterly 74:18 separate 8:18; 14:2 resolved 14:12,14 quote 92:2 reference 27:9, 10, 17 September 87:2,4 referenced 27:14 resource 45:21;72:9; 105:23,25; 106:3; 110:5 sequence 86:18 referring 9:3; 14:9; SArTH 120:5' R 17:20,64:17; 76:4; 91:16; resources 6:16; 16:22; salary 47:9 Sequoyah 5:13; 27:9; 37:6,11, 14; 41:14, 15,20; 57:8; 105:18,112:12,19 103:18 Sam 8:24; 14:20; 42:19, 43:16; 44:18; 45:6; 46:22; Rad 56:10; 65:10,11; respective 38:19 47:20,65:10; 69:7; 101:13 reflected 13:22; 14-.18; 22,22, 22;43:7, 7; 44:20,

%114:9 15:5; 16:8 respectively 54:8 23, 24; 47:20; 49:4, 15,19; served 8:4;71:22;75:25; K..)AadChem 35:8; 39:6; regarding 37:15 responded 49:14 50:1,2,14,17; 69:6; 76:1; 76:1,3 41:14; 51:13, 16; 66:17; rehire 6o.20,20,21 response 10.9 98.7, 12;99:1,3,4; 100:1; service 70:20' 73:22 rejected 52:12 responsibIlities 26:11; 101:7, 12 services 12:10 radio 79:9, 11 27:21, 24; 28:6; 30:.8, 9, Sam's 42:1 1; 50:17 serving 67:8 relate 88:18 radioactive 80:13 10, 12 samne 11:3; 13:16; 15:22; related 101:15 session 99:5 radioanalytical 78:17, responsIbility 18:18; 16:23; 17:3; 21:1 2; 24:5; relation 88.9 19.3; 22:6; 106:13 25:4; 27:11, 16; 30.3; 35:8, set 20:20; 96:11 25; 79:3 relationship 43:5;69.24; responsible 58:19; 25; 40.4, 20,23; 43:5, 5; setting 94:4 radiological 79:23

-88:10,11 112:9 59:2 1;67:4,4, 6; 108:17, settled 81:24 rate 75:11 relationships 88:4 restate 117:10 25; 109:6, 6,20; 111:1I0, settlement 116:19; rather 38:1 1; 117:9 11;214:11, 12 117:1,19; 118:11 rely 105:23 result 71:23 rating 75:17 remain 24:19 set 16:5; 65:19; 67:1; several 19:19; 20:9; re 40:9 returned 5:9; 117:23 remained 73:17 115:19 5 1:21; 53:8; 56:25; 58:16; reached 117:1; 118:11I returning 116:20 saw 32:25 60:12; 81:21; 89:13 remaining 54:3 review 6:6; 7:10, 15; 56:6, reactor 23:3; 24:20, 23 remember 34:6;78:5; saying 52:4; 59:11, 17; shake 40:1 11 17; 57:10; 70:16, 20; reactors 24:22; 26:8 84:12; 85:5; 90.2; 100:9, 71:3,4,9,74:22; 75:16, 90:19; 92:3; 95:1- shakes 38:22 read 29:2,4; 79.17; 82:8, 11 19,76:13,16; 77:7; scenario 33:20 share 55:12; 92:19 10 reo rg 47:6 102:20, 10-4:4 schedule 68:2; 89:3 shared 55:21;92:17; realized 36:12 reorganization 11:1,2, reviewed 32:25 scheduled 5:12; 68:6 115:1 really 5:8, 15; 20:24; 4; 16:3; 17:21; 20:7; 30.20, reviewing 112:6 scheduling 66:24; 68:11i, Sharon 4:15 51:10; 55:7; 82:17; 22; 31:4,7; 37:25; 39.1 3; reviews 74:18 21 shelf 82:10 105:22; 107:20; 109.25; 58:15;99:9- revised 16:9 scorer72:2 shift 19:21 116:18 reorganIze 59:12 se 56:2 shooting 104:15 rewrite 11:12 reason 19:12; 67:17,23; reorganizing 105:11 Seaford 8:3 short 32:5 94:24; 95:4, 11;97:7, 16; rewriting 29:15-reoriented 99:8 rewrItten 11:13; 106:23 search 118:5 short-term 32:1 107:24--

repeat 28:25;78:21; rewrote 62:5 second 39:22; 41:13; shoritly 20:.7; 41:12; reasoning 55:12,23 102:7 84:6 96:24

-tasons 66:22 Rich 41:15; 50:13 replaced 6:22 - secondary 26:2; 27:14 shouldn't 107:16 call 7:11, 12; 9:8; Rick 65:13; 84:2; 114:17 report 94:18 secret 42:8 side 54:12,25; 55:5, 18, z4:11, 11,20; 18:17; right 5:8; 9:4; 10:12; 23:21;31:1, 11;33:23; reported 9.1; 10:3; 13:6; 12:24; 13:15, 24; 15:20; seems 57:25 19; 110:1

- 36:19;65:9;76:15, 17; - 87:2, 3; 94:13,15 22:14; 24:24; 26:15; 27:4; select 72:15 sign 7:8, 10; 76:16 77:1 1; 84:7.9; 101:20. 25; reporter 29:4 29:19; 35:16,19,23; selected 14:14; 16:4; signature 75:7,7 102:6; 105:14; 106:24;, reporting 5:18, 20; 36:1 8; 44:25; 45:4; 52:15, 98:17 significant 36:1;60:15, Hall & Associates (423)267-4328 Min-U-Scrilote Hall&Asocites(423267328CD0OOSO1 (7) rvurp~oses, - sienificalt.

Ronald C0. Grove.

in me matter of Gary L Fiser v. January 29, 1991 Tennessee Valley Authority specific 18:16; 27:17; stuff 58.8 targeted 79.20 totally 61 4 16; 69:19 Toward 18:4;55:' 1 subJect 79.9,11 task 17:18; 19:22 significantly 61:23; 62:1, 29.16; 61:15; 74:1;79:25; 180:5; 20; 80:4 4 109.14; 110.6,8 113:20 tasks 15:14; 17:9,14; 54:1; 77:11; submit 33:12; 5 7:9,77:12 22:9,109.15; 110:2 traffic 18:23; IC +

signing 7:12 specifically submittal 33:16 ,23 team 34:16, 16 training 5:13;3. :1 similar 101:24; 105:13; 78:5 13; 79.8,8,11,17.

20; 80:12; 91:8 submitted 50:2 5;56:14, technical 9:19; 26:1,17; transfer 44:20,23,24; 108 8,9 46:2,3;47:19;48:11; specifics 25:18;41:25 23 58:3; 65:14,23,24; similarly 80:10 50.25; 101:12 sit 14:7; 36:12; 112:4; specified 27:8 subsequent 32 .:23; 46:5; 109:13,22 51:12 tedious 25:14 transferred 37:5,8,10, 114:21 specify 27:8 47:15; telling 101:20 14;41:20;45:5; s te 38:22; 46:2,3,4, 5; speculation 66:13 substantially 108:10; 48:1;49:22;69.6 48:1,2,7,15; 49:2,4,7, speed 16:24 112:1 temporary 5:9 sufficient 107:! transferring 50:17; 16,22, 50.17; 55:25; 56:2 spend 47:13; 104:16 ten 102:20 101:17 sites 19:4,16; 24:24; spent 47:8,9; 103:25 suggested 78:l Tennessee 4:10 suggestions7 7:21 transition 16:13;111:17; 26:1,20; 38:15,15,19; split 25:6; 29:7 term 32:5; 60:6 suggriesin 717:9 113:18 42:13; 53:2; 56:1 split 25:61 23: testified 103:22; 114:16; 5:8 spoke 6:11,23 summarke 11 transitional sitting 6:3; 106:16; 116:6 117:13 spots 15:2;43:14 summer 16:4 transitioning 59:3 8:2C testify 116:1 118:13 situation 38.6,20; 40:4; staff 7:12; 30.24,25; supervise transpire 31:2,5; 32:3; 33:21;38:2 supervisor 74: :13 testimony 21:16;28:10; transpired 10.8;73:1; 44:12 44:22; 52:10,78:1; six 9:9;20:9,22; 51:24, stage 24:2 supervisor's 715:7 82:5; 89:18;96:15; 98:25; 106:25; 111:22; 112:22; 25;79:24 stand 38:24,25 support 21:5; 35:10; 100:13 118:15 skills 75:12 standing 94:5 36:9; 37:11; 38. 14;39:16; travel 36:8 themselves 28:11 slot 9:1,6; 10:17; 45:11, standpoint 7:13; 13:10; 42:16; 43:5.8,1 8; 49:15; tried 29:6,8; 35:6; 43:22, 50:16; 65:15,23 24 3, Thereupon 12:3; 22:18; 44:3,4; 67:2; 89:2; 91:7; 12 15:12;34:13; 46:18; 29.3; 30:17; 63:2; 70:6; slots 40:18 54:15.24; 56:3; 57:8, 18; support-wise 55:24 102:7; 113:13,16,17 74:22;76:20; 102:22 59.7, 65:17; 66:6; 81:8; supported 42. 24; 46:1 Trlsh 44:2 small 24:3; 103:25 they'll 58:5 smaller 16:21 88:7; 98:13; 99:25; supporting 381:14;49:10; they're 25:20; 26:12; true 11:22,24 Smith 44:2 111.15,16 1081516; 99:11 27:16; 38:24; 42:25,25; try 20:22,25; 32:17; start 18:10; 28:22; 48:19 supportive 49 9:13 48:10;66:18;79:13; 43:23; 46:22; 50:8;'

somebody 100:16 88:13; 111:17; 11' started17:6,6,7,11; supposed 28: 16,21; 97:11; 100:15; 107:5; someone 75:11;95:10 trying 10:14; 14 48:13;60:1;70 :16; 108:11; 112:12 something 34:5,8; 111:3 ):12,13; 43:10;46:10;52:. _;

starting 5:14;31:20 1i6 107:11,12; they've 17:1; 59:22; 37:19;849:2; 52:1; 57:19; 100:15; 119:16,18,19 60:25; 76:10;91:1,12, 67.20; 82:8.89:23; 90.3,4, starts 107:20 sure 19.9; 21:1:; 26:23; 100:8,104:24; 108:3; 6,8,15; 96:3, 17; 98.20; thinking 48:5,7; 85:8; 111:2,5; 112:15 state 4:7; 5:8; 28:23; 30.6; 32:4; 37:0 6; 47:17; 90:20; 117:5,13 101:3; 111:2,6; 114.21; Turn 15:3;30:19;,75:5 118:25 94:22 48:12; 50:20,2 2; 52:2; third 65:16 stated 50:7; 55:16.20, 57:11,14; 58:1 4,20,22; TVA 5:5; 7:18; 8:14; 10:4; sometime 89:17 though 31:19; 44:14 37:22, 44:16; 84:19; 100:12; 115:21; 63:21;66:9;73 :16;78:15; 24:21,23; sometimes 66:22; 3:24; 94:2,6; thought 83:7; 87:24,25; 70:1,2,12; 73:17,17; 101:21 119:5 84:22; 92:6; 93 91:4; 97:17; 99:25 81:12; 86:25; 88:20; 90:5; somewhat 6:14; 25:6 statement 7:2 4; 15:19; 112:3 three 4:19; 6:25:13:10; 106:3; 110:5; 116:7,21; 25:24;26:22,24; 27:1; suspect 90:2 somewhere 74:21; 85:12 29:8; 101:2 sworn 4:3 15:5; 24:23; 31:21,22; 118:19 statements 6:6, 9; 87:16, system 26:6 40:18,1B; 51:2,25; 53:20; TVA's 30:21;45 2 sons 4:19 59.21;80:14, 19; 91:4 soon 68:25 18;88:19 systern-wiso 25:9 TVAN 26:1,19; 109:22 thwarted 20:3,24 two 4:19; 8:3,25; 11:7; sooner 33:9 status 5:16; 95:16; 97:14 tied 117:2,2 13:1,11,25; 15:5; 16:12, Sorrell 14:24,25; 15:1; stay 34:21; 47:1; 59:21; DJ 104:22 title 93:11,13 19:16; 20:4,5; 24:13, 18, 20:8- 108:21,22,23,24; stayed 25:4; 35:18; 47:14 table 16:2 today 5:23 19,21,21,24; 25:25,25; 109:18 26:7,17,24; 27:1;28:1,4; sorry 6:2,5,18,21; stays 27:11 tab te 1: together 34:18; 51:16;

15 56:13; 76:7,11;77:11; 29.7; 45:15; 46:12; 51:3; 12:14; 14:25 steam 25:9; 26:5,8 tabulated 71:

89:21; 119:14,19 53:20;54:3; 55:18; 56:1; sort 33:1 1; 36:10; 48:23; t 58:9 tackle 21:2 59:23; 72:7; 73:14; 74:3,8; tag told 25:18; 40:6; 42:9; 67:6;71:6;76:17; 83:8, 11; stepsl8::10 117:24 49:1,5; 81:20,88:5; 89:5, 76:2 85:9; 8.8:11I. 16; 89:22; tp17:4ag0:0 5:;45:21; two-page 22:22;76:25 still 16:22; 39:Z845:6, talk 5:23; 39:2 11, 12; 90:20; 91:7, 8; 90:7292:8; 108.3; 117:1; 2; 87:13; 92:3,8; 98:25; 99:6,19; tying 111:18; 116:18 119.25 22,46:20,25: 47:4, 16; 73:1 1; 82:1, 13, 23;94:3, 74:3, 6, 8; 84:22; 92:124 88.8, 13; 93:2 2 100:22,24; 108:19, type 5:13; 20:14; 24:3; source 91:23 116:10; 117:17; 118:11 BS14100:15,21, souce 22; 101:5;. 4; 99:16; 107: 43:5,5; 47:23; 85:23; 90:6; sources 88:14 111:10, 11; 113:17 talked 6:13;' 42:19- 48:13, Tom 31:2; 33:1,2;48:25; 109:17 span 31:15 stock 100:19 25; 49:5; 63:1 o0, 10; 69:4; 50:15; 51:11; 52:3; 58:17; types 104:1; 10!

stood 65:15 8.;8:9 :1, 23;88:2; speak 28:11 61:2; 62:16; 63:24; 65:6; typewritten 79:-

specialist 54:2,3; 69:13; 91:4; 94:9, ICi; 100:7; 115:7 74:4; 105:24: 106:9; stop 28:21,22; 118:12 101:11,12 typo 24:4 took 7:6; 20:8; 25:1; 30.7 111:21 straight 10:14:40:6,7 talking 18:1 1; 20:22; 7;37:24;73:4,9; 77:4 specialists 16:17, 18; strictly 91:2 22 8, 15; 39:1lo; 41:17; topic 70:9 U 33:17; 55:17; 67:20,25;71 .16; 95:14; 17-1,2; 20:12;21:11: 22.5; structured total 13:3,5; 52:4 54:555:13,20:105:19 75:18 101:6; 105:8, ,18 U.S 8:8 totaled 71:15 specialty 54:7,7 student 8:6 talks 88:7

- - Ronald 0. Grove w f suit_LUr ot "(jary L. Fiser v. JalUaIY 29, 199k TTemneSSee Valley Authority 88.10,99.10; 106:10,14, Uftims ite 62.21,63:25 102:14,15 warned 25:14 S8;109:13,18,22 ultim* stely 9.6 10:2,7; workload 19.13; 56:2 61:6; 1.12:18; 115:3 Waste 56:10; 114:9 workplace 85:15 indei r16:2; 21:13; 26.7; _ water 23:3; 24.20,21,23; works 44:15;97:10 33:20; 35:10;53:13;80.2; 26:8 -

Watts 27:9,65:12;66:9, writing 98:11,15 109.8; 111:12 written 7:7; 13:12; 24:16; unde rgo 5:12 18 27113:4 unde rstandings 105:17 way 30.7;45:25;46:16, 21;47:12; 5O.16; 58.22; 21o113:4 unde rstood 9.15; 47:18; wrong 43:9186:20; 108:1 1113:6 59.2,25; 61:5,6,7; 63:19, 22,25; 66:18;75:1B;2; 110t2:218 unde *rwent 11:1 91:12; 100.21,24; 101:22; wrt 21 uc 25-22;27:5 uniql ue ., . 102:10,15; 107:11,12; unit;24:21 112:11,14,17; 113:4 T units 24:21 ways 15:6; 45:15;46:12 ----------

weak75:11 Yeah 6.21; 14:25; 23:2; unle ss 69.23; 100:16; 30.4; 31:20 48:6; 51:10; 101:' 3;111.1 weaknesses 80:23 week 96:14  ;

up6 :12; 16.24: 17:220 63:16:67:10, 17; 68:,16, 33:1 1; 37:20,38.25; 40.6; wei  : 6;71:1:74:2;76:2; 78:3; 52:1 4; 59.6.17; 67:18 82:13, 22,22; 84:17; 85:3; 68.7 ;70.23; 72:21;7 :1 6; Welch 6:13, 15,23;7:4 87:3,93: i6.6; 100.7; 81:3 :;82:9.11;84:5; 90:13; welcome 43:13 105:6,114:4,4; 119:12, 94:3 ,,4;96.11,20;q9:1,4, weren't 40:14 12,12 7;1( 31:19; 104:25; 105:2; -what's 18:22;38:22, 39.7,15:95:15:96:16; year l7:19,20,24;31:13, 115 :6;118:20,119.7,8 97:13; 107:21; 110.20 14,18,21,21;32:21; upc;orning 46:9 33:14, 18,25;34:4,8, 22; UpC on 45:9 wheneve 25 46:59,;

7:2535:22,24; 41:22; whenver UpC 85:2 whereas 26:7 52:12,20; 53:.6,8,9,15;

et 74

17 urGlency 68.8 whistle 83:14 whole 16:10,26:6;38:8; years 8:1,4,5; 16:12,12; e 11:15; 23:12;61:24; 19:1;31-17,22, Z2;46:5; 105R.24; 110:11 58.19; 95:21; 113:7 wife's 4:14 19:20 USI ed 18:24; 23:18; 80.23 willing 45:25 York7:25 er's 29:17 us ually 96:22 Wilson 10.3 48:9; 51:20, Z

58:17; 65:6, i9; 67:11,20; V 68:18;69:1;73:2,76:13, 17; 77:24; 81:20; 83:1,2, 2; 85:10,113:14;114:25; zip 4:10 23 li6:11 vaicancy34:13;41:21, VEicent 9:1; 10:16;45:15; winner 71:17;72:6; 98:18 465:21;47:5;116:18; within 11:3;35:12 1117:4,11 without 39:18 VIacate 11:16 witness 4:2; 9:18,23; V:clue 102:8 28:20,24;29:5; 101:19; V. narable 36:14 103:1;; 115:12; 118:20 V arious 17:3,14;66:22 wonder 42:15 Versa 15:21 word 23:12;29:11,11, V,ersed 106:2,5 14,14,25,25;38:11; V'erslon 23:16,17,24,25 80:11 rersus 27:18 words 11:15; 16:15; 18.23; 30.3; 54:6; 55:6; rice 15:21 99:11,17; 109.12 4lew8f 2:20 wordy 57:17,22 viewpolnts 67:5 work 16:15;20:14;32:17, voiced 62:13: 84:1 8 j17,37:12;38:15; 43:23; Volar 98:21; 99:1,5,16, 44:4, 16;48:22; 54:14; 58:18,21; 59.7; 60:1; 19,101:7 volunteer 81:1 66:24,69:24;72:11;82:4; vying 14:11;46:19 87:1; 8S:2; 105:3; 107:12; 112:11; 116:21 worked 13:9;40:23;44:1, CDO00603 2" 3,51:15,20; 54:11; 69.1 1.

19, 83:3, 10, 89.21; 91:25; walt 33:8 105:20;119:14,19,23,25 waiting 48:10 - working 21:13; 29:9; (_o1r .-

wants 38:23:72:7;888; 37:11;61:24:62:17; Hall 8c Assoclates (423)267-4g28

Lawyer's Notes CD000804

• . . S 0 P0 NO.

POSITION CESbIPTIOH I; .E _ T, r~tpr Social Security Number_

Fositioi Title CHFMISTRY ANO ENVtRONXMNTAL Pay Group or Schedule/Grade PG - n I PROTECTZON SENIOR PROGRAM MANAGER Location Ch a ttanooa Organization Titles:

Group TVAN Operations Fuelgar operations greratfcns Strvies -

Oeparnment Chemistry and Environmental protctiofi - Reports to I.

Section (Title) Maacer. Chemistry and tnvironmental s

0PrM-opcI.;

w v % v X . _

n Ore Cede Suearvi aorv

- - .. nan fl Approved Jet LCodUA: Function Cods: L21- I Schedule/Pay Grade: PG-8 - .

ECSR REVIEWER

.POSITION EVALUATION: EVALUATION DATE: 9/21/94 INITIALS: IVAN1/JEC FT3 . 350 E3 (38) 132 E1P 132 614 56-22-22 a K-K Slot K-K P tS P-S Slot P-S *ts Acct Slot Acot Pts Total PFs Profile

,TTON FUZFOSE:

Provide senior technical direction, support, and oversight to the TVAN chemistry and environmental protection programs. The incumbent series as the primary liaison between the sites and TVAR corporate. The Incumbent Manages the implementation of dir ctives, standards, ,^d pol:'es and rtsulations.at all TYAN sites. The incumbent is the lead individual for ensuring that hlmn statn'isrds are set and maintained at both corporate and the sites. His/her efforts art focused on establishing/anintaining a chemistry and environmental program that enhances the safe and reliable operation of TVAH sites.-

OTHEHSTONS:

?lhnageuEent./rotehsional/Tech~nical- C - -, - -

Claricil/lTchnical Support " - - -

TOTA:- 0 Budget:

Operating - a Payroll - O TOTAL . 0

/ O stribution: Original - fuman Resources Hicrorecords Unit, Knoxville CDQCOS05

- -- ----- CoFY.-.Opcrations Organization 1 (a: needed)

Copy - Central Offi c of Union Ha rinduris-Copy - E-ployet - I-- - -

< IZA (CLED-CLA 7-g1) C7 Sl) Page I oa'Z

&147u Exhibit 5

1A~ Garyr L. riser EFFECTIVE CATE pl~g 3RYNC'TPAL ACOIM.Z.

1. pro-vde trChnical and yro anvatic expertise for Implimentation of the TVAN chtaistrY Ind environmental protection programs at individual sites. Provide direction as needed for project manageri managing projects at his/her assigned sit#. Oversee the activi ties of other personnel a~ssigned support functions for meeting the responsibilities of this bostition.

2. Assist yut, mamage-memt with Interporetation of ch";iutrY and-enviromnemetal volicy; review' and concur with site procedures a~nd other TYAJ( docum~ents that way Impact. the programs. Proote optmum~ consistency among site pro gram&s.

3. Receinnend chems'itr-vamd enviro~nemetal protection goalt and specifications that are consistent with bist industry practices1 and assist with the irpitinentation of actions to achieve them. Oirect the performance of site evaluationx of the chemistry and environmental protection programs to ensure consistency and comnpliance with established requirements.

A. Direct review and concur with root cause analyme for identified che mistry and environmental protection program problems, direct the development of corrective action plans. and coordinate the implementation of approved corrective actions.

S. DIfrect the oerfar".irie of repijlatory and licegming review? of chemistry and environmental issues. recotnmend TYAN responses or posi tionis, and concur wi th responses to external orjanizlationis..

6. Direct the develocnent of chemistry and emvi'ron-ental protection traiingn and qualification criteria.

-Conduct specialited seminars on chemistry and tnvironmental protact~ion technical topics as requested.

7. Provide lono-term/larce scope 2rolect tupoort to the plant sites for major chemistry and environumental projects. Provide short-term plant problem response to the sites as requested.

8. Perform leng-tern data trending and assessment of key chemistry and environmental protection data. Provide appropriate feedback and corrective action proposals as necessary. Prepare an Annual Chemistryazid Environmental Protection Report; review for concurrence with site staffs and issue.

9. 'Functlom as a primary TVA revriemetative to the £PRI PvR Primary Water Chtmistry Cosmittee. EPRI/SGOG Chemistry CormitLte and EPRI BWR Owniers Group Chemistry Committee and the appropriate environmental protection comi ttsts. Coordinate the release of chemistry and environmental data to outside organizations as authorized.

0. Serve at a chemisti-v and envirormnental orotictlon TpeC11141t or alternate dose assessor, or environmental assessor, in the event of a radiological emergency. Rtmain 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.

1. Actively emczace in veeklv plant tourl, personnel Interviews. observation feedback and working meetings during routine operations and plant outages. Coordinate with sites the preparation for 1HP0 evaluations and hsponses.

2. Fumetlem at team leader and orovi'de technn~ial expertlie In support of the Quarterly Chemistry and Environmental Protection Tea.-a assessments for IVAN sites.

3. Chair 'working grouyps such as radicanalytical working group. and analytical working group. the radiological assessment review cormittee.

4. Develo2 research and develocmemt rofoecte tssuij and act as technical coordinator. Compile data and research positions that support requests for systems specificatle-i changes and engineering design changes.

CDOOCSC6

-- 10/17/94

AM SSW F-CVE DATL.

• *4. CFirst) (Mdle) (Last) s a senior technical advisor and assist In carrying out sitt s;.cific environmental Ptnnitting tasks Jchas FOES. HEPA. underground storage Lanks. asbestos, 404 Permits. landfill/disposal mixed waste.

-__ uterial storage. storm water.

2. provide direction in the Smplerentation of site hazardous caterials control plans, the proper handling and shipping of hazardous wasta. mixed waste and solid waste.

3. Function as the TVAN senior technical expert to the stias In the areas of Chenical Traffic Control plans.

bulk chemical control. handling of spills. PR and FWR operational chemistry control. laboratory QA/QC.

radioactive effluents, de.minerlization, post-accident sampling requirtments. and failtd.fu51 action plans..

4. Cevelop and interpret dttailed data trending in the areas of primary and secondary chemistry for both EWR's and PWR's auxiliary and makeup sys-tes chemistry, radioactive effluents, site *environmental discharges.

Provide specific feedback for improvtrent on a routine basis.

S. hake rtcormendations to TYAH sites an resin type for usage In all plant applications. Assist the site in the development of resin specifications and analysis.

6. Understand the purpes.e and provide direction to TVYX site staffs in the Irpleentation of such programs as ETA/loric Acid1/olar n tio control, secondary MdR Chemistry Control IGSCC. mitigation. RW: and Zinc injection programs for SVR's, zibra mussel/clan control In service water systems.

7. Function as the sinior technical expert and provide direction to the WYAS sites-in all aspects of PFR steam generator chemistry/corrosion ccntrol which include hideout return evaluations, sludge lancing, chemical clvaningand corrosion product transport minimization.

8. Function as the senior technical expert and provide diretion to the WAR sites in the areas of OOCi and radiological effluents ranagement. Coordinate all regulatory updates.

HTHTKUM OUALIFTC.ATTOHS:

nager should have a bachalors degree or the equivalent in chemistry, environmental sciences, or chemical tring. including formal training and euperimnce in management. The manager shall havi at least eight years

!essional exptrienet In applied chemistry or environmental protection, with experience at an operating 1 plant preferable.

r The ranager should have detailed 1nwoledge of modern analytical and radioanalytical

__4"ment and rethods used for performing all required checistry and environmental analyses at TYAN sites which includes equipment operation and capabilities.; He/she must possess a very good knowledge bast in An the areas of environiental regulations, FWR and EWR chemistry control guidelines and permitting requirements. advanced degree and tin years exptritnct at the professional or rmangerial l evl are desirable.

TVA IZA (C&ED-CPLA 7-91) U7-91J Page 3 of 3.....0058G. a'191, 7/11194 CDOCOSr7

7 _. , .

PD NO. 960383 POSITION DESCRIPTION Name Social Se-unty Number /

Chemistry Program Manager Poshion Tite (PWRI Pay Group or Schedule/Grade _ _

Location Chat4anoooaa Effectrve Date Organization Titles: _ .

Incumberirs Group TVA Nudear Sionature -

Superisor's Operations Nuclear Ooerations Signature . _ .

HRM/HRO's Division ODerations Sucoort Signature Corporate Radiological Control Reports to Corporate Radiological Control and Department and Chemistrv Or~I.) Chemistrv Manacer Secbion -

FOR COMPENSATION PLANNING AND ANAL YSIS USE ONLY CP&A REVIEWER POSION EVALUATION: EVALUATION DATE: 711619& INITIALS: JEC

,13 350 E3 (38) 132 E1P 132 614 5-22-22 =

K-H Slot K-H Pts P-S Slot P-S Pts Ac: Slot Acct Pts Total Pts Profile Profile Approved Job

Title:

PROGRAM MANAGER Schedule/Pay Grade: PG-Os Organization Code: Job Code 2581 SupeMisory Code: N Function Code: L20 POSMON PURPOSE:

Provide senior technical direction, expert support, ovirsight, and Progra-mProject management in the chemistry programs of the WVA.N facilibes. Develop programmatic requirements for chemistry management programs. The incumbent serves as the primary liaison between the TVAN sntes and TVAN corporate. The incumbent manages the implementaton of directves, standards, and polides and regulations at all TVAN sits. The incuimbent Es the lead individual for ensuring that high standards are set and maintained a. both corporate and the TVAN sites. His/her efforts are fc used on estabrishing/maintaining a chemistry program tha:

enhances the safe and rcliable operation of TVAN sites.

DIMENSIONS:

Typical size of projects - SIOM- S1OMM. Annual projects managed -10 Other:

Incumbent acts as Manager, Radiological Control and Chemistry, in his absence with the signature authority and control of the budget (S3MM) associated with that position.

2. Serves as Technical Cnstrac! Manager estabrishing. controlling, and maintaining mu-site chemistry services and material contracts. (Matenial and Serices Annual Budget S10MM)

3. Serves as Radiological Assessment Manager in the event of a nuclear site emergency.

Distribution: Original - Human Resources Microrecords Unit Knoxrte CD0008C8 Copy - Operations OrganaiaUon (as needed Copy - Central Offce of Union Having Jurisdiction Copy - Employee TVA 12A HR 7-911 Page 1 o?2 960383.doc

I PbST1T6c5I TITLE: Chernistry PrOOrMM Manacer (PWRI PD NO. - 950233 NAMt (iPt (as) SSN ________ _E;F=C7ilV= DATE _________

'FlINCIPAI. ACCOUNTABILITIES:

of Pesconsibitlities IN. WBN (PWR) Chemistry Program

,/=cndary Chemistry Program Suoport for WVAN pWRs

• Post accident sampling systems

• Cooling tower chemistry

• sot'ware control program

• Analytical Working Group Management for all TVAN sites

• Multi-Site Technical contract. Managemnent such as Ecclochem. Dionex. PASS services for all TVA.N sites I.' Provide technical and procrarmmatic exoertise for implementation of the TVAN chemistry program at individuakites. Provide direction as needed for p~roject iranagees managing projects at SON -and WBI,. Oversee the actrvties 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 TVAN senior technical expert and provide direction in the implementation of such programs sMolar Ratio Control. Secondary A. Assist Management Chemistry Optimization, and zinc injection.

with interpretation of chemistry policy - review and'concurvwith site procedures and other documents that may impact the programs. Promote optimum consistency amrong site programs.

S. Recommend chemistry program goals and specifications that are conssiten: with best industry practices, and assist with the implemnentation of actions to achieve them. Direct the performance of site evaluations of the chemistry -program to ensure consistency and compliance with established requirements, B. Dire-.; review and concur with root cause analyses for identified site chemnistry program problems, direct the development of corrective action plans. and coordinate the implementation of approved corrective actions.

7. Direct the perform.ance of regulatory and licensing reviews of chemistry issue~s. recommend WVAN responses or positions, and

• ,concurwith re-sponi sz to external organitzations.

S. Develop and conduict specialized seminars on chemistry technical topics as requested and conduct periodic training related observations/provide recommendations for improvements as necessary.

S.* Provide long-termflarge scope project support to VWEN and SON for major chemistry projects. Provide short-term plan, problem response to the sites as requested.

10. Perform long-term, data trending and assessment of key WSBN and SON Secondary chemistry date. Provide appropriate fete:back and corrective action proposals as necessary. Prepare an annual WBN and SO chemistry repr with review gric iecurrence vftth site s'taff s and issue.

iction as a WVAN representative to the EPRI PWR water chemistry committee. PWR Owners Group Chemistry Committee.

d appropriate industry and regulatory workshops/cortferenceslse rmnars. Coord'inate the release of chemistry data to outside

'\....~gaiztinsas authormzed

12. Serve as a Chemistry Specialist, does assessor, or RACIRAM In the evenit 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, peronnel intervierys, observation fetdback and working meetings during routine operations and plan', outages. Coordinate with sites lor INPO evaluations and responses.

14. Function as team leader and provide technical expertise In suppor, of the Quarterly Chemistry Team a1ssessentsi for TVAN sites.

.5. Chair Analytical Working Group for all W AN sites and ERMI.

16. Develop multi-site contract technical soerifications and act as'technical contract manager for applicable contracts Such

&S mnakeupowater, Dionex services, PASS servces, bulk chemnicals forallsites.-

.7. Act for the CorporalteRadiological Control Manager in hsther absence.~

.8. Provide eff ectrve commrunications of the Corporate Chemnisry program to the TVAnuclear sites.

MINIMUM QUALIFICA~TIONSt The Incumnbent should have a bachelors degree or the equivalent In chem.istry, environmental sciences, or chemnical engineering.

including formal training -and experience in management. The incumbenit shall have at least eight years of professional iexperience in applied chemnistry, with experience at at'. operating nuclear power plant preferable. The incumbent

,kniowledge of modern analytical and radioanalytical equipment and methods used for performing all requiredshould have af detailed chemnisry analyses It TVAN sites which includes equipmenit operation and capabilities. He/shie must pessess 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 assignmenlt k [MR 7-91tPage 2 of2 CDOOGS09 S,-~.Of

I . -

PERFORMANCE REVIEW AND DEVELOPMENT PLAN (FOR HMAAGERS AND SPECIALISTS)

(For COO & TYAN Use Only)

Namne GARY L. FISER Social Security Number A_ _ _ _ _ _ _ L-  :

Position Senior Chenistry & Environmlental S ecil.st Organisation Chemistry & Iromna Protection Review Period - 1.lIL24I...2.L__ to 9130/95 1 Date of Annual Performance Review PERFORMANCE RATINGS DEFINITIONS Exceeds Expectations Individual far exceeds expectations for this objective or expectation. frequently makes significant contributions well beyond job responsibilities.

leets Expectations 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.

HoMts Some Expectations Individual partially meets expectations for this objective or expectation. Improvement In this area Is necessary for the emanloeo to fully moet expectations. Performance does not Indicate successful conpletIon of all assigned r spon iilI *I.

Unacceptable Individual conslstontly below expectations and performance Is unacceptable for this objective or expectation. May require more supervision than expected. Improvement required to moet expectations.

REVIEW DISCUSS 1=RTELY IS 4thL _

tanager Law-b, 2nd t ---

a _ DtE iw1_

1hp-0 i, _lu/s :)/

0 I cu sod Date DIscus1oF 0

I-*

0 IVA ' EZ-95] 1 ..... 3028C

.K (

PEr- ICE 0( ES I

I- -

I PERFORMHWCE OBJECTIVES Establish specific results or goals that this PERFORMANCE SUHfARY Review perfornance againt each objective. W 4 z employee Is expected to achieve during this Discuss results *chieved, areas of success, E U rating period. (Additional pages may be used and Improvements needed. Cite examples I 'N as necessary). whhere appropriate below. Then mark (X) In the G X M A column on the right which best describes the Ii E C T employee's performance. T E C 0 S E T X S P A C T L E S A D 0 0 D M~ L J. - E E

1) Heet the expectations of the Corporate Chemistry Satisfactory results achieved. 15% X 45

& Environmental Protection (CLEP) FY95 Business

-Plan. Management Expectations and Goals as determined by the Corporate CLEP Task List.

2) Maintain focus on CUEP/TVAN Top Ton priorities Satisfactory results achieved. 15% X 45 list.

3) Support adherence to the FY95 budget requirements Satisfactory results achieved. 5% X 15 L continually look for effective ways to reduce costs.

4) Functlon as lead chemical engineer,In support of' Excellent effort: Gary played a key'role Inaissting the 5% X 20 WON site startup preparation. site staff In'addressing program deficlencles/solving problems In startup preparation.

5) VlsitTVAN sites-on a routine basis (consistent Excellent effort; Gary consistently exhibited a hilh level of 15% X 60 with REP responsibilities) and exhibit a high support for site activities. He was a key player Inhelping level of support for site activities. Site to address critical Issues at all sites.

badging to be accomplished as required.-

6) Pursue a high'level of technical capability by Satlisfictory results achieved. 5% x 15 personal development and attendance at appropriate conference/meeting.

7) Manage Implementation of multi-site raw water Satisfactory results achieved. x 15 contract. .

I0

8) Assist In development ofmonthly and annual The annual chemistry report was completed. Monthly reporting X 15 I chemistry report for WON and perform routine data has started, but Improvement Is still needed to get a reviews. complete report Issued by the site staff on a consistent basis.

b

.10.

h I iIA 3 11 9J Li-Y uJ L r e s ra c e s _ iu r . _ _ . or m ui m i wU ul rb _ U UI

]VA 4535 U-YJ) LZ-VbJ Z rerforinance Objectives - 10 Percent of lotal weight - - - - - -L UW I'I

PERFORMANCE BEHAVIORS BEHAVIORS PEREORKIANCE

SUMMARY

These behaviors come directly from TVA's workforce mission. Employee and supervisor jointly decide Review performanco against each behavior.

Discuss results achieved, areas of success, a

4 3 z which of these behaviors specifica1ly pply for and Improvements needed. Cite examples V the review period. Choose up to six behavi ors, where appropriate below. Then mark (X) In the E x H with no behavior receiving a weight of less than 5. column on the right which best describes the I E T employee's performance. G E 0 H E T T T X S A C E S L E E 0 E

0 T H S S E

1. High Performance Excellent effort; Gary has been very proactive In this area. X 20 Sets clear goals for self and others; Includes lie consistently takes the lead in finding solutions to the needs of customers in sitting these goals; problems to make projects/programs successful and assumes shows persistence and dependabli ty In accomplish- personal responsibility.

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 Excellent effort; Gary Is a superb team playor. lie Interacts 5% X 20 Shows a team orientation by placing team goals well with peers and site counterparts. He has worked well at over Individual goals; effectively communicates all sItes and has been Invaluable In keeping key programs information needed for task completion; contri- moving forward. He has often been asked to stop Into crIsis butes actively to group projects and meetings; situations and has always met the challenge.

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 chleve organizational goals; treats co-workers with dignity and respect; encourages and supports actions to eosure a representative demographic mIx in the workforce.

4. Innovation Excellent effort; Gary always looks for and pursues cost x 15 Develops original, cost effective. and resource- effective and efficient ways to complete tasks.

ful approaches to work situations! encourages and recognizes the Initiative and creativity of C) others; takes appropriate levels of action to t7 got the job done right.

0 0

• FA74535StV-93 F (2-95] 3 auWSI v

T-I I N( (

I.

H* BEHAVIORS PERFORHANC JORS PERFORHANCE

SUMMARY

EXPECTATIONS These behaviors come directly from TVA'stworkforce Review performance against each behavior. a -1.1 misslon. Employes and supervisor jointly decide Discuss results achieved. areas of success, U which of these behaviors specifically appl for and Improvements needed. Cite examples V N the review period. Choose up to six behaviors. where appropriate below. Then mark (X) In tho E X H A with no behavior receiving a weight of less than S. column on the right which best describes the I E C T employee's performance. G E C 0 If E T E T T x S P A C H T L E E S A E E O L 0 T E0

• 4- .4.4 .A S 4-*

r 8.

5.. Continuous Improvement Excellent effort; Gary always sticks with problems until X 20.

Determines customer expectations; identifies they are solved. He has the ability to work with site strengths and weaknesses In present work methods; counterparts In getting good solutions/fixes In place. Ho uses Quality problem-solving tools and techniques always strives to seek a win-win situation.

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 benchmark.

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 Implementatlon of development plans;-evaluates performance based on established expectations.

7. Leadership -

Consistently communicates a clear direction for the workgroup; galns 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.

Cormunication Satisfactory results achieved. 5% X 15

0) Sends and receives Information clearly, accu-rately. thoroughly, and effectively; verbal, 0 written, up, down, lateral, one-to-one, and 0 group comminication.

i, %

1- 5 oa iV 4535

'IVA ( - 3 [2-95) 4 5 5 (1-93) Total

PERFORMANCE BEHAVIORS BEHAVIORS PERFORHANCE SUWIARY 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 V N the review period. Chooso up to six behayors, where appropriate below. Then mark (X) In the E X H A with no behavior receiving a weight of less than 5. column an the right which best describes the I E C T employee's performance. G E C 0 E T E T T X S P A C M T L 0 T H L S S E IE I

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 FORUULA RATING Objectives Rating Total - 230 MEETS

_ . EXCEEDS MEETS SOME UNACCEPTABLE n.K. . _ ~ a__ t -l i nr Bhvor Inz nonting lotal - IUD Overall Rating Total - 335 Divided by 100 m 3.35 A2 Isxz1 3.12 Below TVA 4! )12-951 5

I Overb..

Strengths:

FiFLP14NTAt NEEDS (To he onmnleted by tinorvygnr with PM Inout.)

II.-

Abilltv to work effectivelv with titt nerstnnnl! total taun olavpr! excellmnt understandina of site ooeratlonal themlstrv. I Overall Continue supoort of the WON startuo effort: continue to focus on qettino a comolete WON monthly chemistry reeort Issued on j Dev. Needs:

routine basis: continue to-focus-on work planningi/timnely task compoletion.

CAPFFR Onn(TTVIq (fO - I vair)

Employee's stated Career Objectives: (Priority order)

(1)istry rental Proteton (3)

(2) (4)

IUDIVIDUAL DEVELOPMENT PLAN AREAS FOR DEVELOPMENT ACTION TARGET developed. Indicate areas of current performance address these development needs. COMPLETION COMPLETION which need-to-be-develcd with an asterisk M. (X Mo.)I_

Develop computer based skillu Attend MS Word Processing Trng TOO Items could not be Develop computer based skills Attend Lotus Freelance Trng TOO completed due to work Develop computer based skills Attend MS Excel I and II Trng TOO scheduling changes -

Develop computer based skills Attend MS Project I and II Too affected by the. loss of Develop computer bated skills Attend Harvard Graphics Trng TOD 2 group members this Develop computer based skills Attend MS Access Database Trng TOO review period.

Develop computer based skills Attend HS Power Point Trng TOO I

'i-..IVA 4535 (1-93) t2-95] 6

. "i..

a Se.

OVERALL

SUMMARY

OF PERfORHANCE:

Gary's overall Rrfrnmance continues to be very good, His aairessive aooroach toward his 1ob has been evident In the chemistry Program turnaround at both WON and SON, He has worked Yery well with all site staffs and IsYery dependable In the folloiwu of Items they request of him. tits Indeoth knowledoe and understanding of site operational chemistry has proven to be a key attrlbute for our staff In assisting the sites.

EHPLOYEE ACKNOWLEDGEHENM: (My signature means that I have been advised of my performancs)

Employee's Comments:

EHPLOYEE SIGNATURE: DATE: I)o- -i 9 ,

APPROVALS:

SUPERVISOR SIGHATURE: DATE: / / G 9&

ER&D REVIEV: _ DATE: // // /

NEXT LEVEL SUPERVISOR / -

REVIEW AND ENDORSEHENT: ___ DATE: _ _ _ _ _ _ _ _ _ _ _ _

_ oA C-)

0 0

. a) tVA 4535 t1-93) [2-951 7 K (

• I :4

--P v fz QUESTIONS FOR K-)i PROGRAM MANAGQFR. CIrEMISTRY (page I of 2) . (o.

(r

'What stengths do you have that will benefit this position?. n 5.'tPv Indicate weaknesses that you need to address if you fill this position.

3) . Part of the accoun ailities for this position is that of assessments. How do you go about assessing the effectiveness of a program and then to develop corective actions for weaknesses?

4) - If, in the process of seeking corsensus from the three sites, you have one site that . r disagrees w'ith 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?

O) VI1COU1 WICrqULjXm.C-L5 C 01 LUC p1UUbL Fs^_ x1^ __ ..........

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to^re a

ltsIeinF ltnmtttnnl rs.....................e..........................e......L L I

.i fill a site position. How do you feel about being assigned to a site temporarily or_

permanently? I I o- ?

-A +: ;e_

I

-4v (53 Descrbe 3projectsfprdgrams you helped to initiate 1 develop, an complete m thc --

Chemistry areas. (T 41 :C ti, L

8) What do you see as the main role for this posi on?

t.49)/ Describe the level of responsibilitry this position she have in contrbit n to the &)W success of the site Chemistry progra s. rr.L Nl *t f.A. e

• tt0-04t - 4toh^-to AO Fr~ tvta 4&d ;Sq 'C"' - o2O

10) What is your method of getting work accomplished for the sites (i.e., how do you go about working out solutions and fikiing problems)?: ..

I ci)Describe at leat 2 chemistry concerns of TVAN.

12 Fefine the term "denting" and where anhow does it occur?

CL ,c s 7t p r t occX

,3,, What is Hydrogen Water Chemistry? How would Hydrogen Water Chemisty benefit BEN?

If an INPO evaluation determined that a concern should be a finding and you disagreed, how would you attempt to resolve the issue?

CDO00017

- . Z,

_ . - - . .1.

QUESTIONS FOR I,

JI PROGRAM MANAGER. CHEDMCSTY D f- L-V-~ ~

(page 2 of 2) 4r4Y'J4 $iel

• Ioe . Ale- -- ~ & .b MzA rc 0i I-Discuss the INPO Chemisty Index. What is its significance? 21J4-- AZ.4. -

@1

( 16 ) Discuss your specific management experience and training. l ,4 L'S.

_ s f ~?4-e-~-~$m_v6eL a~~ I a\RdCbcnon?

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3 CDOOOSIS