ML20078L704
| ML20078L704 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 06/27/1983 |
| From: | Addis B DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20078L617 | List: |
| References | |
| FOIA-83-434 NUDOCS 8310240040 | |
| Download: ML20078L704 (129) | |
Text
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U NIT E D STATES OF A ME RIC A NUCLEAR REGULATORY C O M MIS SIO N BEFORE THE A T O MIC SAFETY AND LIC EN SIN G BOARD In the Matter of:
)
)
j DUKE POWER COMPANY, et aj. ) Docket Nos. 50-413
)
50 414 (Catawba Nuclea r S ta tion,
)
l U nit s 1and 2)
)
D E P O SITIO N OF:
BRENDA GAIL A D DIS
}
AHLERS83-434 PDR i-Evelyn Berger Associates STENOTYPE REPORTING SERVICE P. O. BOX 19444 AH ARLOTTE. N ORTH CAROLtN A 28219
LAWYER'S N OTE S Page Line t
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l r
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2 ROBERT GUILD, ESO.
C olumbia, S.
C.
.3 Couns el on Behalf of Int e r ve no r, P alme tt o 4
A lli a n c e C o r po r a tion 5
RONALD L.
- GIBSON, ESQ.
C ha rlott e, N.
C.
6 C ouns el on Behalf of A pplica nt, Duke Powe r
7 Company 8
A ls o Pr e s ent:
9 George W.
G rie r Duke Power Company 10 Roger O ue ll e t t e 11 Duke Power Company 12 Glenn H.
3 e ll Duke Power Company 13 M ic ha el F.
Lowe 14 Palmetto Allia n c e 15 phit yog Palmetto A llia n c e 16 Betsy L evit a s 17 C a r olin a E n vi r o n m e n t al S tu dy Group l
19 I N D E X M
WIT NE SS DIR E C T CROSS 21 Brenda G a il Addis 4
22 23 24 25-EVELYN GERGER ASSOCIATES. STENCTYPE REPORTING SERVICE. CHARLOTTC. NORTM CAROL'NA
W 3
Diroct Addis i
i The D e p o s itio n of Brenda G a'il A ddi s,i s i
2 taken at the corporate offic e s of Duke Power Company, 3
C ha rlott e, North C a r olin a, on this the 27th day of 4
- June, 1983, in the presence of R ob e rt Guild, Attorne y 5
for the In te rv eno r; and Ronald L.
- Gibson, Attorney 6
for the A p plic a n t.
7 All f o rmalitie s as to c a ption, c e r tific a t e 8
and t r a'n s mi s s i o n are waived.
It is agreed that 9
Lynn B.
G illia m, Notary P ublic in and for the State lo of North C a r o lin a, may take said D e po s ition in 11 machine sho rthand and transcribe the same to type-12 writin g.
k 13 Said Depo sition is taken s ubj ec t alone to 14 te s timony for c o m p e t e n c y, relevancy and materiality; 15 and a-!! o bj e c tion s, save as to the form of qu e s tio n s 16
- asked, are reserved until the H earing.
17 18 BRENDA GAIL A D DIS, 19 having been firs t duly sworn to teli the truth, was 20 e x a mi n e d and t e s tifi e d as f ollo w s :
21 22 DIR EC T E XA MIN A TION 23 BT M R.
GUILD:
24 C
Ms.
A ddi s, state your full name and busine ss s
M address for the Record, pl ea s e.
EVELYN EERGER ASSOCIATE-STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROWNA
Diroct 4
A ddis 1
A Brenda Gail A ddis, Duke Power Company; 2
Box 3 3179, ' C ha rlo t te.
3 Q
Do you work here in the c o r po ra te head-4 qua rte r s ?
5 A
T ha t 's correct.
6 C
W ha t is your pre sent position ?
7 A
Director of Employee R elations.
8 O
Ms. A ddis, my na me is Bob Guild, and 1 9
represent Palmetto A llia nc e in the Lic e nsin g case 10 fo r the Catawbc S tation; and are you aware that 11 Palmetto Allianc e ha s fli e d and the Board has accepte d 12 fo r litigation a contention c alle d Contention Six rstating 13 to the subject of Q ualit y Assurance at C a ta wb a 14 S tation ?
15 A
The N otice of the De po sition explaine d 16 about the welding at C atawba.
17 Q
I want to show you a copy of the text of l
18 that Contention so you can refresh your r e c olle c tion l
or see it for the fir s t time, if it is the fir s t time.
l 19 20 T his is a document dated December 31st, 1982 A pplic an t's R e s pon s e to first set of Palmetto 21 M
A lli a n c e Interrogatories (in dic a tin g).
23 This is the s e c tion of that C ont e ntion as 24 Admitted by the Licensing Board.
25-MR.
GIBSON:
Can we point s pe cifi-EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CMARLOTTE. NORTH CAROUNA
A ddio - Dlroct 5
1 c a ll y to what you are talking about?
2 MR.
G UILD:
It is the indented s e c tio n 3
of that p a r a 'g r a p h,
if you can take a m i n.u t e 4
and read that, and it goes over to the next 5
page.
6 MR. GIB5ON:
Mr.
G u il d,
you are 7
showing her the o rigin all y A dmitted 8
Contention Six and not the C o nt e n tio n Six 9
as recast by the Board.
10 MR.
GUILD:
- Yes, I will show her 11 that in a minute, Counsel. That is the 12 o ri g in ally filed text of C ontention Six and
~
13 describes Palmetto A llia n c e 's concerns.
14 THE W IT N E S S :
All r 'i g h t,
I read dowa 15 through (indicating).
16 17 SY MR.
GUILD:
18 Q
Now there.is another quoted para gr aph that 19 has a bracket around i t, if you would take a moment 20 to look at that as we ll, this paragraph I meaa 21 (i n dic a tin g ).
Can we agree this is 23 paragraph which is C onte n tion Six as a
24 recast by the 3oard?
25 MR.
GUILD:
Yes.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
l Diroct 6
A ddi s 1
BY MR.
GUILD:
2 Q
A ll right.
'm a ' a m ; have you seen those 3
before today?
4 A
No, I have n't.
5 C
Pleas e s peak up to m ake sure that the tape 6
picks you up.
7 A
1 had not seen those before today.
8 O
I want to ask you a s e ri e s of qu e s tions.
9 Mrs. A d di s,
and what 1 am trying to do is gather some inf o rma tio n in Discovery, try to learn f ro m 10 11 inf o rm ation on this general subject reflec ted in the 12
- g.,g Tou jus t read s p e c ific a lly r e la tin g to your 13 knowledge concerning Quality Assurance and welding 14 at the Catawba S ta tion.
15 You have been involved in r e s p on din g to concerns that were raised by a number of Catawba 16 17 W eldin2 Inspectors; haven't you?
18 A
The recourse procedure that some of the inspectors used about the pay grade, I wa s involved I.n.
19 20 Q
- Yeah, that would be g e n e r ally the subject 91 of my questions.
I will try to ask you que s tio ns in 99 plain En gli s h, and please s to p me if I am not clear
~-
23 in my gue stioning or you don't understand.
24 If you don't understand, just say s o, and 25 I will try to rephrase it or explain what I mean.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORT 1MO SERVICE. CMARLOTTE. NORTH CAROUNA
Direct 7
Addio 1
Otherwise the transcript will r efle c t your answer to 2
a question, and we will unde r s ta nd that your answer 3
was. responsive, and you understood the que s tio n.
4 If ref erence to a document would help you 5
answer a qu e s tion, if'you could indicat e that document' 6
and we can take a moment, there are a number of 7
documents here in the room that relate to the subject 8
and I also just this mo rnin g had a copy 2 ven to me i
9 of what was indicated to be your file s with respect to to this subject.
11 Those are available, too; is that an 12 acceptable procedure?
13 A
I will do my best.
14 C
T ell me a little bit about what your job 15 is and you r r e s pon sibilit y.
16 A
I am Director of Employee R ela tion s in 17 the Corporate Personnel O f fi c e, and the scope in c lude s 18 but is not limited to a variety of things involving 19 human resource, management thi n g s in general.
20 T he e mpha si s in c o o r din a tin g pilot efforts 21 in quality circles, looking at s y s te matic kinds of 22 procedures such a s c o r r e c tiv e discipline, positive 23 dis ciplin e, c o rn m u nic a tio n s,
channels and processes 24 are a part of ou r ju ris dic tio n.
25 We work through Employee Relations peopig s
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVlCE. CMARLOTTE NORTM CAROUNA
Diroct S
A ddis 0
1 in the field at each con s truc tio n site, steam s t a tio n, 2
division o ffic e s.
3 There are many people 1.n v o l v e d in this 4
role.
I am also taking a lead role in the Step Two 5
Phase of the E rn pl o y e e R ecou rs e Procedure, which is 6
one of my primary r e s pon sibilitie s, and also r e all y 7
in helping the company have a kind of progressive 8
and innovative human recourse f unc tio nin g that we 9
are desiring to have represent the company in to national o r g ani z a tio n s, utilitie s,
industry, committeen 11 fo r handicapped people, and those typ es of things.
12 C
H o w l o n g.h a v e you held your present 13 po s ition ?
14 A
I' m in my fif th year.
15 O
D e s crib e for me b ri e fly, Ms.
A d di s, the 16 structure of Employee R e l a ti o n s at the Catawba 17 S ta tio n ?
18 MR.
GIBSON:
I will object ba sed on 19 the li mi t a tio n s or na r r owin g of Contention 20
- Sim, but I will allow her to answer.
21 THE W IT NE S S :
I guess my concern 22 i s.. whi c h de pa rtment ?
23 24 BY MR.
GUILD:
25 C
You have to help me under stand; as sume EVELYN BERGER ASSOCIATES. STENOTYPE PEPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
A ddis Diroct I'
no knowledge on my part on how Duke Power is 2
organized or your area of r e s pon sibility.
3 1 hear you make a reference to E m plo y e e 4
R ela tio ns people in the field.
We will be focusing 5
on Catawba.
6 fielp me understand how the Employee 7
R ela tion s func tion at C a t awba and the o r g a ni s a tion al 8
structure of your work at C a tawb a.
9 A
There is an Employee R ela tion s f un ction 10 in th e C on s t ru ction Department at Catawba, which is 11 a m aj o r department, meaning the number of e mplo ye e s 12 on site, the way the E m plo ye e R elation func tion 13 works in some of the other areas, division oper ations 14 not located at C at awba, there is a ge o g ra phic kind of 15 s e r vic e which is what Quality Assurance D e pa rtme nt 16
- has, and the Nuclear D epa rtm ent has an E mploy e e 17 R elation s function th rough their Personnal A sistant 18 p o s iti on at C a ta wb a.
19 Q
A ll righ t, le t's take the Cons t ruc tion fir s t 20 Is there a s p e ci fi c Employee P. e l a t i o n staff that work s 21 in the Con s t ru c tio n Department at Catawba?
22 A
- Yes, several.
23 O
W o 21 d you give m e an idea of who those 4
24 people are and how many there are and how l
25 g e n e r ally th a t effort is s tr uc tu re d ?
EVELYN SERGER ASSOCIATES. STEM *E REPORTING SERVICE. CHARLOTTE NORTM CAROUNA
Diroet 10 A d.d i s 1
A At Catawba c o n s t r uc tio n, of course, the 2
Employee R ela tion s pe cific f un c ti o n is assigned to I 3
b eli e v e two people p re s ently who are c alled Em ployee 4
R elation. s taf f, although the Personnel Mana ger is 5
involved in va riou s and other positions at Catawba.
6 Q
Yes, who are the two people p r e s e ntly in 7
E mp'lo ye e R elatio n s ?
8 A
Steve Alexander and Fays Fowler are the 9
ones I have worked with.
10 O
Have tho s e people been at Catawba for 11 some tim e in that c a pa city ?
12
'A Steve has, I am not sure how lon g Faye 13 has been as signed there.
14 Q
W ould Mr. Alexander have been in that 15 f un c ti on at C a ta wb a during the period that is the 16 subject of the W eldin g Inspector concerns?
17 A
I believe he was, yes.
18 Q
Say from early 1981 forward?
l l
19 A
I think so, in the C o n s t r uc tio n Department, i
l 20 Q
Now then, how about for Quality Assurance 1
21 at C atawba ?
W ould there be a separate Employee 22 R ela ti on s staff there tha't deals with Quality A s surani:e i
)
23 personnel at C atawba ?
24 A
N o.
25 Q
H el p me understand then how someone who EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CARouMA i
a
=
Diroct 11 A ddis I
was in Employee R elation s in the Q u ali t y A s s.u r s a c e g-2 Department--
3 A
The QA Department b a s ic ally handles their 4
personnel func tion f r om the C ha rlo t t e o f fic e s.
5 Q
W ho in the C harlo tte o ffi c e then is 6
r e s pon sible f o r e m p~1oyee functions in the QA Depart-7 ment?
8 i
W ell, the staff is under the direction of 9
Neal Alexander.
10 Q
Help me understand; we have a couple of 11 A lexande r s.
Is this C.
N.
Alexander?
12 A
Yes.
13 Q
As opposed to S te ve.. Alexande r ?
14 A
- yes, 15 Q
C.
N.
Alexander, what is his title ?
16 A
I believe Personnel h!a n a g e r in Quality 1
l 17
. A s surance, by title.
18 Q
And he has Employee R ela tio n s responsi-19 bili tie s in that capacity?
20 A
- Yes, the functions are s ub or dinate to him.
21 Q
Soes he report to you?
U A
No.
23 Q
Is there an Employee R elatio n s person in 24 th e Quality A s su ra nc e Departmont who does report to 25 you?
EVELYN EERGER ASSOCIATES. STENOTYPE REPORTING SERWCE. CMARLOTTE. NORTH CAROUNA
Direct 12 A ddis 7--
1 A
No, they do not re po rt to me in direct line.
2 Q
How about Mr.
Steve Alexander and Faye 3
F o' w l e r,
do they report to y'o u ?
4 A
No, they do not.
5 Q
T hi s is.a 11 s t of the persons whose 6
D e po s itio n s are to be taken this week (in dic a tin g ).
7 Are the re any persons on that li s t, Ms.
A ddis, who 8
are responsible for Employee R ela tio n s ; and if s o, 9
if you would indicate who they are and I will g e t you 10 to tell me what their p o s itio n is?
11 A
Iam the only person I am aware of on that 12 list who is dir e c tly re s pon sible in title.
~
13 Q
We have M r.
C.
N.
Alexander on that list.
14 A
There is a lin e through there on my list.
15 O
All ri ght, ignore the line.
You have told 16 me about Mr. Alexander.
l 17 A
Mr.
Grogan has subordinates r e p o r tin g to 18 him who are re s ponsible for E mplo ye e R ela tio n s.
19 Q
What is his po s ition ?
20 A
Functionally the P er s onn el Manager in the 21 C on struction Department, although he has a broader 22 scope of r e s po n s ibility.
U Q
A nd also D a vid Abernathy--do you know Mr 24 Grogan's title s pe cific ally ?
Give me a paraphrase of 2
it if you do n' t have it exact.
EVELYN SERGER ASSOCIATES. STENOTYPE REPO,tTING SERVICS. CMAlWLOTTS. NORTM CAROUNA
A ddio Diroct 13 1
A Ithink he is the Manager of C o n s t r uc ti o n 2
R e s ou rc e s.
3 O
Now, Mr.
A b e r n a thy; do you know what his 4
title is?
5 A
He is the Manager of the personnel 6
function in C o n s t r uc tio n.
7 O
A ll right, Bill B radley is involved in 8
Personnel Services in the Quality Assurance D e pa rt-9 m e n t.
Do you know what his title is ?
10 A
His present title, no; I do n' t.
11 O
Ms.
A ddis,
do you s up e r vi s e either directly 12 or in di r e c tly any persons who pe rf o r m E m plo ye e 13 R elation s work at the C a ta wb a site ?
14 A
No.
15 C
And then how about any persons who are 16 responsible for Employee R elatio n s i nv o lvin g persons 17 who might be working at the Catawba site ?
l l
18 A
Not dir e c tly, no.
1 19 O
Ms.
A ddis,
I want you, if you can, take 1
20 as much tim e as you need and we can break this down 1
l 21 into s m all e r pieces af ter a bit; but I want you to l
22 relate to me your knowledge of what I will c a ll the 23 Catawba W eldin g Inspector concerns.
,v 24 Give it to me g e n e r ally how you got 25 involved in the s ubj e c t and what your work was is avstys senaan associares. stumonre nenonrima suavica. cuantorts. nonTw canouma l -
Oiroct 14 A ddi s 1
regard to that subject; and as we go along if ref re sh-r 'e c o ll e c ti o n would help, we can get access 2
ing your 3
to our file.
4 But tell me ge n e r ally how you became 5
involved and what you did.
6 A
In my. role in leading the company in Step 7
Two of the Employee Recourse Procedure, I b e c a me 8
aware that several e mploye e s had gone through Step 9
- One, Catawba W eldin g In s p e c to r s, in te rms 'of asking 10 management to take another look at their pay periods 11 At Step Two I received n o t i fi c a ti o n of the 12 e mplo ye e s ' desire to pursue it beyond that department 13 to Step Two; and in r e viewin g those concerns at Step 14
- Two, a standard p r a c tic e is to meet individually with 15 those e m plo y e e s.
16 So I met with each one of them assigned ti) l 17 m e.
I did have s o me help in the process.
Their 18
- concerns, each concern, was founded on the pay grad e
19 dif f erence s; and each man pr e s en te d to me in the 20 context of that, reasons and concerns, perceptions j
l 21 and o pinio n a to some extent, about why the pay grada-l 22 should be equated to o th e r p eo ple in the company in 23 their opinion.
24 I took these concerns, which I b e li e v e you E
have seen, and relayed those to man a g e m ent.
The l
l
. m m....... c.m... m on. m m..
.c..c
.u m..
- c..ou.
Addis Diroct 15 I
step pr o c e s s is one where the company m an a gem e nt 2
a c tually takes a s e co n d look at any e mploye e's requen t 3
or concern or que stion and is guided by the corporato 4
o f fi c e and serves as a communication resource, 5
a c tu all y, between the em ployee s and the appropriate 6
level of management.
7 T hat is what I did.
8 O
A ll right, when did you fir s t become awar a 9
of the C atawba W elding Inspector concerns?
10 A
I was aware in July of
'81, or I wa s some 11 what aware when they started Step One: although we try to kee p the s e steps dis tinc t; and I did not get 12 13 involved in the details.
14 MR.
GISSON:
Excuse me.
I am not 15 clear whether you are referring to the 16 concerns as indicated in the do cu ment s 17 attached to your M otio n for extended time l
18 and identified in the B o a rd 's
- Order, or you can use the term " inspector concerns" 19 20 referring to the pay recourse p r o c e d u.r e 21 that Mrs.
A ddis was involved with.
22 MR.
GUILD:
If she wants to explain 23 her und e r s ta ndin g, that w o ul d be h el p f ul, l
~
24 MR.
G 13 S O N :
I want to understand 3
that; I need to understand aach que s tion.
EVELYN SERGER ASSOCIATE $. STENOTYPE REPORTING SERVICE. CHARLCfTE. NORTW CAmouMA
Direct 16 A ddis 1
MR.
GUILD:
If ths %itness under.
2
- stands, if she has a problem with the 3
que s ti o n.
I hope she will ask me to clarifr.
4 5
sy gn.
GUILD:
6 Q
Ms.
A ddi s,
do you understand the use of 7
the term " concerns," as you answered it?
8 A
My unde r s ta ndin g, I thought that he was 9
referring to the Step Two concerns over the pay I 10 have been describing, Mr.
Guild.
11 If you do change the s ubj e c t, please let m e
12 know.
13 C
I will be happy to, and if you ha ve a prob lem-14 with my terms, please let me know.
15 A
Okay.
16 C
Beyond the Step Two grievanco you stated 17 that you had some awareness of these concerns at 1
l 18 l
Step One; did you not?
l l
19 A
All I knew was that so me CA e mplo ye e s 20 were be ginning the recourse process.
I am u sually 21 n o tifi e d of that, not by subject or detail, just in 22 l
anticipation of our s taf fin g tim e and whether the j
23 e mplo ye e s will elect to go to Etap Two.
i.
24 O
How did you become aware of the Step One 25 8 ta88 7 EVELYN BERGER ASSOCIATES. STENOTYPE REPOFNG SERVICE. CMARLOTTE. NORTM CAROUNA
A ddia D :, J a.: t 17 of'the 1
A Mr.
3 r a dle y inf o r m e d me some 2
e mplo ye e s were b e ginnin g to use the process,_ but n o-;
3 the d e t ail s of the subject matter s.
4 Q
M r.
dradley, who is he a g ain ?
5 A
Bill B r a dley, he was responsible for Per-6 sonnel and Quality Assurance.
At that ti rn e he was 7
the person in v olve d in that.
8 C
W ha t was his r e s pon sibility at that ti m e 9
with regard to those con ce rns ?
10 A
His exact r e s p o n s ibilit y I can't tell you.
11 Q
G en e r ally can you give rn e a general de-12 acription of his role?
13 A
As I understood it, he was the contact I4 resource involved at the d e pa r t me n tal level.
15 C
Did the Welding In s p e c to r s come to him ?
16 A
The recoursa process involves, and I 17 b eli e v e this is what these gentlemen know, involves I8 an e rn pl o y e e giving a written statement of concerns I8 to mana ge me nt, and that b e gin s p re tty much at the 20 local level and goes to the staff for any e v alu a tio n 01 support they can give.
I eM O
W ha t was Mr.
L radle y's role as you know 23 it or as you understand it?
t 24 A
He in off ec t conducted the e v aluation and 25 analysis and helpe d me understand the concerns and EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE, NORTM CAROUNA n-.
A ddi s Diroet la I
answer the e m p l o y e e 's.
It is a similar function to 2-mine.
3 Q
B ut at Step One of the recourse?
4 A
(The Witnes e nodded her head affirmatively.)
5 C
How do the concerns come to his a t t e n ti o n,'
6 if you know?
7 A
My un de r s ta ndin g is of the typic al pr oce s s, 8
the e mplo ye e s ' written concerns co me up through thei r 9
s up e r vis o r s.
10 C
All ri gh t, le t's take a mom e nt, M r s.
A ddir.
previous o p p o r tunity to have your file 11 I just
.had a 12 in front of you.
W hy don't you make reference to 13 that ?
14 I have a copy of the m a t e ria ls that were 15 id e n tifie d as you r file, and perhaps you can describe l
i 16 tho s e; not in detali, but g e n e r a lly what is it that we 1
17 have her e ?
18 A
A ll of these thin gs ?
l l
19 Q
Yes, ma'am.
20 A
T hi s brown envelope, the part that is 21 stapled together is the contents of the Step Two 22
- concerns, some of the history as it is presented at 23 Step Three, l
1 24 Q
O ka y, hold that a m o m e n t.
It is the con-3 tents of the Etap Two file ?
EVELYN SERGER ASSOctATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NCRTH CAROUNA
A ddis.. Direct 19 1
A Yes.
2 C
Mow you mads a reference to 7tep Three.
3 Yhat is the Ftep Three r e f e r e n c e. ?
4 A
Step Three is the presence, thl's is the 5
summary of the data that wa s. p r e s e nt ed to Step Three 6
at present.
7 Q
So this is a summary of your Ste p Two tep Three at present?
8 file that was present to e 9
A It is all the referenced inf o rmation that I 10 have.
11 O
What was excluded from that that you had 12 that did n ot summarize or in clud e that bound folder?
13 A
N o thin g pertaining to this situation.
I 14 didn't exclude a ny thi n g that dealt with Step Two.
15 C
What did you mean when you said "relevan4"?
16 A
1 didn't include rome of the things, I gues s,
17 with regard to where I went or when mo s t of the dat os l
18 are in there.
19 There r e ally isn't anything excluded that l
l 20 is pertinent to this, to the case.
og C
- Yes, w e ll, I appreciate your judgment on
- that, but I would li k e to under s tand, -to have a fair 22 sense of what process you went through to s u mm a ri s o 23 those document s or decide what was relevant or w ha t 24 was p e r tin en t; so help me understand what is not 25 l
I avstys announ associares. sramorna nunmnma sanwes. cuantorra. monta camouma
Addis Direct 10 1
included in there so I don' t pre s ume that e ve r y thin g 2
is there.
3 A
The things that I included c o mple t ely are 4
the e m plo ye e s ' s ta te ment s to m e, messages to me.
5 positions, o pi nio n s about their pay rate.
6 1 did not fully copy and do c ume nt a ll of th e 7
inf o rmation at Step One.
That w ould be the only 8
thin g that would be not totally as s e mble d here.
8 C
A ll righ t, did the Stop One ma te rials come 10 to you?
11 A
1had the o p p o r t unit y to review t h e m.
12 Q
Did you?
13 A
(The Witness nodded her head affirmatively.)
14 g
ge m sorry, the tape needs an a ffi r m a ti v e 15 o r negative answer.
16 3
7,,,
,37, 17 C
V. hat did tho s e Step One materials consist 18 of?
19 A
S a s ic ally the d e pa r t me nt 's position in 20 response to th le tte r s that the e mploye e s had sent.
91 C
V, hi c h d ep ar tmen t would that be?
~
92 A
C ua li t y A.; s u r a n c e,
o3 O
And what did tho s e department responses 24 consist of?
25 A
They are individually m a d e --I can't t e ll yo u EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
-+--
A ddis 01roct 21.
I from m e mo r y.
2 O
Give me an idea of what fo rm they would 3
h e in, a letter to the c o mplain an t ?
4 A
That is the typical response, the e mplo ye e 5
is given a written response during 30 wo r kin g days 6
af te r the recourse procedure.
7 T he time f r a me may be extended, but that 8
is just the procedure.
8 C
W ho would at the Step One process for this 10 p a r tic ula r instance, who would have been responsible II for the de pa rtme nt al Step One response?
12 A
Jim Wells.
13 C
Now look in th at folder, if you would, Ms.
I4 A d dis ; is there at least a s p e cim e n response from 15 Mr.
W ells to the M elding Ins pe ctor a ?
16 3
7,,,
17 C
% ould you i d e nti f y that by the date so we I8 can note what it is?
19 A
October 24, 1981.
20 Q
A nd is there an in di c a tio n on the face of 91 that do cume nt ?
Is that a document that is a copy of
~
one of the Step One responses to the c o mplainin g I
l 23 I
anspector?
04
~
A T ha t la my understanding.
25 O
And were there dif f e r e nt responses made I
Emm.ERGER ASSOCIATES. STENOTW WORTING E2RYlCE. CMRLOTTE. Nom CAROUM L
Addin Direct 22 1
to each in s pec to r ?
2 A
Yes; this is one (indic a tin g).
There is an 3
A ugus t 10,
'81, response als o.
4 Q
W ho is that?
5 A
T hi s was also Mr.
% ells.
6 Q
hi r.
% ells to a c o m plainin g inspector ?
7 A
(The Vi i t n e s s nodded her head affirma tively.)
8 G
A nd I believe the name of the a c tual 9
ins pecto r ha s been marked out?
10 A
I did that.
11 C
A nd those were s p e cim en s of what was sen t?
12 A
When I a s s e mble d this packet, that was my 13 intention.
14 C
Can you explain why we have an Au gu s t an i 15 then an October response?
16 A
E mplo ye e s did not start on the same days, 17 so the time frame do e s n' t start--
18 C
Some came e a rli e r than other s ?
19 A
Diff e r en t e mployee s started at diff e r ent 20 ti m e s.
21 Q
Both of thes e ar e Step One s up ple m ent al 22
,,,po,,,,7 23 A
That is my understanding.
24 O
Do you know what the range of ti ne s were 95 for the c o mple ti on of that Step One response, when w as Eb ELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERYlCE. CHARLOTTE. NORTH CARCLINA
A ddis Direct 23 1
the fi r s t and when was the last, g e n e r a ll y ?
3 A
Without r e vi ewin g those in d e t ail, no.
I 3
know when I got involved.
4 C
Is August t h r o u g h' O c t o b e r re pr e s enta tive of 5
the range of tim e s for the Step One response?
6 A
W ell,
- again, without r e vi e wi n g thos e in 7
d e t a il, I can't t ell you.
8 O
If you can refresh your r e colle c tio n from t
9 looking at the file in front of you, how about taking 10 a moment and doin g that ?
11 I would like to try to e s ta bli s h the timin g.
12 A
These were my files, which m e an s those 13 were Step Two; so I c an't tell you about Step One, 14 precisely.
15 C
A ll right, look th r ou gh that binder ther e.
16 that s ummar y binde r, M r s.
Addis.
Is there a speci-17 men of a Step One recourse letter or recourse 18 c o m plain t from the c omplainant, from a Vi e l di n g 19 Inspector?
20 A
I did no t include the Step One lette rs in 21 the summary.
The e m ploy e e s, particularly in m e etin g 22 with me, they have ba sic ally an option of writing 23 a nothe r ou titin e o f their concerns, but there are 1stte rs 24 in here of Ste p Two and the concerns are mainly the 25 same.
EVELYN BERGER ASSOCIATES. f ENOTYPE REPORTING SERvlCE. CHARLOTTE. NORD* CAROUNA
c 24 Addis Lirect 1
Q By Step Two letter, identify what you are 2
speaking of here.
Iust pick one specimen that is s
3 r e p r e s e nta tive,
4 A
I have one here from Mr.
B e ntle y, Welding 5
Inspector at C a tawb a; O c't o b e r 28,
'81.
6 O
- Yes, is Mr.
Bentley's Step Two recourse 7
le tt e r r e pre s entative of the--
8 A
T hi s is an individual process, and each 9
e mploye e presents his individu al concerns.
10 Q
So are all the Step Two recourse letters 11 that came f rom Welding Inspectors included in that 12 binder 7 13 A
A ll th e ones in this p ar tic ula r binder whici 14 are id entified in the front.
15 O
And the front, you me an the page that is 16 e n ti tl e d,
"In tr od u c tion" ?
17 A
Yes.
18 O
And how many V' e l di n g Ins pec tor s are show n on that int r o duc tio n by name as pursuing t h ei r 19 20 recourse?
21 A
There are eight W eldin g Inspectors from 22 Catawba.
23 Q
A ll right, m a' a m, I see eight in type-24 w ritin g li e t e d under the tit t o,
"C a tawba, " and I see 2
four in hand.
EVELYN SERGER ASSOCIATES STENOTYPE REPORTING SERV 1CE. CMARLOTTE. NORTM CAROUNA
23
.i d d i s Direct 1
A R i g ht, those gentlemen elected also to go 2
to Step Three, but it was after I had written this 3
s u mm a r y.
4 It was the same concern, and they as ked tc 5
b e i n c lu d e d.
6 Q
And when was this summary writt en;. ca n 7
you tell me?
8 A
I took this to th e President on D e c e mbe r 4, 9
C Is that when it wa s written ?
10 A
It was typed the thir d.
11 O
Now on the f ac e of the intr oduc tion. Ms.
12 A ddis, it indicates,
" Initially there were 53 Step 13 Ones on the pay issues; 34 continued to etep Two.
14 With those, 11 c o n tin ui n g to Step Three.
A summary 15 of the concerns is as f ollows " and it goes on.
16 Did you r e view the etep One, grievance 17 Step One recour s e letters for the fif ty-th re e ?
18 A
No, I d e alt with the ones that were pro-19 ces sed to St e p Two.
20 O
The 34?
21 A
- Yes, remember the numb e r changed 22 slightly with some of the ones joining ete p Thr e e.
23 O
Help me understand how those number s 24 would change with tho s e others joining?
25 A
The handwritten names the r e made it more EVELYN SERGER A510CIATES. STENQTYPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROUMA
26 A ddis-Direct 1
than 11.
2 C
Thirty-f our did c o n tinu e to Step Two; that 3
is the c o mple t e list, the c om ple t e nu mber ?
4 A
At this writing it did; I di dn ' t have any
.5 more c o me in that I am aware o f.
6 C
Eleven went to Step Three and they were 7
joined by the four others indicated here?
8 A
That's correct.
9 O
Did you see any of the original Step One 10 g rie va n c e s or recourse c om plaint s ?
11 A
- Yes, I did.
12 O
You did, and in what form are they?
13 A
Letter.
14 C
They are not included.
D e sc ribe the Step 15 One recourses.
16 A
Some were handwritten, some were typed.
17 C
Where are those documents now, if you knciwS 18 vs. A ddis ?
19 A
I don't know.
20 C
Where were they when you r e viewed the m ?
21 A
I r e vi e we d those through Mr.
Sradley.
22 C
E :c pl a in how do you mean that?
23 A
He had them when I saw them.
24 C
Did you go to him and find him in his 25 office ?
Did he bring them to you?
EVELYN BERGE8B ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NCTfM CAROUNA
es d d i s Direct 27 1
A I think I went there.
2 Q-Yhere is "there"?
3 A
Do you mean whe re is his of fic e ?
4 Q
- Yes, where did you s e e its here in 5
.C ha rlo tt e ?
6 A
Yes.
7 O
Have you r e vi ew e d those documents since ?
8 A
No. I haven't.
9 O
Now, those Step One grievances or recours es, 10 if I use that term, is that a fair term to u se ?
11 A
I will unde r s tand what you m e sa.
12 O
Those Step One grievances, would the y have 13 c om e f ollowin g July of 19 817 14 A
The recourse concerns that I rec eived we r's 15 in July, s ta rted in July of
'81.
16 Q
Step One concerns?
17 A
Step Two that I got involved in.
18 Q
M a ' a m, you got in volv e d with them in July ?
19 A
O f fi ci ally, some.
M Q
Some had reached 'tep Two by July ?
21 A
Yes.
To the best of my knowledge, I can open this and looks but I think so.
M 23 C
Iam tryin g to und er s ta nd, I' m recognizing I
24 not all of th e m happened on the same day.
I would 25 like to understand when the Step One grievances wer a EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CARQUNA l
' J..i r o c t 23 A ddis I
flie d or Step One recourses were file d.
2 MR.
CIBSON:
While she is doing 3
that, Mr.
G uil d, may I see.the copias we 4
gave you the fir s t thing?
5 Ma y I 's e e that?
6 MR.
GUILD:
Yeah.
7 MR.
GI3 SON:
Mr.-
G uil d, this copy 8
I gave you inadvertently includes the pay 9
data we indicated would not be in clud ed, 10 so I' m r e m o vin g it.
11 MR.
CUILD:
We will cross that b rid g e 12 when we get to it in the other D e p o s i tio n s.
13 These computer p rin t o ut s, does that appear 14 to have na me s of people on it ?
15 MR.
GIBSON:
Yeah, each one.
16 N! R. GUILD:
Are you sure ? I looked 17 at it over the break, and I didn't think it i
18 wa s wha t you were talking about.
19 MR.
GIBSON:
To p lef t corner has i
20 emplo ye e's name, lo c a tio n, occupation, rai.e 21 of pa y, and s'o m e 'o f the c o ding inf o rma tion.
22 MR.
GUILD:
- Fine, if you would pro-l 23 vide me the generic pay inf o r ma tion.
f 24 MR.
GILSON:
I think we will have to 25 hear your qu e s tion and make a d e t e r min a ti on EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERV CE. CHARLOTTE. NORTH CAnouMA a
.A ddis Direct 29 1
at the ti m e as to relevance and everything 2
to see what you s p e c ifi c all y need.
3 THE WIT N ESS:
I think I was involved 4
in July and August at Oconee.
The C atawb a 5
weld e r s were October.
6 7
BY MR.
GUILD:
8 O
These would be the Oconee, and the s e 9
would include the 30 Oconee inspectors who are li s t e d 10 on the fir s t page of your int r o duc tio n as pursuing 11 the Step Three recourse?
12 A
It may have.
13 O
A ll ri ght, I am sorry th en, it was Oc tobe r 14 you said when you be gan receiving the Ste p Two 's 15 from C a t a wb a ; is that right?
16 A
- Yes, that is what my records s ho w.
17 O
- Now,
'is.
A d dis, I want to show you a 18 series of document s, and these have be en in tr od uc e d 19 in Response to a Discovery R equ e s t by Palmetto l
l 20 A lli an c e,
and they have been id e n ti fi e d by the company 21 as handwritten notes from CC and QA Inspectors whic h
22 set forth th eir s pe cific problems and concerns; and 23 they are an attachment to a Motion that was fil e d 24 with the Lic en sin g 3oard in this case, l
25
/ h a t I am t ryin g to unde r s tand is that is EVELYN SERGER ASSOCIATES. STENOTTPE REPORTING SERVICE. CHARLOTTE. NORTM CAROLINA
~
\\
a d di s
. Direct 30
~
1
.a~ cover sheet I' m showing you, a cover sheet which 2
li s t s the name s with letter s besid'e the na m e s as 3
indexed by the copy in their response; and f ollo wi n g 4
that is a fairly thic k s tack, some typed and.s ome 5
handwritten notes.
6 Are those Step One recourses or if not, 7
tell m e what they are ?
Take a minute a nd look throt,gh 8
them and tell me if you can id en tif y tho s e f or me, 9
please.
10 A
Do you want me to review all of these?
11 O
Just fli p through them and tell me if you 12 can identify those documents, please.
13 A
No, I c a n ' t.
14 O
Have you ever seen them before?
15 A
No, I have n't; not to my knowledge.
16 Q
Those are not the ctep One recourses then
?
17 A
They do not appear to be at all.
A gain, 18 I have not c ompletely gone through this s tac k, but 19 they doO ' t appear to be.
20 c.
o il ri gh t, you have not seen those before 21 to the best of your knowledge ?
22 A
No, n ot to the best of my knowledge.
23 Q
D e s crib e g e n c,- a ll y witbout n e c e s s arily a 24 s p e cific regard to these / e l d i n g Inspector concerns 25 and their processing, how the employee recourse EVELYN SERGER ASSOCIATES. STENOTYPE REPoprflNG SERVICE. CHARLOTTE. NORTM CAROUNA
Direct 31 A ddio 1
procedure works, and g e n e r a lly what happens at what 2
step.
Not a d e t ail e d d e s c ription, but just gen e ra lly 3
t h ei fu n c tio n s.
4 A
It is intended to be a f o rm al kind of 5
process which in essence means that th e concerns are 6
w ri tt e n and the responses from m a n a g e m e nt people ar e 7
w ri tt e n as o utli n e d.
8 There is obviously an open door and verba l 9
routes f or employee concerns.
This is a separate 10 thing from. the wri t t e n.
11 Any e mplo ye e, as an individual, can use 12 the procedure by outlinin g his or her concerns in 13
- writing, sub mittin g them through m an a g em e nt, s ta rtin g 14 with the s up e r vi s io n up.
15 Staff support is available to help employee s 16 express the m s elve s if they ask for that.
A written 17 response is from t h e. department head is some form o r 18
- other, I guess the variation or the reason I am vagu e l
19 is because the corporate procedure c all s for a respo tt s e 20 within 30 working days unless both pa rtie s, the 21 management and employee agree to extend that.
l 22 Within each departmont there is some 23 variation on what happens within tho s e 30 w o r ki n g
!k' 24 days.
3 The corporate says 30, and they take it EVELYN BERGER ASSOCIATES. STENOTYPE REPC RTING SERvlCE. CHARLOTTE. NORTM CAROUNA
Direct 32
.\\ddis 1
from th e r e.
Step Two i s, where I b e c om-e involved or 2
some other designee of corporate E mplo ye e R ela tion s, 3
to work with the ma na gement of the department and i
4 the employee to be sure th a t the c o. m p a n y understands 5
the employe e concerns and the po si tion o r o pinion s 6
or thoughts or f e elin g s related to those concerns.
7 T hi s is all at th e request o f. t h e employee 8
that we might be involve d in taking a s econd look at 9
it.
10 The decision at Step Two is,
- however, the 11 one of the d e p ar tmen t m a na g e m ent, not the staff, such 12 as my s elf.
13 We do not render a decision.
14 G
H elp me under stand that you perform the 15 Step Two r e vi e w--
16 A
Take the lead role in the r evie w; yes.
17 Q
B ut you don't decide th e Step T 'v o recourse ?
18 A
T ha t's correct.
19 C
Who would make that d e c is io n ?
20 A
It goes back to the department head with 21 wha te ve r input, inf o r m ation that we may have gathere d 22 with our independent discussions a n d r e vi e w s.
23 If the employee at that point elects, the 24 l
matter is pr es ented to Step Three, whic h is the 25 P re sident and I or a no the r Emplo ye e R e la ti o n s staff EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMAfhJDTTE. NORTH CAROUNA
Otract 13 Addis I
per son make s that pr e s enta tion, c o m pile s that info r-2 mation for the P r e sid e nt.
3 C
And M r.
Lee was President d u r i n g t'h s timet 4
that is important in d e alin g wit h the W elding Inspecto r 5
concerns?
6 A
In '81 when I went with the m, 7
Q So the department head decides both Step 8
One and Step Two?
9 A
T ha t 's correct.
10 Q
And you f a cilitat e at Step Two by perform-11 ing an interviewing function.
Do you make a rec-12 o mm e nd a tion ?
13 A
% e will di s cus s with the man a g e m e nt thingo 14 such as precedent knowledge we have gained in the 15 same or s imil a r situation somewhere else, if that 16 exists.
17 C
Do you make a r eco mm e ndation ?
18 A
We do p r o vi d e input, but in terms of 19 r ec o m mend a tio n s, at tim e s we have been asked for 20 professional o pinion, but it is not r e ally a manage-21 ment r e c o mme n d ation at that point, more of a pro.
f e s sional opinion.
23 C
Is there a fo r ma l written d e s c rip tion of 24 the empicyee recourse procedaro?
25 A
C h, yes.
EVELYN BERGER ASSOCIATES. STENOTYPEI REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
l A ddio Diroct 34 1
O Whe re is that de s c riptio n c ontained ?
2 A
In the management procedures book and the 3
e mplo y e e 'h a ndbo ok.
4 O
Is that the f o rmal tit'le of that book, the 5
" Ma na g e r's Procedure Book"?
6 A
Manual I think instead of book, that is it.
7 C
Do you have that wit h you?
'A No, I don't.
8 9
Q Mrs. A d di s,
I want to show you a N o ti c e 10 that provides for the taking of your D e po sitio n here.
11 It is probably at the bottom of the list or close to 12 it.
13 I show you a document and ask if you can 14 identify it, plea s e, m a ' a m.
15 A
I can read it, yes.
16 Q
Have you seen that before?
17 A
I've seen a copy of this, yes.
18 O
You have seen it before?
19 A
(The Witne s s nodded her head a ffi r ma tively.)
20 0
Is that the Notic e of taking D e po sitio ns 21 that was served on you?
M A
It was given to me.
23 O
W ould you read th e second paragraph, 24 please, ma'am, for the Et e c o r d ?
U A
The second paragraph 7 EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE, NORTH CAROUNA
Direct 35 A ddis O
- Yes, ma ' a m.
1 A
"You are required to attend and may be 2
3 represented by Counsel and are required to b ring with 4
you any and all document s in your pos s es sion or 5
subject to your control r e fle c tin g your knowledge of the above de s cribed matter s upon which you will be 6
exa mine d. "
7 Q
Have you seen that b ef o re ?
g A
Yes.
9 10 O
Have you read that before ?
A (The Witne s s nodded her head affirmatively.)
11 12 Q
Why didn't you bring those do cum ent s with 13 you?
VR. GIBSON:
Mr.
- Guild, I object to 14 15 the question.
We repeat what we have 16 repeated before.
17 We have produced all of the items 18 we contend are to be produced consistent 19 with the Board's two Orders which relate 20 te C onte ntio n Six.
21 Mrs.
A ddis is free to talk to you 22 about what documents she has and what she 23 brought.
24 The ob j e c ti o n to that qu e s tio n is we 25 have produced what is available.
TVELYN SERGER ASSOCIATES, STENOTYPS REPORTING SERVICE, CHARLOTTE. NORTH CAROUNA
Diroet 36 Addis i
MR.
G UIL D:
I would li k e the question 2
answered as asked, C o un s el.
3 THE WITNESS:
Repeat the qu e s tio n.
4 5
SY MR.
G UILD :
6 Q
V/ h y h av e n ' t you brought those documents 7
with you, Ms.
A ddia ?
8 MR.
GIBSON:
Which document s are 9
you referring to, s p e c ifi c ally, when you 10 say "those doc ume nt s" ?
11 MR.
G UILD:
Does she understand the 12 que stion ?
13 MR.
GI3 SON:
I will und e r s ta nd it 14 before she answers the qu e s tio n.
If I do 15 not understand i t, she does not answer it.
16 Y. o u l d you explain what you are 17 referring to?
18 MR.
GUILD:
There is no need to 19 raise your voice.
The %itness s h o ul d hav s 20 an o pportunity to tell me whether she 21 understands the qu e s tio n.
22 Of courus, it~ is the V/ i t n e s s r e s pond- -
23 ing to the qu e s tio n, not C o un s el.
24 MR.
CIBSON:
I will not le t, du rin g 25 Discovery, a
V. i t n e s s answer que stion s tha t EVELYN BERGER ASSOCIATES. STENOTYPS REPCF1NO SERWCE. CMARLOTTE. NORTH CAROUNA
Diroet 37 A ddis 1
I don't under s tand as their Counsei, okay?
2 So would you describe what you are 3
talking a b'o u t when you use the term "why 4
didn't you b rin g those documents," w hi.c h 5
documents are you referring to, and we ca n
6 move on and get an answer.
7 8
BY MR.
GUILD:
9 Q
Wha t documents have you produced?
Mrs.
10 A d dis, I will withdraw the que s tion.
11 MR. GIBSON:
Okay.
12 THE WIT N E S S :
T he s e are my docu-13 ments here (in dic a tin g ).
14 15 BY MR.
G UILD:
16 Q
What are they ?
17 A
Each folder relating to the w ei din g c o n c e r ns 18 and the summary inf o r ma tion which I presented.
Tha t 19 is the inf o r ma tio n here.
20 0
In the bound document?
21 A
Yes.
22 O
And there are two separate stacks of docu-23 ments that are c li p p e d together, and what are those?
24 A
These were co pie s of letters that Mr.
Lee 's 25 s ec re tary sent me concerning his dis po sition at EVELYN BERGER ASSOctATES. STENOTYPE REPORTING SERvtCE. CMARLOTTE. NORTH CAROUNA
Direct 38 A ddis
~
1 Step T h~r e e.
2 Q
Did you b rin g. with you the M ana ge me nt 3
Procedure Manual that d e s c rib e s th e. re cour s e proco-4 dure ?
5 A
No.
- 12 I did n' t.
6 Q
Is that t he written d e s c ription of the recours e 7
procedure that those files r e fle c t ?
general outline as amended.
8 A
Yes, it is a 9
Q Lo you have a copy of that manual in your 10 po s s e s sion ?
11 A
I have one in my offic e.
12 Q
So you could have brought it with you?
13 A
Mad I known that it was r ele va nt.
14 MR.
GUILD:
C oun s el, I would suggesit 15 that ifwe could get a copy of tha t documen t 16 it might be helpful now.
17 MR.
GIBSON:
We will refuse to do obj ection earlie r to your 18 that.
I entered an 19 going into areas that are not within the 20 scope of D epositions at present.
21 I t ho u g ht it might be less time 22 consuming to ist her answer some of thosa 23 background qu e s tio n e.
24 If that document was not requested 25 and turned over, we do not b e li e v e it is EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
39 1
covered by her Notice of D e po sitio n, given 2
the limita tion s that have been placed on 3
ths Board's Order.
4 If you want us to get that, I will havo 5
to stop and talk with her about whether we 6
will change our po sitio n.
7 That is not a document covered by 8
the present status of the matte r.
9 MR.
GUILD:
Mr.
- Gibson, we can 10 avoid this g ame s man s hip--
11 MR.
GIBSON:
This is not game s man-12 ship.
13 MR.
GUILD:
Excuse m e, sir; we hav e
14 a s pe cific que s tion that talks about employ ee 15 recourse procedure.
16 MR.
GI3 SON:
Have you asked for it ?
17 MR.
GUILD:
- Sir, I' m a sking fo r it now.
If that procedure that she is de-I8 l
s cribing is r e fl e c t e d in a document, that 19 20 do c um en t, in my judgment, should have 21 been produced.
l 22 If it ha sn't, C oun s el, we can take that up with the Board.
The Witne s s said l
23 24 she ha s the manual in her possession.
l 25 I contend she was gi con the N otic e EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAROUNA
[
,4 0 I
that documents that were r elevant to her 2
te s timony should have been produced.
3 She has n o't produced it.
Notwithstand 4
ing that, I w o uld ask that she make that 5
document available so we can proceed in a 6
timely f ashion so we can s ee what it pro-7 vides with regard to the e mplo ye e recourse 8
procedure.
9 MR.
GIBSON:
Mr.
G uild, since we 10 are now at 12:15 and the n or mal lunch houn 11 is 12:15 to 1:15, we break now and upon 12 returning, I will let you know af ter ana-13 lyzing that p o sitio n, and we can re sume 14 her D epo sition approximately one hour from 15 the ti :n a we a dj ou r n.
16 Sc we do not have to have an adjourn 17 ment tim e,
we will let you know as soon a s
18 we r e tu r n.
19 Are you aware of any other documenta 20 you take that--
21 MR.
GUILD:
C oun s el, I would ask if 22 she was awars of any other document s 23 needed in order to have a fair and fuli 24 explanation of h sr involvement in this 3
subject.
EVELYN SERGER ASSOCIATES. STENcTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
41 1
I will ask that she he reque sted to 2
produce the m.
MR.
GI3 SON:
Why do n' t.you go th ro u g h-o.
3 4
MR.
GUILD:
If you have a que s tion 5
for clarification, plea s e--
6 THE W IT N E S S :
I guess when I got 7
th e No tice then to some extent it was was relevant to th e Catawba 8
judgment what 9
welding situation, which I did produce.
10 11 BY MR.
GUILD:
12 O
- Yes, ma'am; it would be helpful to me 13 if we have reference to a s p ecific procedure that you have referred to several time s now, and what 14 15 the procedure refers to, if instead of you having to 16 paraphrase or try to r e c olle ct or me pr e s umin g that 17 the document says s om e thing that it may not, if wo 18 had that manual in front of us so we would have no que s tion s or mis unde r s tand1a g, I wou ask if over 19 a copy of that 20 the luncheon recess you could produce Management Procedures M a n u a l.
21 22 MR. GIBSON:
I will discusa this durin g 23 the lunch hour.
We will make a deter-94 min ation whether we will produce it.
25 W e will r e sume ths D epo sition a pproxi-EVFLYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA
42 1
ma t ely one hour from the time we adjourn 2
here and take up the matter again at that 3
point.
4 MR.
GUILD:
- Yes, all right, so we 5
are breaking for lunch for a n hou r.
6 MR.
GIBSON:
- Sure, what time do we 7
have now?
8 MR.
GUILD:
We have 12:25, 9
(Whereupon, the D e p o s ition 10 adjourned for a luncheon recess at 11 12:25 and resumed at 1: 41 p. m. )
12 13 MR.
GIBSON:
Prior to the lunch 14 break we were o bj e c tin g to and dif f e rin g 15 with you in te rm s of your inter pretation 16 of which documents should be made avail-17 able.
18 We have decided to give you a docu-19 ment entitled.
E mnloye e R e cour s e 20 Procedure, which I b eli e v e is the document 21 M s.
A ddis was d e s c ribin g as s etting forth 22 the various steps of the recou rs e procedur<s.
23 we are doing this in the interest of 24 trying t o move t hi n g s along and 13sssa the 25 number of it e m s that the Board may have EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NCRTM CAROUNA
t A ddis Direct 43 1
to pick up at a later time.
2 We s tay with our p o s i ti o n t h a~t the 3
D e po s ition s are limited to welding concern s, 4
but there is the document (in di c a tin g ).
5 MR.
G UI LD :
Thank you, Mr.
Gibson.
6 7
SY MR.
GUILD:
8 Q
Does this procedure describe the recourse 9
procedure that was in effect at the time.that was 10 material to the V7 e l din g Ins p ec to r concerns?
11 A
There was an amendment made in October 12 of
'81, whic h is identified i n.t h e columns her e.
13 Q
Yes.
14 A
A nd subject to that one change, it r e fle c t s 15 the procedure then in eff ect, yes.
16 Q
Thank you.
Now with respect, as far as you know, Ms.
Addis, was the recourse procedure 17 18 followed as set out in this w ritt e n policy with r es pec :
19 to the Welding Inspectors?
29 A
The Step Two recourse process that I 21
- handled, it was.
This was f ollowe d e s pe cially with 22 regard to the time f rame s may be extended upon the 23 a g r e e me nt,
so it was f ollo w e d as writ t e n.
24 The Manager of E mploy e e Relations desig-25 nated me to handle Step Two, so there is a d e si gn a tic a EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE CHARLOTTE. NORTH CAmouNA
Diroct 44 A ddis I
mark there.
2 Q
Who is th e Manager of Employee R ela tio n a l 3
A T.
F.
M c C r a c ken.
4 Q
Is it Mr.,
M s. ?
5 A
Mtster.
6 O
Was Mr. Mc Cracke n ~in that position at the 7
ti me of these concerns?
8 A
Yes.
9 Q
Do you report to him ?
10 A
T hat 's c or r act.
11 Q
W ha t was his involvement in proces sing 12 these e m plo y e e recourses?
13 A
He was not involved.
14 C
All ri gh t.
Ms. A ddis,
you did have an 15 opportunity to not only review the Step One recourses.
16 but you had co pie s of all of Step One recourse docu-17 ments f o rwa r d e d to you; didn't you?
18 A
No.
19 Q
You did not?
20 A
I read through them with the QA person.
21 O
Let me show you a document that is a 22 November 6,
'81, letter (indicating).
Is that your U
signature on it?
24 A
That's correct.
25 O
What does it r efle c t at the b ot o m of that EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERV CE. CNARLOTTE. NORTN CAROUNA
l Direct 45 A d dio 1
lett er ?
2 A
-I asked Bill to share with me the records 3
from St'ep One and the service records.
4 Q
"Please send copies of the. correspondence 5
and records of Step One as w ell as the e mplo ye e 6
s ervic e re co rd s," als o the e m ploye e s f o rwa r d a copy 7
of s ervice po sition s analysis for this position.
8 Did M r.
B r a dle y do that ?
9 A
I reviewed those do cume nt s with Pill.
He 10 did share them with me.
It is my recollection that 11 I went to him because of the volume.
12 O
You asked him to send copies of it to you; 13 didn't you?
14 A
Yes.
15 O
A nd he did not send th em ?
l 16 A
T hi s is a le tt e r related to one f ellow.
{
17 Q
There are others, they a ll say--
l 18 A
What I did was r e vi e w tho s e with him l
19 because of the volume of them; and I left them with l
M that department.
l l
21 O
You asked him to send copies in all of the l
22 in stanc e s ?
We can go through a numbe r of the other a, you s aid, "Please send c ople s of corres pond enc e. "
23 24 A
I was aware of Step One.
M Q
Did you get copies?
EVELYN BE8h3ER ASSOctATES. STENOTYPS REPORTING SERVICE. CMARLOTTE. NORTH CAROJNA
A ddi s Diroet 46 1
A I don't have the m; I reviewe d the m with 2
Bill B radley,
'3 O
He did' no t send.you th o s e co pie s ?
4 A
I don't remember g e ttin g th e m, per s e.
5 I didn't keep the m.
6 MR.
GUILD:
We will take a break
-7 for a second.
8 (Whereupon, the D e po sition 9
recessed at 1:48 p.m.
and was resum ed to at 1:53 p.m.)
11 12 BY M R.
GUILD:
13 O
You just don't r e c all whether or not you 14 actually had those Step One do cument s in your 15 po s s e s sion ?
16 A
I had them in my h a'n d s, but they had been 17 returned to Cuality C ontrol.
18 O
They have been returned ?
19 A
I didn't keep the m.
20 0
Is th at consistent with th e recourse pro-21 cedure f or y ou to. re view the Step One d oc um e nt s ?
22 A
O h, sure.
23 O
Why wouldn't you tell the complaining 24 e mploye e that you were goins to r e vi ew the Step One ?
25 Why is it a message that is not reflected in the actu al EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
Addis Diroot 47 1
. letter sent to the employee instead of blind copies to 2
M r.
B radley ?
3 A
Per sonal choice; each employee is well 4
aware that it is a s e qu e ntial process, the concerns 5
they present at Step One are the ones they present
.6 at S tep Two.
7 Q
And you reviewed th e file f rom Step One 8
in r e a c hin g your r e c o mmen da tion ?
9 A
Sure.
10 Q
What is a Corporate Pe r s onnel Employe e 11 Relations Report ?
12 A
I write several, so I' m not sure what you 13 m e a n.
14 O
A ll right, I have a document that is 15 entitled, " Summary for Task Force Appointed to 16 In ve s tig at e Alle ga tion s by GC Inspectors," dated l
17 12/10/81; and it has the initials W-H-0, Warren Owen
?
18 A
Po s sibly.
19 Q
Is that his initials.
Warren H.
Owen ?
20 A
Those are his initials, yes.
21 Q
Have you seen that document bef ore ?
22 A
I did not receive a copy of this.
23 Q
S ut have you seen it is the que s tio n ?
24 A
1 don't re me mbe r reading this, no.
I see 25 my name, is that what you are referring to?
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Addis Direct 48 9
1 O
- Yes, I'm asking you'if you recognize the 2
document; and your answer is you don't ?
3 A
I didn i t get this, n o.
l 4
O A ll right now, Page Three of the document
~
5 second paragraph before the end of th e --I' m sorry--
l 6
third pa ra gr aph.bef o re the end of the fi r s t part, just 7
before the second part begins that is entitled, "The l
8 Task Force."
i 9
Would you read that paragraph for the 10
- Record, Vs.
A ddis, please?
11 A
- Yes, "A
number of inspectors started, in 12 deciding to use the employee recourse procedure, to la que s tion the pay a dju s tm ent s.
See th e Corporate 14 P e r so nnel Employee R ela tion s R epo rt for d e tail s. "
15 O
That is that Corporate P e r s onn el E m plo y e o 16 R elation s Report that is referenced there; do you kno r?
17 A
Not for sure.
l 18 O
What do you think it is?
i l
19 A
The only Employee R ela tio ns Report that l
20 I' m aware of that I generated ar e the documents that you have, the brown folder.
21 I
22 O
Yes?
23 A
That is it.
24 Q
A ll right now, at th e front of that folder 3
that is r e fle c t e d in th e copy I hav-here is a docu-EVFLYN BERGER ASSOCIATES. STENOTYPE REPORTING SERysCE, CHARLOTTE, NORTH CAROUNA
Direct 49 A d dic 1
ment of four pages that is haaded, "In d o c t rin a tion, "
2 and is that your work?
3 A
Yes.
4 O
And thi's was written for whom ?
5 A
Step Three in the recourse procedure.
6 C
For N' r.
Lee?
7 A
Yes.
8 O
Is that the report that you had reference 9
to as possibly the reference in the O we n's s umm a ry ?
10 A
T hi s is the r e po rt.
11 O
There are, of course, a number of docu-12 ment s that are included in th e r e; but is the r e any-13 thin g else in there that represents your work, your 14 analysis or your report, if I can use that word?
15 A
There is a m emo that I wrote dated 16 October 7,
'81.
17 C
- Yes, ma'am, I see that.
To whom is that 18 addressed?
19 A
Jim W ell s and Bill B r a dle y.
Here is a 20 December 3,
'81, letter.
l 21 Q
- Yes, to who m ?
22 A
War r en Owen.
l l
M C
Yes.
l 24 A
Those are the only ones in the book that I 25 wrote or reported.
l EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE, NORTM CAROUNA
l A ddis. - Direct 30 1
C Are there any other reports that you m ad e 2
on this subject, Ms. Addis ?
3 A
(The Witne s s shook her head ne g a tiv ely. )
4 O
When did you interview the C at awba V'eldin g 5
Inspectors, Ms.
Addis ?
6 A
There were several dates tha t I--th e r e wer e 7
diff e r e nt e mploy e e s on diff e rent dates.
8 O
- Yes, ma'am, the December 31 re po r t s,
the 9
dates set forth next to those dates, is that the date 10 that you interviewed the m ?
11 A
- Yes, they were interviewed more than onco 12 and so there were dates other than tho s e indicated 13 and other people.
14 C
First the mor e than once, each of these l
15 people would have been interviewed on dates other l
16 than what is act forth here?
17 A
They may have.
18 C
May have; and there were others beyond 19 those referenced here, beyond the na me s set fo rth ?
20 A
I think this is fairly inclusive, but there 21 may have been; yes.
M Q
A ll right.
U A
All of the people in the front of this book 24 look like the C stawba name s were int e r vi e w e d.
25 C
In cludin g the handwritten names in the fro nt i
EVELYN SERGER ASSOCIATES. STENOTYPE RSPORTING SSRveCE. CHARLOTTE. NORTH CAROUNA I
Addis Direct 51 I
as well ?
2 A
I pe r s o nally inte r vie we d the typed na me s.
3 O
A ll right.
4 A
And any other of the gentlemen that I had 5
quoted in the December period.
6 Q
You interviewed the one s you had quoted 7
in the D e c e mb e r report?
8 A
(The Witne s s nodded her head affirmatively.)
9 Q
Now I s how you a letter dated November 19 10
- 1981, from you appar ently to hi r.
John R.
Bryant.
11 Can you identify that?
12 A
Uh huh.
13 Q
That again was from the file produced this 14 morning; is that simply r e pr e s enta tiv e of similar or 15 the same c o mm u ni c a ti o n sent to Vielding Inspectors is upon your receipt of the Step Two recourse?
17 A
No.
18 Q
No?
19 A
T hi s was not a recourse request.
20 Q
Can you explain that to me?
21 A
Ac I explained to Mr.
3ryant, we under-22 s tood he was expressing a concern rather than a s kin s 1
23 for a r e vi e w through the recou rs e procedure, 24 Q
w hat was the concern that hi r.
Eryant l
25 expressed?
l l
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SSRWCE. CHARLOTTE. NORTH CAROLINA
Addis Direct 52 1
A As it states, concern about the pay grade 2
of the W eldin g Intpectors.
3 Q
In'what f o r m 'di d Mr. Bryant's concern get 4
expressed to you?
5 A
It was in a le tt e r, November 3rd lett e r 6
just outlining co nc ern about the pay grade, but not 7
using the recour s e procedure.
8 Q
How is it di s tinc t,
if it was, from the 9
recourses or the c o mplaint s or concerns expressed to by the others?
11 A
Mr.
3ryant had no personal concern with 12 regard to hi s. pay r a te.
He was s t a tin g a position 13 and o pinio n.
14 a
I..,
15 A
To the best of my m e mo ry.
16 Q
A li right, and did the others explicitly 17 say that they were invoking the recourse procedure 7 18 A
y,,,
19 Q
You know, f o r mally they used the term wo 1
are invoking the Step Two of the recourse procedure?
21 a
Most of their le t t e r s s tated that.
They 22 all stated it to me at Step Two.
23 O
A nd Mr.
- Gryant, by contrast, did not say 24 he was invoking the. recourse procedure?
25 A
T ha t 's
- correct, and that was my impres sic a
EVELYN SERGER ASSOctATES. STENOTYPE REPORTING SERVICE. CNARLOTTE. NORTM CAROUNA
Direct 53 Addis 1
in r e s pons e-to hi m.
2 O
Did M r.
Bryant respond to you af ter 3
r ec eiving this letter ?
4 A
I don't re member him responding at a l'1.
5 Q
?,ow, Ms.
A d dis,
there is a t t a c iz e d to a 6
stack of documents that in c lu d e the lett er s that you 7
wrote to va riou s W elding Inspectors inf or min g the m 8
of you r receipt of the St ep ' Two recourse request 9
and your delegation of r e s p on s ibilit y for pursuing 10
- that, are a nu mb e r of pages of handwritten notes.
11 Can you identify that handwriting ?
12 A
This is min e.
l 13 Q
What are th o s e notes, and I am looking at 14 one in p a r ti cula r, but th e r e are several lik e that?
15 Can you tell us what the c i r c u m s t a n,c e s were?
16 A
On this p a rtic ula r page?
17 Q
- Yes, let's take that one.
The le tt e r that 18 appears in front of that is to whom?
19 A
T hi s is to Mr.
Peeler.
l 20 O
A nd it is dated what?
21 A
November 6,
'81.
22 Q
A nd what is the handwritten note that 23 follow s ?
24 A
T hi s is regarding diff e r ent men.
25 O
Oh, it is ? Okay, what are the h a n dw ri tt e n EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAmouMA
s A ddis Direct 34 1
notes that 'f oll o w that?
summa ry of the 2
A These are b a s ic all y a
3 dialog between this man and my s elf.
4 Q
A summary of your review?
5 A
It is more of a dialog.
6 C
A 'r e there notes r e fl e c tin g your dialo g or 7
interview or m e e tin g with each of the Step Two 8
recourse or W elding In spector s ?
9 A
There is some notation u s u all y.
10 Q
Are there in this instance, Ms. A ddis ; can 11 you t ell ?
12 A
On every one th a t would.be. r efle cted in the 13 documents, it is my unde r s tanding that there are.
14 O
All ri ght, thank you.
Were there tran-15 s c riptio n s made of the dialogs, interviews, me e ting s 16 th a t you had with the Felding Inspectors?
17 A
Do you mean lik e typed?
18 O
E l e c t ro n i c,
any sort?
19 A
My own notes which I read back to the m 20 for ve rtific a tio n of u n d e r s ta n din g.
21 O
Those are notes attached here?
5 A
T ypic ally.
23 C
A re there o the r s ?
24 A
No.
25 O
Let me see if I can f ollo w this, m a'am.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLUTTE. NORTH CAROUNA
A ddis Direct 55 1
L et 's turn to your December 3rd,
- 1981, memo to Mr.
2 Owen.
3 Now you placed, let's say for Mr. Surr, 4
he is the fir s t one on th e list, there are quotation 5
marks placed around your de s c ription of your dialog 6
with Mr.
Burr.
j 7
W ha t do you m e a n, what do you intend when 8
you use quotation ma rks ?
9 A
To represent what I heard him saying to 10 me.
11 Q
It is intended to be a verbatim r efle c tion 12 of what he told you?
13 A
.As clo s e as I can get it, whi c h was read 14 back to him.
15 C
Now then, le t's see if you can help me 16 fi n d the notes in here r e fl e c tin g your me e ting with 17 Mr.
Surr.
18 MR.
GIBSON:
Mr.
G uil d, why don't 19 we pull the file over here, which you 20 should have a copy o f.
21 It might speed things up so we can 22 look at the individuals instead of thumbing 23 through.
24 MR.
GUILD:
Your method is quicker 5
than mine.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA Le
56 A ddin Dirnet 1
THE W I T N E '15 :
Okay.
2 3
BY M R.
GUILD:
4 Q
N ow I'm l o o kin g at a one-page set of hand-5 written note s; and let me s h o w 'you. min e (in di ca tin g).
6 Are those your notes of your meeting with Mr.
Burr?
7 A
Yes.
8 Q
That is 11 / 2 3.
Now on your report to Mr.
9 Owen you indicated 11/24 Would there have been an 10 11 / 2 4 m e e tin g with
.M r.
Burr?
11 A
N o, it w ould have been a three o r four.
12 I don't know why it varies.
13 Q
Might there have been a second day me e tin g 14 with Mr.
Surr?
15 A
It would have been in here.
16 Q
So it is likely just an error in the day?
17 A
(The Witne s s nodded her head a f fir m a tively.)
18 O
- Okay, that is fin e,
if you help me find in your notes here the text which you then reproduced 19 20 in your report t o M r.
Owen.
21 A
Okay, the fi r s t document.
"We have had 22 craft people ecme in that c an't read the blu e p rint s 23 and paperwork p r oble m s appear to be the major 24 function. "
25 My major problem there is s om e thin g that EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
Diroct 57 A ddis I
he told me.
2 O
Yes?
3
'A "I've had to face f e e li n g.... "
This little 4
square right here (indicating).
5' Q
Yes.
6 A
That is ba sic ally what he was talking about 7
in the s econd para graph.,
8 Q
A ll right, and this note is the basis for 9
th e tr an s c ription that appears on your memo to Mr.
10 Owe n ?
11 A
- Yes, this whole sheet; the em plo ye e s have 12 requested that e s s entially their po sitio n s be presented 13 or their concerns of any type, and they were aware 14 that they would be.
15 O
And then explain to me, you would read it 16 back to them and make sure you had it accurately 17 quoted ?
18 A
I would su mma ri s e when I finished.
W.t a t 19 I did not restate in this pa r tic ula r statement was l
20 obviously the primary concern, why he was there, 21 was the pay grade recourse, which I mentioned earti ar.
22 O
Try to understand, Ms.
A d di s,
in the box 23 up there, "Is what you have stated more important 24 than $7 I have had to face f e elin g like I would be 25 fi r e d in order to see that work would be done ri g ht, '
EVELYN SERGER ASSOCIATdS. STENOTYPE REPORTING SERV CE. CHARLOTTE. NORTM CAROUNA
,______.,_._.-....c__.
l Diroct 58 Addis 1
etc.
2 A
And als o where he said, "The p ri m e c o n'-
3 corn is the pay procese," so that is the subj ec t of 4
his recourse.
5 O
Where is that now ?
6 A
Right here (indic a tin g),
i i
7 O
" Internal comparison plus c o mp aris on to 8
Daniel and Union Shop," did M r.
Burr or the other 9
W eldin g Inspectors, were they shown the in s e rt s that 10 you reported to Mr.
Owen and asked whether that wa n 11 an accurate r e fl e c tio n of their concerns?
12 A
Not af te r they were typed.
13 O
All right, there are no other notes that 14 were taken or other t r a n s c ri pti on s made of tho s e 15 gag,,,g.,,y I
16 A
N o, this is it.
17 Q
Did anyone else participate with you in 18 in t e r vi e wi n g those W eldin g Inspectors or meeting with 19 them?
20 A
M r.
W e lls talked with some of them.
21 O
A nd did you sit in when Mr.
W ells talked 22 with them?
23 A
No, I didn't.
24 O
Do you know what the product was of his 25 interviews or meetin g with the m ?
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVCE. CHARLOTTE. NORTH CAROUNA
-. _ _ = -.
l Direct 59 Addis 1
A 1' understand th at he o utlin e d his concerns,
~
2 his manag ement~ also, as I did or the emplo ye e s '
3 concerns and his.
4 O
Did Mr. W ells keep notes of his in t e r vie w s ?
5 A
I don't know.
6 O
Did M r.
W ells transcribe his interviews ?
7 A
I don't know.
8 O
You have never seen any notes or tran-9 s c ription s of his m e e tin g s with the inspectors?
10 A
There is a memo that he wrote o utlinin g 11 the concerns as he understood them.
12 O
R i g ht,
can you help me identif y tha t.mo re 13 s pe cific ally ?
Is that contained in--
14 A
L e t 's look.
No, I g u. s s' it is not in my 15
- report, but there,is a Jim W ell s' n o t e because wo 16 were working and the men unde r s tood that and agreed 17 because the concern about the pay grade was so 18 g e n e r a li z e d that they all had it.
19 But I don't have his s pe cific report in my 20 stuff.
21 O
A nd who was his report to; do you r e call ?
A No his supervisor was Warren Owen.
23 Q
Likely to Mr.
Owen then?
24 A
(The Witn e s s nodded her head af fir m a tively. }
25 O
On what basis did you and Mr.
W ell s divid o 1
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CNARLOTTE. NORTM CAROUNA
A ddis.- Diroct 60 1
up your tasks or your r e s p on s ibiliti e s in me e tin g wit h 2
the ins pectors ?
3 A
There was r e a ll y no a pecific s elec tio n 4
about who would meet with who m.
It was more a 5
matter o f ' t'i mi n g in being able to respond to the 6
e mploye e s in a time period.
7 O
Can you give me a rough idea of how you 8
divided up the work, who got what and how many he 9
did and you did ?
10 A
On the days we both visited C a t a wb a, I
11 think we each saw approximately six people.
12 O
How many days did you s'p e n d doing that?
13 A
We were at Catawba at least one day that 14 Jim was there, and I was there ind e p en de ntly at 15 least one other ti me.
16 O
One other time ?
17 A
Or more.
18 Q
You just c an 't remember ?
19 A
I can look on the dates in the file s,
but
(
20 o the r than that I r eally can't remember s pe cific ally.
21 O
Le t's look at those, this is your report 22 to Mr.
- Owen, December 3rd report ( L adic a tis g) ?
23 A
(The Witne s s nodded her head affirmatively.)
4' 24 O
And there were several that li s t the 24th 25 of N o ve mb e r t is that one of the days that you were i
.... _ m.
A ddio Dir'ect 61 1
there at C a t awb a.i n t e r vi e win g.?
2 A
Oh,
- yes, the 23rd and 24th.
3 Q
On the third page we have the 23rd;,were 4
you.there that day as we ll ?
5 A
- Yes, that or we transposed the 23rd and
'6 24th; and I would have to check to be sure.
7 Q
A ll right, then there is an indication that 8
you met with M r.
Rockholt on Page Four, it shows 9
11 / 9 / 81.
W o uld that have been the date that you met to with him at Catawba ?
11 A
Yes, unless we typewrote it wrong; yes, 12 that is my record.
13 O
And you also interviewed on some dif f e r ent 14 days workers at Oconee; is that right?
15 A
T ha t 's right.
16 O
Is it fair to say that the Oconee W el din g 17 In spe c to r s had s imila r complaints to the C a t a wb a 18 Welding Inspectors?
19 A
The recourses about the pay grades were 20 facts s imila r.
21 MR.
GIBSON:
We would object to any 22 further qu e s tion s about Oconee since it is 23 clea rly not within the scope of the s e i
24 D e po s ition s at this point.
25 MR.
GUILD:
C ou n s el, my intent is SVELYN SENGER ASSOCIATES. STENOTYPE RSPORTING SERV'.CE. CHARLOTTE. NORTH CAROUNA
c----.--
62 Direct Addis not in Quality Assurance at Oconee except 1
to the extent that it relates to the subj ec t 2
3 of my inquiry which is' Ouality A s s ur ance at C a tawb a.
4 5
6 BY MR.
G UIL D :
7 Q
M s.
A d di s,
stand back f r om the detail a general de scrip g
little bit, and if you can, give me a e
9 tion of the process by which you determined how to 10 proceed in r e s pondin g to the Quality In spector 11 concerns that came to you, s pecific ally at the Step 12 T wo recourses?
i 13 A
The process is fairly standard.
The pro-14
- cess, it s elf, c a ll s for an individual m e e tin g with 15 any e mplo ye e s in the recourse procedure f ollo w e d by i
16 an analysis of those, any is sue s that the employee 17 may raise with the m ana g e m e nt to be sure that that 18 is understood.
19 Then th e management of the d e pa rt me nt 20 issues a decision b a si c ally af ter reviewin g the infor-21 m atio n, and we d e li v e r that to the employee at the 22 end of the Ste p Two ve rb ally.
23 O
W er e there any featurse or circumstances 24 which dis tin gui s h e d these recourses from recourses 25 that you would :. a n d l e in the nor m al course of your EWELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA
__m
Diroet 63 A ddis o
I work?
~
2 A
T hi s was handled li k e all the recourse 3
procedures are.
4 Q
N ot hin g unusual about this one?
5 A
The process of it, no.
6 Q
How about the subject of the recourses?
7 A
T ho s e vary individual by individual.
8 Q
- Yes, my que s tio n is was there anything 9
unique about the se recourses?
10 A
They are all unique; each employee pre-11 s entin g their concerns.
12 O
So your answer was there was nothing 13 unique about these?
14 A
I think the only thin g th at might have beer, i
15 s om ewhat unique in the process was the high level 18 of involvement of the management, which wa s certainl y 17 welcome because the pay issue was rather e motion al.
l 18 Q
Explain that, if you would.
What was l
l 19 dif f e r ent about the high level involvement in this l
20 case?
C om pa r a o r contrast it with another recourse 21 where the involvement would be o th e r wi s e.
5 A
The diff erence in in volv e m e n t r e all y 23 centered around the nu mbe r s.
It is unusual to have 24 that many e mplo ye e s with the same concern at once.
25 So we had departmental support, as I EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
Direct 64 A d dis I
m en ti o n e d, M r.
W ell s as sis tin g me.
2 O
How f requently do employe e s exercise the 3
employee recourse procedure?
~
4 A
C ould you clarify that?
I 5
O Y e's '.
Give me some mea sur e for compara.
6 tive purposes, c om pa r a z ation so that I can undvrstand 7
how common the exercise of an e mploye e recourse 8
procedure is at Duke.
9 A
Last year the.nu mb e r of Step Two concerns to was 23 related to Step Two, desiring to go to Step 11 Two.
12 O
C alen da r year '827 13 A
Y es'.
A p p r oxim a t ely 40 percent of recours e 14 procedures since we initiated the process in
'79, 15 have been resolved at Step Two.
16 That is fairly c on sis t e nt in this case sloo 17 Q
By that do you mean they exercised their 18 Step Two recourse and do not go beyond Step Two to 19 Step Three?
l l
M A
T ha t's correct.
21 O
How many exercised Step Three of the M
recourse last year, if you know?
23 A
Step Thre e ?
24 g
y.,
25 A
I think it was 14, 13; one h e l'd over into evetv,.......ocar.
.r. own a. o.m
.mc.. cwaatorr.. e.osm. caaou a
- ~ _ _ _. _ _. _, _ _ _ _ -. _ - -. _ - _
Diroct 65 A ddis 1
January, about 14.
2 O
Those would be people who went to the 3
President of the compa ny ?
4 A
Referred their concern that way, yes.
5 O
How many Step One recourses du rin g the 6
'la s t calendar year, if you know?
7 A
Those are handled by the departments; I 8
don't do a corporate report on those.
9 O
Do you have an e s tim a te,
r e c o g nizin g your 10 answer; can you give me a ball park f e elin g for how 11 many they would lik ely file ?
12 A
The official written recourse procedure is 13 probably two to three hundred; and the verbal pro-14
- cesses, but the department s maintain those records.
i 15 O
So two to three hundred approximately 16 would exercise the written Step One recourse pro-17
- cedure, and many more, or more, a verbal?
18 A
No, not r e ally; some of th e de pa rtment s 19 are u sin g the recour se proce s s as it is used here 20 which encourages the verbal; so I think that wo uld 21 he the total, and the written process, we would have 22 to check with the d e partme nt s to give you a definitiv e 23 answer.
\\
24 O
Les s than two to three hundred though?
l 25 A
Ch,
- yes, j
l avstyn esRoeR AssociATus. sTsNovyps REPORTING SSRVICE. CHARLOTTE. NORTH CAROUNA
A ddis Direct 66 1
C And this procedure has been in effect eine's
-~
2 the-fir s t of May, 1979?
3 A
Yes.
4 Q
W ould it be fair t o.a s s u me that there have 5
been a ppr oxim a t ely the same nu mbe rs of recourses or 6
fewer recourses for Step Two and Three and Step O n.s 7
in f o r m ally in years before 19827 8
A It is r e a lly, I think, too early to r e all y 9
tell you how it is going to p a tt e rn.
I don't know.
10 C
T hi s has been running about even?
11.
A You are talking about this year now?
12 Q
Yes.
13 A
1983 has been running about lik e 1982, yes 14 O
Take it back before that wa s what I was 15 t r yi n g to di re c t your attention to;
'79,
'80 and
'81, 16 can you give me a rough idea of the numb e r s of 17 recourses that were exercised during those time s ?
18 A
I c.a n ' t tell you s p e cifi c ally because when l
19 the system was implemented, of course, it started 20 off g r a du ally as e mplo ye e s got use to the s ys tem, so 21 tracked up th r ou gh
'81, and there have been we 22 a pp roxima tely 7 5.
23 l
C S e v e n t y-fi ve whic h step?
24 A
T ot al that had gotten to Step T wo.
M Q
Through the end of 19817 EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERYlCE CHARLOTTE. NORTM CAROLINA
\\
A ddis.- D ir ec t 67 1
A I think so.
\\
2 Q
M s.
Addis, can you tell me, if you know, 3
whethe r.or not the r e, h ad ever been a group of 4
recourses on the same or s imila r subject file d beforl:
5 at Duke Power Company?
6 A
Before the inspectors at Catawba, yes.
7 Q
W ha t wo ul d the subj e ct of that have been?
8 A
It was a pay issue.
9 Q
Can you give me the circumstances and the 10 type work involved?
11 A
Can you help me under stand what you are 12 trying to learn?
13 O
Had groups of workers file d recour s e s 14 together on the same or simila r or general subj ect?
15 A
No, it is a quite individual m att e r.
16 Q
Here you had 53 characterized as similar 17 enough to treat in the same process?
18 A
Yes.
19 Q
My que s tio n is was there any precedent?
l 20 Have you encountered this p r a c tic e bef ore ?
Have yo's 21 seen groups of e m plo ye e s exercise recourses around 22 a common problem or concern that you had treated a n j
a common problem or concern before ?
23 l
24 A
I think we had as many as seven, seven o r 25 eight over a period of time with the same conce ru.
)
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTH CAROUNA
68 A ddis Diroet 1
O
- Yes, and then take that seven or eight and
\\
2 tell me a little bit, about tha t s ubj e ct, type work a
- involved, so I can un derstand for c ompa r ative pur-4
- poses, please.
5 A
T h a t 'w a s a reduction i n' fo rc e situation
.6 and C on s t ru c tio n was the service being conc erned.
7 Q
I' m sorry.
8 A
S enior cla s sific ation s.
Senior C r af t, the 9
concern about their being denlared an excess in their 10 p o s iti on level.
11 Q
A ll right, and where were the s e worker s 12 located; whe re ware they assigned, if you r e c all ?
13 A
At various construction plants.
14 O
So they weren't all at the same project.
seven or eight were at diff e r ent places?
15 16 A
Yes, at diff erent time s.
17 Q
Dif f er ent time s and diff e re nt projects?
18 A
(The Witne s s nodded her head af fir ma tiv e 1 r.)
19 Q
Let me see if I can--I am intere sted in any othe r instance then where a group of workers who 20 were at the same project who had the same kind of 21 22 exe rcised recour s e s in the s ame time
- concerns, 23 g,,,,,
A No, I'm not awa re --I think I had maybe 24 p olic y issue 25 two or three at one place or another, a
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
A ddis Direct 59 1
at one time o r a n o th e r..
2 O
Do you mean a group with a specific kind 3
o f numb e rin g.. anything m or e than one; have you ever, 4
had more than one e mploye e jointly filin g a recourse P
5 A
No, you can't file recourses j oin tly.
6 Q
I apprecia.te your c o r r e c tin g m e; but fili n g 7
recou rs e s on the same or similar subject that you 8
recognised and treated as a common concern?
9 A
No; they are all individual cases.
10 Q
You did treat the C a t a wb a Welding Inspecta re 11 and th e r elate d Oconee Inspectors as a common con-12 corn?
(
13 A
To the extent that their concern was in I
i 14 common, which is r e fl e c t e d in their le t t e r s to u s.
15 O
This had never happened before that or a 16 simila r action by employee s had never happened before?
17 A
I have not been aware of any other situati ons 18 s imila r to this one.
19 Q
A nd how did you, what sig nific an c e did y o1a l
20 attach to this d e velo pme nt ?
l 21 A
I think as alway s,
the individual signifi-cance to the e m plo ye e and his concerns was attached l
22 i
l 23 C
No special significance ?
l l
24 A
They are all special.
's l
l 25 Q
Yes, ma'am; I appreciate that and I EVELYN SERGEft ASSOCIATES. STENOTYPE REPORTING SERvlCE. CMARLOTTE NORTH CAROLINA
.-,,,-,-n._,.._
Direct 70
.iddis 1
appreciate your trying to d'o a good job; but did you 2
attach any s pe cial significanc e to this becau 3 of its 3
unprecedented character about. a group recourse with
.4 a common concern, 53 Step One grievances?
5 Did you a ttach any s pecial s'i g ni fi c a n c e to 6
it becau s e of the common ability or the subject 7
matte r ?
8 A
I think the significance more to me was in 9
terms of coordinating and ma kin g sure each individual 10 was properly handled and recognized.
11 O
Did it present somewhat of a lo gi s tic al 12 prob.lem in response?
13 A
T hi s is true.
14 C
%as that your p rim a ry basis for treating 15 it as s i g nific a nt or unusual?
16 A
I think the primary em pha sia in t r e a tin g l
l 17 these individuais and their concerns according to I f
l guess their value and their importance and being 18 sure that they were given that consideration to whic h 19 20 they are entitled.
l 21 They are all s i g ni fic a n t.
22 C
Did you feel that the Catawba
'h e l d i n g M
Inspectors received the c o n sid e r a tion they were 24 e n ti tl e d to ?
l 25 A
To the best of my a bili t y, yes; they did EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SEWICE. CMARLOTTE. NORTM CAROWNA
i A ddis Diroct' 71 with the role that I played.
O Ms.
A d di s,
did you go to bat for the Catawba W elding In s pectors ?
A Would you d e fin e that, plea s e ?
5 i
O Sure.
Did you advockte for them; did you lj,try to urge management to redress their grievance, 7
I to do what the W eldin g Inspectors urged you to do?
a
'l you go to bat for dem?
9 I
jof A
I did what the Welding Inspectors asked 4
'l ji jme to do, w hi c h was to be sure m a ma g e m e n t under-d[ s too d their concern over their pay grade.
12 i
isl Q
Did you recommend that the Welding 4[ Inspectors get the r eli e f that they reque s t ed ?
i4 l
A What do you mean by " r eli e f" ?
15 i
O I mean they asked you very s p e cific ally ll 16 l
l 17 for s pe cific r elief s; did they not?
l 18 A
They were c o n ve yi n g a message to manage-19
- ment, not to me.
20 O
- Yes, and did you make a r ec o mm e nd a tion 21. that the requests that they made of management be l
l granted?
22 23 A
I did not make a wage and salary l
24 r e c omm e n d a tio n, that is reserved for the wage and
'l 25 ! salary profesalonals.
LYNN B.
GILLI A M STENCGR AP>e REPCRTER
A ddis C ir o c t 72 i
2 i C
Is your answer no?
l 3
A My answer is no, nor did I not recommend.
4 O
R ec omm enda tion s that individual le tt' r s e
5 he sent explaining again how their pay was deter-mined for this year a nd that it is an accurate l reflection of inpersonal equity and e.t t e r n a l compen.
8 s ation; so you did not do anything more than I recommen d that they c o nfir m the decision that had I
already been made, perhaps in a more elaborate i
11
!jway?
l A
My intent in my communication and my 12 13 in te r e st aspect is what is behind that, not the wage i
l' and salary q ue s tio n, per se, which is made by the 15 wage and salary p e o ple.
l C
Is that a way of explaining that you l
17 l
wanted them to f e e l b ett e r about g e t ti n g turned down?
I 18 l
A No, it isn't.
C Help me understand what your role was i f 20 it wa s n' t to make a recommendation or try to either say you are wrong, W eldin g In spec to r s; or you are 22 right and I'll see what I can do to get them to 23 change their minds.
24 What was your role, h" s.
A ddi e, if I can 25 und er s ta nd ?
f LYNN B.
GILLI AM STENOGR APM REPORTER t
I ! A ddis Liroct 73
~
2 A
My role is to be sure at that time c om m unic a tio n s between the individuals involved is 4*
as good as it can be, not always that agreement is 5
always reached, but that u nd e r s t a ndin g is reached.
6 O
W hy do you think the Vl e i d i n g Inspectors t i
7 expressed the concerns that they did?
8 A
Vhich concerns?
9 O
Take c olle c tiv ely e ve r ythin g that was 10 brought to you?
11 A
It is difficult for me to remember every.
12 thi n g that they said, the recourse that was brought 13 !ld to me in Ste p Two concerned the pay grade adjust-14
- ment, the lowering of the pay grade for the l
15 W elding Inspectors.
i C
Why the y did that is because they dis-j 17 l
agreed with that decision, according to what the y l
18 told me?
19 A
Yes.
20 O
- Now, the W eldin g Inspectors b r ou ght to 21 you much more than sim ply a complaint a bo ut the 22 l
l pay grade r e cla s si fic a tion; did they not, Ms.
A ddi s :?
l 23 A
Some in di vid u al s expressed v a r yi n g 24 o pinio n s, ra tionale s behind tha t; but it was the pay 25 i grade issue that they brought me.
LYNN B.
GILLI A M l
STENOGR APH REPORTER Hl i
}l 1
$ddis Direct 74 O
They also brought you c o m plaint s about the ef f e ctivene s s with whic h t h e y, w e r e able to do 3
their work, 'did they not?
4 A
The concerns presented to me had to do 5
[with the pay grades and why dif f e r ent ones of them 6
felt that the pay grade decision was not e quit a b le.
7 C
A re you t e llin g me that th e y did not 8
9 C om plain about the ef f ec tiv ene s s of Quality A s eurance io at the Catawba Plant?
nl A
No, I told you wha t I m e a n t.
l O
Your own report to Mr.
Owen b elie s your 12 13 c ha ra c te ri z a tion of their c o m plaint to you as li mi t e d l
14 soley to c om plain t s about pay.
15 MR.
GIBSON:
Object to the form 16 of the s ta te me nt.
Is that a que s tion ?
I ld 17 '
I'm o bj e c tin g to the form of that state-la ment.
19 If you have a que s tion, go ahead a n c; l
20 ask it.
21 22 BY MR.
GUILD:
23 Q
Isn't it true, le t's look at your 2#
' D ec embe r 3rd report to Mr.
Owen.
l 25 A
Okay.
LYNN B. GILLI AM STENOGRAPH REPORTER
c 1IA ddio Direct 75 O
"I' v e had to face f eelin g li k e I would be 2
Iire d in order to see that the work was done ri g h t, 't 3
f 1
is the fir s t one li s t e d the r e.
4 Y u wrote that; d i d n~' t you?
5 i
A I had that typed.
6 l
I Q
That is what he told you: correct?
7 I
A That is what he said.
a I
Q Does that have to do wit h pay?
jo A
The entire dis cu s sio n with these gentle-n' men was centered around their recourse for pay.
t 12 Q
W a s n' t what Mr.
Burr t e llin g you had m or e 13 to do with the substance of his work?
14 A
The context of the entire c onv e r s a tio n 15 was over th e pay grade recourse.
l 16 O
- Yes, ma'am; but Mr.
Burr is t e lli n g you 17 that he is f eelin g like he would be fired if he did
(
18 his work ri g h t.
l' A
Mr.
B u r r's s ta t e m e n t, to the best of my a bilit y,
is restated here for Mr.
Owen.
It is not 20 s om et hin g that I pass j ud gm e nt o n, if that is what 21 22 you are w ond e ri n g.
23 Q
Why didn't you?
A My f unc tion at that point in ti m e was to 24 get the in f o rrn ation tha t the e m ploy e e wanted the 25 LYNN B. GILLI AM STENOGRAPH REPORTER
fi 1
A ddis Diroct 76
~
company to consider about his pay grade f rom him 2
to the appropriate ma na g e m e nt.
3 That is ' what I said here.
4 I
5 I O
~ B 'u t that doesn't have anything to do with
!, pay grades, does it, Ms.
Addis ?
6 I
7 /
A The e n ti r e discussion we had centered a
around the pay grade of these gentlemen.
9 O
- Yes, ma ' a m; what I' m trying to under-to s tand is this, I mean the document will speak for n
it it s elf--on the one hand you've told me that their l
12 only concern was the pay, and that is what your ti il 13 in vo lv e me nt was, was to pass on this concern about
]1
, pay; is that right?
14 l
15 A
A ll of the concerns that the e m ploye e s l
l were passed on.
T he entire context of our 16 l r ais ed 17 discussion had to do with that.
Is I brought the information back to manage.
ment.
2o Q
- Yes, and you included, I'm not c ri ti c i z i n.g l
21 y,,,
y,m asking you, you included a s p e cific concern 22 that interpreted as a pay concern; and you 23 communicated that.
That is good.
i i
94 A
When I presented th at informatio, hat I had learned to Mr.
Owen at his request, these LYNN B.
GILLI A M STENOGR APM REPORTER l
l'
[A d di s Diroct 77 i
s ta t e m e nt s were w ri tt e n.
O A ll ri ght, le t's see if we can back up a second.
All. of the recourses, the Step Two recourses that came to you expressly s ta t e d t he. pay 5
r e cla s sific a tio n ~
the basis f o r their recourse?
as 6
A T ha t 's correct.
7 O
They wa nt e d that decision undone, didn't a
9 they ?
A They wanted the company to look at that io d
'd e ci sion again.
n 12 O
They all asked s p e cific ally to undo the 13 P 8Y. c la s s ifi c a ti o n ?
14 A
Very many of them asked that the decision is be r e vi e w e d.
l 16 Q
But I don't want to mince words.
You t h e'y had been re cla s sified 17 agree their pr oble m was way that they thought adversely eff e cte d th eir is in a pay; and they wanted their pay and they wanted Duke 19 20 power to change that decision so they wouldn't be 21 adversely effected?
22 They wanted a change, didn't they?
l A
They asked me what will you do in this 23 24 pro c e s s --a s k the management to look at this 25 decision again.
LYNN B.
GILLI AM STENOGR APH REPORTER
l A ddi s. - Direct 78' 1
i I
2 O
But they did want the pay i's s u e ; they 3
want e d the pay decision to be changed.
4 A
W hat they have asked for is here, Mr.
5 G uild, in their own letters.
6 O
.Y e s,
ma ' a m, and we can go back through 7
all of the m a g ain.
8 A
If you need to.
O No, ma'am; if you need to.
I see them i
I
'O asking them f o r the company to change its decision i
to r e cla s sif y the pay.
12 MR.
GIBSON:
Are you referring to i
'3 i
a s pe cific docum ent ?
l MR.
GUILD:
We can go through l#
'S O
each one of them.
L MR.
GIBSON:
You are drawing a f
'7 l
conclusion that she dif f e r s with.
MR.
GUILD:
If she dif f e r s I wish 19 she would say so.
I am trying to get a 20 l
clear answe r to what I thought was a 21 pretty clear que s tion.
22 THE WITNESS:
Many of them asked i
23 l
l that the decision be r e vi ew e d, that the l
24 1etter be given co n s ide r a tion.
25 "I
sincerely hope vou will give th e LYNN S. GILLI A M STENCCRAPM REPORTER
W 1
A ddio Direct 79 matte r your deepest c on sid e r ation. "
Mr.
- Burr, that is what he asked for and that 3
is what he got.
5 BY MR.
GUILD:
O
- Yes, okay; in the context of bringing that 7
concern about the pay readjustment to you, the l
W eldin g In s p e c to rs, many of the Welding Inspectors 9
also rai s e d qu e s tio ns c onc e rnin g wo rk quality and io the r elation ship with C raf t; did they
- r. o t ?
n I
A Yes.
12 p d
Q And those were not s p e cifi c ally pay 13 b
I i
14
- concerns, were th ey ?
i is A
The e ntir e conversation with these people l althou gh these matters do concern the December 3rd 16 fmemo, were q u a li t y r ela tio n s hi p s and c o m m unic a ti on,s.
17 I
l la In my judgment those are my words, and 19 I am not qu ali fi e d r e ally to make q u a li t y kin d s of 20 s ta t em e nt s.
l Those discussions were the basis for 21 22 these gentlemen p r e s en tin g to management through 23 me why they thought their pay should be dif f e r e nt l
24 in relation to other people.
25 O
A ll right, did M r.
Owen ask you 1
LYNN B.
GILLI A M j
S*ENOGRAPH REPORTER i
,.,,.,---..--n_,-.--
i Direct 80 1
A ddis 2
.s pe cific ally to report on the non-pay concerns that wer e.rais ed to you in these in t e r vi e w s with the 3
4 W eldin g Ins pec to r s ?
5 A
- Yes, he did.
6 O
How did he do that?
7 A
We met, it was either the 2nd or the 3rdo 8
s ho rtly before'I wrote this memo, probably during 9
the same day and outlining the e n ti r e feedback to 10
- him, he asked that this be o u tlin e d for him.
l 11 Q
What was M r.-
Owen's role in the process
- 12 ing of the Step Two recourse, Ms.
A ddis ?
13 A
As Mr.
W ells ' s up e r vi s o r,
he was involved 14 in it as was M 'r. W e ll s.
15 Q
Mr.
w ells was the department head whose decision on the employee recourse, according to the 16 procedure, was the decision on the Step Two?
II Is A
The department head.
Q And in this case it was Mr.
W e ll e,
and 2
he had the authority to resolve Step Two of the 21 recourse?
22 A
- Yes, he did.
23 O
How did M r.
Owen become involved?
24 A
He is his supervisor.
25 Q
Is that con sis tent with p olic y of the LYNN B. GILLI Af4 STENOGR APH REPORTER
{
i Direct 81 l'
Addis F*cour88 Procedure?
2 l
A The polic y does not exclude that.
3 O
No, but does the p olic y deal with the 4
department head s olicitin g the participation of his 5
6 s u p e r'i o r in r e s olvin g the Step Two recourse?
A It is not excluded at all.
A ll we do is I
7
(
a make a dif f e r e n c e between Step Two and Step Three.
9 Q
A ll right, is the re a formal proc edure l
io that is f ollo w e d that would make the r e s p on si bilit y Ofor the Step Two r e s olution that of the depar tm ent 11 il 1
hhead?
12 l
i 13 ;
A As a matter of. all our past p r a c tic e, if l
l llth e r e is a s up e r vi s o r of the department he had a 14 i
15 l S e nio r or Executive Vice President.
I i
,b T he y are inf or med before anything goes l
16 I
17 tlto Step Three by us.
t is O
B ef or e Step Two is c om ple ted ?
A The departmen t head has the o ption of l
20 c on sulting with their supervisor whenever they 21 choose.
22 O
That is what happened in this case?
23 A
That is not excluded at all.
94 O
Is that customary or normal?
25 A
I believe it is with th e S e nio r or LYNN B. GlLLI A M STENOGR APH REPORTER
1 A ddis Diroct 82 Exe cutive V P.
Q So if I were an e m plo y e e I would a s sume 3
going to talk to his boss b,e f o r e he 4
.m y boss was
.a c t u ally made a decision on your recourse?
5 A
Your a s s ump tio n would b e' up to you; it 6
7
.i s not o mitt e d.
a Q
B ut excluding the P r e sident of the compan n.
9 obviously the President of the c o mpany is not to supposed to be involved in Stcp T.v o if he was involved-1 ii lin Step Three ?
12-A If he were he would have to designate i
Step T hr ee.
That is outline d in there also.
13 janother 14 Q
It is, all right.
So your t e s timon y is l
15 that Mr. Owen became involved at Mr.
W e ll s '
l l
16 jrequest?
O 17 A
Yes.
la O
And when was your fir s t co n t a c t with Mr.
l' Owen?
l A
I think it would have to be p r i'o r ' t' o this 20 21 memo.
I don't remember an e a rlie r one.
22 O
The m e e tin g that you have talked about ?
23 l
A Yes.
24 O
W ho else was present at that m eeting ?
25 A
Jim.
LYNN B.
GILLI AM j
m ~oo.. ~.......
1 Addio Diroct' 83 O
Mr.
W ell s and you r s elf and Mr.
Owen?
A Yes.
3 O
Any other s ?
A Not that I r e c all.
5
-Q Wha t. did Mr.
Owen say to you ?
6 A
W ha t did he say at the me e ti n g ?
As I 7
understand it was exactly thi s.. 'tha t I was to out-a 9
li n e a record of the comments made to m e' on this io
- subject, the pay concerns, the primary concerns ii th e gentlemen presented to me were fairly well out.
i 12 line d in there own le tter s.
13 O
A ll s'ght, and w h a t. h e asked you to do 14 was to o u tli n e as you have de sc ribed in this is int r oduc to ry paragraph, co mment s c o nc e rning work, 16 q u a li t y, and r e la ti on s hip s with con s truction ?
17 A
Yes.
18 Q
Is this the fir s t, this December 3rd, l'
- 1980, memo, that you wrote to Mr.
- Owen, is this 2o the fir s t documentation that you know of that 21 r efle c t s the non-pay concerns of the Welding 22 In s p e c to r s at Catawba ?
23 A
I think Mr. W e ll s' summary may predate 24 this.
l 25 O
A ll right, we have not been able to put LYNN B. GILLI AM
.rescoa m ac,carca l
i 1
Addis Diroct 84 our. hands on that, but anything other than M r.
W e ll s '
summary that would have been e a rlie r in time than 3
this document, Ms.
Addis?
4 A
Not that I ' m' aware of
'a t all.
5 O
A ll right, what did you say to the W eldin g 6
7 In s p ec to r s when they brought up to you these con-a
- cerns, the concerns other than pay?
A T he y.und e r s too d, you know, at the outset io what my function wa s was b a s ic ally to be sure that 11 m ana g eme nt understood their po sition.
12 I explained to everyone at Step Two what 13 that role is was to be sure that mana ge m ent under-i 14
! stands that if any independent kind of evaluation of 15 precedent or whate ve r in any kind of case would be 16
.done, who would do it.
17 O
- You, meanin g your s eif ?
18 A
Employee R el a tion s,
but to assure them 19 that management would hear their p o sition as 20 accurately as possible as they pr es ented it to us.
21 O
What was your reaction to hearing con-22 cerns that were not relative to pay, Ms.
Addis ?
23 A
The issues r e ally were related to pay to 24 the recourse, pay recourse, which was why I wa s l
1 25 there.
A nd my reac tion was to write them down.
l LYNN B. GILLI AM sTENoGR APH REPORTER
i i i Addio D'i r o c t 85 O
Were you surprised to hear the c o mplaint s 2
that you have r e fle c t e d here?
3 A
I don't re ally pa s s a personal judgment; 4
I was just t r yin g to li s t e n and be sure that I under.
5 stood.
6,
l Q
I am not a s kin g for your personal judg.
7 8
m e n t, your professional judgment as Employee 9
R elation s person and you're hearing a Isrge number io of W elding Inspectors, not only s ayin g that they are'
~
11 unhappy about a pay adjustm ent, but that that, inter.
12 related with that pay adjustment concern, are con-13 cerns that have to do with the ef f e ctivene s s of doing l
l 14 th ei r job, Quality A s suranc e job.
l I,
is Did that cause you concern?
Was that a red fla g ?
Was that s o methin g that as someone w ho 16 l
17 is responsible for E mplo y e e R e la tio n s, you thought 18 was s i g nific ant ?
19 A
I was con ce rned about the c o mmuni c a tio n s 20 as my notes do r e fle c t, and my recommendations 21 th at a tt e n tio n to improve communications be a 22 p rio rity.
23 l
O What did you do next af ter you. m et face l
lto face with these W elding. In s pe c to r s and you 24 25 heard for the fi r s t tim e these, as you have l
1 LYNN B. GILLI A M STENOGR APH REPORTER I
~.
- i Direct 86 l A d d i s-i c ha ra c t e ri s e d th e m, work qu ali ty and relationship
< c o mmuni c a tio n eoncerns?
A What was my fir s t--
4 O
What did you do next, what was your f i r s t.
5
[ response?
A Mr. W ell s and I dis c us s e d it and made an 7
appointment with Mr.
Owen.
O What did you and Mr.
W ell s say to one
""O 10 A
Verbal exchange r e ally that we had ji fi ni s h e d,
to make sure that we had an o pportunity to 12 33 j meet with eac h pe r s on, and more or le s s a l c o o rdina tion type dis cu s sion.
14 is O
- Yes, and w h a t. did that consist of?
16 A
1 don't remember e x a c tly except th at we i
17 wanted to be sure that the inf o rm ation go t back to 18 the appropriate levels.
19 Q
And what did you do to insure that that 20 happened?
What did you decide to. do to make sure 21 that happened?
22 A
I f ollow e d Mr.
W ell s ' lead, r e ally, and l,we ca me back and met with Mr.
Owen.
23 24 Q
He came back and set up a m e e tin g with 25 Mr.
Owen?
LYNN B. GILLI AM STENOGRAPM REPORTER
1 4
A d di s Dlroct 87 s
A I b e li e v e he did, it could have been the 2
s ec r e ta r y.
)
3 Q
A nd that was the meeting that t o'o k place 4
5 just prior to your December 3rd memo?
A Yes.
6 MR. GIBSON:
Mr.
G u il d, are you 7
a going to be much longer or can we take a 9
short break?
Io M R.
GUILD:
- Yech, if you want to 11 take a break, we can do that.
L e t 's 12 take about fiv e minutes.
13
( Wh e r eu po n, the D e p o s itio n 14 adjourned for a brief recess and is reconvened as f ollo ws :)
16 17 lBY MR.
GUILD:
is Q
Ms.
A d di s, let me ask you a few que s tion s about in t e rvie w s you had with inspectors.
First I I'
20 have some documents that seem to r e fl e c t Mr.
21 Irby's file.
22 Do you remember Richard Irby ?
23 A
- Yes, I d o.
24 L.
Q I have two sets of notes here (indicating;F.
25 O ne set is two pages dated 11/9 / 81.
Is th at your LYNN B.
GILLI A M STENOGR APH REPORTER
i ll 1
! A ddio Diroct 88 !
1 Il I
i h an dw ritin g ?
2 A
Y e s.. it is.
3 Q
Are those your note s ?
4 S'
A Ye*-
l Q
A nd a second set of notes has "S tep 6
7 Three," at the top.
Is that your writing ?
a A
Yes.
9 Q
Was that done at the same tim e or a lo diff e r ent date?
11 A
L at e r.
I 12 Q-How did you come to talk to Mr.
Irby 13 I more than once?
14 A
P a r tic ul a rly the way the recourse process l
l 15
- works, when I initially met with Mr.
Irby the re is 16 always a face to face me eting at Step Two when thei I
answer is, I guess, given to us af ter discussing 17 la with the m ana g e me nt we give the answer back to the l'
e mplo ye e, eith e r face to face or over the phone.
2
't is a verbal kind of process, and it 21 depends on what the employee requests.
What we liit.e to do is understand the employee has the option of r ef e r rin g it to Step Three or not, and ex pl ainin g if 14 he or she has any diff e r enc e s, s p e cific s that he l
25 wants Step Three to consider.
LYNN B.
GILLI AM STENQGR APH REPORTER
1 Addis - Direc t 89 4
2 O
All right, 'i s that what happened in this-3 ins tanc e ?
^
4 A
- Yes, it certainly appears to be.
I w o ul d 5
have talked to Mr.
Irby on another occasion at l
6 which he indicated he wanted S te p Three.
l I would note that, when he want ed' to go 7
a to Step Three.
9 Q
So you me t face.to face with M r.
Irby 10 to take his concerns; and once to explain the Step 11 T wo to confirm the e a rlie r d ecisio n ?
I 12 A
I did talk to him twice.
lI 13 Q
W ould the second ti m e have been to
!!0 explain the re s ult s of Step Two?
14 i'
l 15 A
- Yes, ty pic ally.
That is typic ally the l
16 llway it w e n t.
T he volume caused us to have some 17 l
variation.
l Each person who m I have notes o n, I did Is 19 meet f ace to face with at least unce.
20 Q
And s ome more than once?
21 I
A Yes.
22 O
All ri ght, on the second document where time l:,
23 you r e fl e c t e d you meet with Mr.
Irby a second 24 have a note with a little star beside it.
,i y o u 25 lj Did you put that little star beside the LYNN B. GILLI AM m soo. _...o m.
1 Addis Direct 90 n tation ?
2 A
A ll those notations are mine.
^
3 O
Does that mean you thought that was 4
i m P o rta n t at ' the time ?
5 A
I don't re me mbe r what I thought when I 6
wrote that little star, 7
Q Do you put little stars by things that are a
9 important or randomly, or do you do things like I do and put s ta r s by t hin g s that you think is io it important ?
12
-A I do n' t r e me mbe r why I put th at little i
13
!s ta r.
14 O
As a general matter, is that what tha t l
15
!means ?
l A
I really do not track my s elf that closely.
16 17 It may or may not.
18 Q
Do you see any other stars?
19 A
No.
l 2o O
What does that note say?
21 A
" C o nvin c e d th e basis of whole issue is 22 to downgrade CA to get them out of the way to get I
23 back to work."
l 24 O
Is that what M r.
Irby told you?
~
25 l
3 7,,,
LYNN B.
GILLI AM STENOGRAPH REPORTER ts
. _ ~
l I
1 Addis Direct 91 4
Q Did you thirk.that was important?
2 i
l i
A Y e s,. all of the m are.
i 3
Q I think everything is important that you 4
5 do, but do you think that was pa rticula rly i mpo rtant ?
A I think all of that is im po r tant.
6 l 7
Q How about just ans we ring the que stion ?
a MR.
GIBSON:
M r.
G uil d,
she has 9
answered the que stio n.
You are attempting to to get her to answer it in a way that you 11 are s ati sfie d with.
i 12 MR.
GUILD:
I'm trying to get her l
to answer yes or no and not double talk.
13 14 The que s tion, and I will restate again--
15 l
l ll. 3 Y 16 MR.
G UILD :
I 17 Q
Do you think that statement that you have is indicated with a star is particularly significant; 3'
yes or no?
20 A
A ll of tho s e statements were signific an t 21 to Mr.
Irby, and I wrote them down.
22 Q
Did you think it was p a r tic ul a rly-- ye s or 2'
no?
I 24 A
E ve rything I wrote down on behalf of M r.
25 Irby was important to me and to Mr.
Irb y.
LYNN B. GILLI A M STENC CR APH REPORTER I
0l. A dd i s Diroct 92 i
MR.
GIBSON:
Mr.
G u ild,
it appears 2
~ he does not feel c o mf o rt able answering s
3 that que stion with a yes or no.
4 Every qu e s tio n is not answerable 3
with yes or no.
6 MR. GUILD:
I will observe that she 7
has declined to an s w er the que stion yes a
9 or no.
MR.
GIBSON:
If that is your evalu.
io it ation.
I suggest that you a sk another 12 que s tion and move on.
13 14 BY MR.
G UILD:
is O
Did you m ak e r ela tive judgments about pthin g s that are s i g nific an t ?
Do you write everything' 16 i
17 j down that comes out of the man's mouth ?
i 18 MR.
GIBSON:
I object, you asked l'
her about her role and what judgments 20 and recommendations she made; and you 21 asked her that af t er lu n c h and now you 22 are s t a r tin g on the same road again fo r 2
the third time.
24 Would you answer that qu e s tio n for
~
25 him ?
LYNN B.
GILLI A M STENOGR APH REPORTER e.,-.,--._,......,._
1 A ddis Direct 93 THE WITNESS:
Would you restate 2
it?
3 MR.
G UIL D :
If:you have an objec-4 5
tion, please state it, Mr. Gibson. Other-wise you will prolong the dif fi c ult pro-6 7
cess o f. g etti n g an answer from the Witne s s.
8 9
BY MR.
GUILD:
i io Q
Do you evaluate what people tell you or 11 do you write down everything that is said or consider 12 it all important because it is said?
[l Do you make any effort to judge what is 13 14 s aid ?
15 A
I write down what the employee feels is 16 important; rather than tell an individual that his 17 thoughts and concerns are unim po r t ant, they are is important if he f eels they are impo rtant.
I' Q
A nd the answer to my qu e s tion ?
20 A
I write down what the employee feels is 21 important.
22 Q
And you make no judgment about what is 23 im p o r ta n t or not important ?
24 A
1 don't tell th e employee his thoughts are 25 not important.
LYNN B.
GILLI A M STENOGRAPH REPORTER
-_. - = _.
- i Direct 94 1 : A ddis i
Q~
You w o u l d r. ' t be in your job this long if 2
r did.
My que s tio n to you, ma'am, do you make 3,you 4
any evaluation relative to the impo r t anc e of what 5 ;th e s e inspectors tell you?
6 i A
Yes.
I 7 I O
How do you do that?
8 A
The concerns expressed by the e mplo ye e s lif are. important; I know that even before I me et t he m.
9 b
i 10 Q
And this p a rticula r concern that Mr.
Irbyl i
l l expressed that you have the star at; that is no morei i
11 i
im por tant than any other.
Is that your t e s timo ny ?
12 l
l A
I don't remember why I put the star.
13 f
14 O
It is no more important than any other?
15 A
I would have to study everythin g he said.
16 a
O T ell me whe th e r or not you can ans wer li
'7 that que stion.
Take a look at it.
is A
I know this was pa rticularly important l
to M r.
- Irby, all this, that s ta te me nt.
2 O
- Yes, ma'am; take a look at it and give me 21 an an s w er to the que stion.
How about looking at it 22 right now and tell me to da y, Ms.
A ddis,
looking at 23 l all the things you have written f rom Mr. Irby's 24 particu-
- inte rvie w, tell me why you consider th a t a l
25 l
larly important thing he said to you.
LYNN B.
GILLI A M STENOGR APH REPORTER
5 i
A ddis Direct 95 P
i truly do not consider that to be of i-You 2
'more outs tandin g importance than some of his other 3
f e elin g o o.r pe rceptions ?
4 5
l A
Right.
O O kay, what did you under stand that state-3 ment by him to mean?
7 A
A bout his p e r c e p tio n ?
a O
Yes, his f e eling, his perception, h is f etatement?
to l
A Pretty much that he was f e eling that the l
11 12 pay grade decision was a put down to him.
13 !!
O Was a put down to him ?
U ll A
T h at is the man I was talking to, yes.
14 h,4 Q
You have written down here it was an 15 I effort to downgrade OA.
Is that him or the pro g ram ?-
'6 i
hj A
That is the way he presented it; he felt 17 U
18 it as a put down.
19 Q
Downgrade Quality Assurance to get t h e m--
20 ihe is s p e aki ng more b ro a dly than him s elf, if you I
21 wrote that down accurately.
22 A
And I did.
i 23 O
"To get them out of the way and get down 24 ito work."
Did you understand that to be more v
25 general than the QA Inspector?
LYNN B.
GILLI A M STENOGRAPH REPORTER
~ -...
..-..t_,._-_,_...__,__.
i 1
Addis Diroct 96 l A
H'e r e again, I am trying to remember in
.2 the context of our discussion.
He was talking about 3
his pay grade and how he f elt about his own f unc tion, 4
5 'yes.
6 Q
Is that how you understood it; as only 7
relating to him ?
8 A
To his f un c tio n, to him s elf, his QA role.
9 Q
Quality A s suranc e at Catawba?
io A
His piece of it, it Q
Did you see that as a p r o g r am a ti c 12 l c o m pl ain t on his part?
1 1
13 l MR.
GIBSON:
What do you mean by 14
" pr o g r a ma ti c, " Mr.
Guild ?
15.
MR.
G UILD:
Let's see if the Witne n s 16 can answer.
l 17 i MR.
GIBSON:
She will not answer is,
until we both understand it.
l' MR.
G UI LD :
I am h a vi n g a dif fic ui :
2 anough time, 21 j
MR.
GIBSON:
I instruct her not to 22 ans we r until it is clear what you mean by
- 3 the "p r o g r am a tic " concern.
24 MR. GUILD:
She will not answer?
25 MR.
GIBSON:
You will not get an l
LY N,N B.
GILLI AM STENOGRAPH REPORTER
t s
i
.1 A ddis Diroct' 97
(
2 answer the way it is asked.
3 MR.
G UILD :
Are you ins tructing her 4
not to a n s.w e r ?
givf 5 l MR.
G I B'S O N :
Not until you can 6
us a definition of p ro g r a matic.
7 MR.
G UILD:
We will leave it h an gi n g.
a 9
B Y MR.
GUILD:
10 Q
Did you pass any judgment on the W e ldi n g 11
, Inspector c o m plaint s,
Ms.
A ddis ?
12 A
No.
[
13 Q
Did you form a judgment ?
'l I
l 14 A
I didn't form a judgment on the pay grade l
33
! issue.
i O
Did you fo rm a jud g me nt on anything you
'7 had to say to them ?
is A
I didn't want to interrupt you.
M y f unc-19 tion was to relay the inf o rm ation.
1 20 O
I unders tand that, but did you form a 21 judgment?
You are a human being and we make 22 judgments and I wanted to know if y o'u formed a 23 Judgment on the basis of talking with these Welding Inspectors and doing your work?
25 A
I reported my judgments to mana ge me nt, LYNN B. GILLI A M STENOGRAPH REPORTER l
'1 l A ddio Direct 98 2
and that was that c o m muni c a ti o n s,
in my professiona l
3 o pinio n, ne e de d attention.
4 Q
W ha t did you urge management to do?
5 A
Some of that is r e fle c t e d in my notes
.6 lwhere I suggested that they improve the c o mmuni-7' c atio n s and very clearly explain the pay issue; and l1 8
of f e red to work with them in d eveloping better c omm unica tion s.
10 Q
Does that represent your judgment and 11 r e c omm endation ?
- l 12 9 A
That is my professional judgment.
ll l
l; O
That is a de s c ription of what you did ?
l 13 14 A
In addition to relaying the employee l3
'c o n c e r n s, w hi c h I did not pass technical kind s of l
l hudgment or wage and salary judgments on.
j Q
Okay, did you form the opinion that the is W el di n g Inspectors wara over qualified f or their 19 po sition s ?
l 20 A
I didn't form that opinion, no.
21 j
Q Did you ever express that opinion?
22 g
A No, I didn't.
23}
i.
Q You didn' t ?
24 l
A You mean my personal opinion about my l
25 aualification s ?
LYNN B. GILLI A M l
STENOGR APH REPORTER
ll 1
A ddi s Diroct 99 i
O
- Yes, either person 1 or p r of e s sional or any opinions; did you ever say that or words to tha t 3
effe ct ?
A Not in my o pinio n, no.
3 i
O Were y u aware of others with the company l
6
h oldin g or expressing that opinion?
7 A
In t e r m s ' o f peo ple being over q ualifi e d ?
g O
- Yes, W eldin g Inspectors being over 9
io q qualified for their po sition s ?
1 Il A
No, not dir e c tly, I did n ' t hear it.
l ti
!I 12 O
In any way, shape or f or m, Ms. Addis, 13 did you hear directly becaus e men told you or I
l 14 because you learned in the course of d e alin g with ll is Ithis issue there was an opinion held by some or a I
I, jfew o r any that the Welding Ins pector s were over 16 E
17 ! qualified for their jobs?
is A
No, it was not a matter of over qualifi-19 c a tio n s.
I remember be tte r understanding that the 20 qu a lifi c ati on s in QA were the qualifications that 21 were amended.
22 O
Did they lower the qualific a tion s ?
23 A
I wouldn't characterize it that way.
24 O
Did th ey reduce the amount of prior 25 l'll experience?
LYNN B.
GILLI AM STENOGR AP>4 REPORTER
1 1
A ddis Direct 100 A
They changed it.
2 Q'
Did it c all for fewer years of exp e rien c e 3
in grade, f e we r levels of c e r t'ifi c a ti o n in grades of 4
actual weldin g ?
5 A
I wa s n' t aware of it, Mr.
G uil d.
6 l 7
Q Did you 'kno w any of that?
8 A
All I know is they are amended or 9
- changed, io Q
Were they changed in the way that I have 11 de s c rib e d ?
I am not a W e ldin g Inspector and neither
! are you; but is that consistent with what happened?
12 ll 13 i
A That is a wage and salary jud gme nt as to i
14 i whether it was lowe r ed or changed.
15 Q
T ha t wa s no part of your info rmation 16 a vaila bl e to you at the time you pursued this matter 17 or were involved ?
18 A
Some of the e mplo ye e s ' f e elin g s about having been Craf ts men in the past were expressed.
20 But it was not a major factor that they pre s ent ed 21 to me.
22 O
- Look, if you would, at those notes for 23 M r.
Cha rle s C ri s p.
Do you r em e mb e r M r.
C ris p
(
to m e an --le t 's
- see, we have two sets of note s.
25 One says Step Three at the top and the LYNN B.
GILLI A M STENOGRAPH REPORTER
~,
- -... - - -. ~ -,.. -
A ddis
, Direct y
101 1
I other one is dated, let's see, it looks like it is 9 /1/ 81.
3 4
Both of these notes are c o nve r s a tio n s you, had with M r.
Cris p ?
5 6
A
'Y e s.
7 Q
Initially what did you und e rs tand -M r.
a C ri sp to mean when you have him s ayin g, "I' v e 9
been a welder and I know the dif f e r enc e.
It would tcke an idiot to be an inspector on weld e r pay."
to,
,i ii i A
Where are we?
12 Q
Do you see it ?
i3 A
O h, a ll right.
The pay grade adju s tm ent 14 would have equated the top C raf t pay with the 15 HInspector pay.
My m e mo ry of M r.
Crisp is.that he 11 o
16 ! b eli e v e d,
- again, that his job j us tified a higher pay
'(grade 17 was his concern.
,.i l
1al Q
That was his concern, and he said, "I
I I
I
'have been a welder and now I'm an inspector and I I
2o Ekno w the dif f e r e nc e. "
21 A
My memory is that he b e li e v e d his i
i 22 ;i n s p e c t o r 's po sitio n m e rite d a higher pay than a li Ilw eld e r.
He was p re sentin g that po sition to m e, 23 I
24 ;t h a t opinion.
25 Q
Is that all you understood from that?
LYNN B. GILLI A M STENOGRAPH REPORTER 4
,.--,--e,
---v,.r-.
,..-.,,,-,v..e,,__.,,.
_.,,, -, - - - - - - - - - - - ~, - -,, - -..,
.3
1 A d dio Direct 102 A
- Yes, that he thought the inspector's job warranted a hi g h e'r rate of pay than welder pay.
3 O
What did you understand he me ant by
" feels-that it will hurt the program down the road"?
5 I
A B eing able to r e c ruit what he believe s l
6 I
is C raf t knowledge.
7 s
Q For Welding Ins pectors ?
A (The 'Witne s s nodded he r he ad ' affirmatively. {
io Q
He said, "Let people go back to C raf t. "
n lI s that a request on his part?
12 A
Where did y ou ' s ki p to ?
13 Q
Just a few more lines below that, he said, itll" Le t. pe ople go back to C raf t, "
14 l
A What he said was he had been told people 15 l
16 lwould be able to transfer back to Craf t jobs if they l
17 jchose to, and he felt lik e th e people really had not 1
18 been able to do that; and of course, they were given l'
that o p po r tunity.
20 Q
Sub s equ e ntly, later on in the process they g
21 were of f e r e d the o ppo r tunity to have some preference lIn going back to C raf t ?
22 23 A
Yes, the o p p o r tu ni ty had been there, but 24 there wasn't the availability.
C Now then, you then spoke to M r.
C ri s p LYNN B.
GILLI A M lf STENOGR APH REPORTER
i-l 1 i.A d di o Direct 103 q
l on wh at appears to be the 23rd of November, and 2
that is when he inf o r m ed you he intende d to take his 3
Step Three?
4 A
Yes.
5 Q
What did you understand by the note that l
6 lyou have on the bottom ? It appears to say the union 7
l l
a' "on hold".
I 9
A T hin g s Mr.
Crisp told me.
l l
io Q
What did he tell you?
11 A
I think there was some interest, Mr.
j i
ilC ri s p was f airly angry and f e elin g a little bit p o w e r-12 i
13 less and s o m e tim e s when e mplo ye e s feel th at way 14 dhe f eels the need for some third party help.
i 15 !
Q The Lord, what third party help are you 16 referring to ?
i p
l 17 A
I' m sorry, that is professional language 1 1
i is i t' h e u ni o n, Q
Did any of the others make tha t kind of l'
20 comment to you?
21 A
I don't remember any C a tawb a person, t
22 maybe one or two.
O Maybe one or two who?
24 A
I don't know.
(
25 I
Q Are they r e fl e c t e d in these notes?
LYNN B.
GILLI A M STENOGR APH REPORTER l
l
- l Diroct 104 I
ddio i
2 A
Everything they emphasized that they felt impo r tant' I trie d to write down for the m.
3 was 4
Q There aren't any uni on s out at C atawba, are ther e ?
i 6
A No, sir; not that I am aware.
7 Q
It is part of your job to be aware of those 8
thi n g s ; isn't it?
f A
Pretty much, we have a Labo r Relations 10
. Director.
Q Did you ever have any indic ation that the jWelding Inspector s worked to gethe r in f o r mula tin g 12 blr e c ou r s e s
'3 that they fi', e d ?
i
'4 A
Did I have indication s ?
i is l O
Yes.
j A
They told me that th e y talked quite a bit i
17 among the ms elve s.
18 Q
That they met together in groups?
19 A
I don't remember that, 20 O
You don't remember whethe r they did or i
21 not?
l 22 A
No.
23 i
O How did you understand the m t ellin g you
\\
24 that they worked to g e th e r, worked in the same job, f
25 l
have the same r e s po n sibilitie s ?
f LYNN B.
GILLI AM STENOGR APH REf-QRTER I
1 A ddio D i r'o c t 105 A
My people felt that it was a quite 2
g e n e r ali z e d concern, and they were well awar e--in 3
- fact, I had their consent to proceed through this 4
kind of--as making one effort to resolve the con-5 l ce;rns because they were so s imila r.
6 7
Q Did you ask them wh e t he r they could do I
a that ?
9]
A Any time I extended the time f rame s of to Step Two, yes; I certainly did.
I il 11 ll O
How did you do that ?
f 12 A
Asked.
13 O
How would you ask?
I 14 i A
Eith e r face to face or on the phone.
15 O
Did you say can I handle this as one big 16 i,p ro ble m ?
L 17 I A
No, I asked each individual.
It wasn't a is group thing.
I' Q
Did you ask e ac h individu al can I handle 20 this as a common concern?
21 A
No more than the concern was bein g d e alt i
22 Iwith at various stages and the concern was very 23 !s imil a r ; and I asked.that my efforts at Step Two be l
24 i:d e la y e d.
25 Q
And they said fin e,
they agreed to that?
LYNN B. GILLI A M g
GTENOGR APH REPORTER
)
Direct 106 1 Addio A
- Yes, they did.
It wa s n't necessary'to all 2
of the m because they s ta rt ed at dif f e r e n t ti me s.
3 Q
Mrs. A d di s, what happened af te r the Step 4
r e s o 1'v e d and'you c o mmunic ate d Two recourses were 5
that r e s olution to the Welding Ins pector s ?
6 l
What happened next in this matte r ?
7 8
A W ell, some of th e m said 't h e y understood 9
and thanked me and decided not to go to S t.e p Three; some of the m, about a dozen or s o, elected to l
lojand l
I 11 jr ef e r it to the President, which I did.
i
{
Q How did you do that ?.
12 l
l 13 i A
I put together. I tried to c om pile the data 1
l 14 in one place and met Mr.
Lee.
15 O
Did Mr. Lee know of the Step Two 16 'r e s olu tion of the Catawba Welding Inspector concerns?
l u
lj I
'7 l
A I didn't discuss it with him.
is Q
Did he know of it?
i' A
I don't know, I di d n ' t tell him.
20 O
Did you have any indic ation that he knew, 21 that he had been informed in one way or another 22 before the resolution of Step Two?
l 23 A
No.
24 Q
You don't know ?
25 A
Because I got there on December 4 I
l LYNN B. GILLI A M l
STENOGR app 4 REPORTER i
y
i 1
A ddis Direct 107 b eli e v e it was.
2 3
Q A nd did he know before December 4?
4 A
It did not appear to me.
s O
You were info rm ed or you understood that lsome dozen were going to pursue it in Step Three?
6 7
A It wound up to be about that many from a
Catawba.
We had 11 minus the 3 Oconees w ould be 9
8 plus the 4 more from C a tawb a, 12; right.
to Q
And they went to M r.
- Lee, the President?
11 A
The situations did, their concerns, i
12 Q
How did it get to Mr.
Lee?
l f
13 A
I took it.
I 14 O
T ell me s te p by step how you processed 15 it beyond the point where you c ommunic ated the Step
[1 16 Two r e s olution ?
l!
A What I do in this situation and others, s e'e
'7 is that the S enio r Executive Vice President is aware of 19 ilit, In this case Mr.
O wen wa s aware.
20 Q
M r.
Owen ?
21 A
- Yes, they are aware of it.
When a case 2
igoes to St ep Thr ee.
I take this inf o r ma ti on to M r.
23
- Lee, th e President, at that ti m e,
and I left it with l
24 l
him.
25 There was some discussion about the LYNN B.
GILLI A,M STENOGR APH REPORTER
1 A ddio Direct 108 c our s e of action, his r e c om m enda tion s, in which I 2
I 3
w a. s not involved.
I was inf o r m e d about a task force that 4
l 5
was being e stablished of e ngine e r'in g kind s of people.
i l
l l
6 l I was not involved in that.
i 7
They worked with the President, you know, l
a he has the option at Step Three of h a vi n g other 9
people analyze or forming individual inve stigation s 10 or whatever; and Mr.
Lee would have to tell you 11 what was involved.
I don't know.
12 I took this up with him, met with him.
13 There was more than one m e e ti n g because when he 14 finali ze d his analysis of this and his r e vi e w, I
15 helped w'ith some of the communications and some of 16 the language that was used to try to be sure to 4
17 v oic e understanding of the decisions.
18 O
L et 's take this one step at a tim e.
You communicated with the W eldin g In spec to r s and a 2
dozen of them f rom C a ta wb a decided to go to M r.
21
- Lee, and you prepared the b ri e fi n g book that you 22 ;have there (in dic a tin g).
Did you phy s ic ally c a'r r y 23 it to Mr.
Lee?
24 v/
A Yes, I did.
25 O
Did you p hy sic ally give it to him, carry LYNN B. GILLI AM STENOGRAPH REPORTER
l j
i i
. A ddio Diroct 109 it -t o his offic e at a me etin g ?
(
A I don't re me mbe r on this p a r ti c ula r case; l
3 it is either in his hands or his secretary's hands.
1 Q
B ut you recall face to face m e e tin g with 5
l j
j M r.
Lee when you fi r s t pre s ente d that book?
I f
A No.
7 Q
You just don ' t remember ?
a A
I know I was in one, but that particular 9
10 day I just don't remember, ii O
Do you remember me e tin g with Mr.
Lee jand discussing this subj ect ?
12 is A
Oh, yes.
14 Q
W ha t did you discuss?
I is A
The inf o r m a tion I wa s atte mpting to log
[and explain the process.
That is just standard 16 il 17 procedure, the un d e r s t an din g that the e mplo ye e s is have raised.
p 19 Q
Did you make a summary of concerns?
20 A
Not much in addition to what is here.
It l
21 is about as well summarized as I could do.
22 Q
H e 'ha d no t seen that when you met with 23 him ?
24 A
- Yes, he had.
I don't a c t u all y re m emb e r, 5
but u s ually the P r e s id e nt has an o c. o rtunity to have LYNN B. GILLI A M STENOGR APH REPORTER m
i Addia Diroct 110 1
this and r' e a d i t and then we discuss it.
2 Q
So you don't recall 'having given him any kind o f d'e s c ri p ti o n-o r oral p re s e nt ation prior to him having had an o p po rt unity to.re view your 3
written statement a ?
A I don't recall doing that.
7 Q
But you do rec all me eting with him and af te r he had an oppo rtunity to review the report?
A At least once.
jo Q
Let's talk about the fi r s t one.
When n
!would. that have been?
12 13 l A
I don't remembe r the date.
I 14 Q
W ould it have been--
15 A
It would have been on or af te r December 16
- I s t is the best I think I can tell you, and prior to i
17 the final lette rs going to these gentlemen.
is Q
In January?
19 A
Yes.
20 Q
January la t ?
21 A
- Yes, prior to that.
l Q
I have a sample.
They may be all dated 22 23 the same, b ut e ach file we have a January 6 le tt e r.
a 24 T hi s one happens to be Mr.
Kirkland f rom Mr.
Lee; 25 l
correct?
I LYNN B. GILLI A M l
src~ocaAPs asponTra
n l
1 i Addis Diroet 111 l
A Y***
2 I
O Is that the fin al letter t h a t-you had 3
reference to or not?
4 ll A
The January 6,
- yes, that would be the I
5 l
l cond of the issue as'far as the recourse procedure 6
7 'jgoes.
8 Q
This one r e fle c t s that he is working on l
i l
it.
T hi s one does not reflect any decision; does 1.t 3 iojTake a look.
11 j A
The inv e s tig ation s and indepth review for l
12 lm y decision.
"I will see to it that a decision is a
13 reached as promptly as practicable and me a ntim e
-r il 14 hask for your patienc e. "
l 15 j' So this is simply an I have received
[
jyour recourse, and it is p en din g letter; right?
16 17 A
(The Witne s s nodded her head affirmativeiy.
l 18 l
Q You met with Mr.
Lee before that letter t
l' went out?
20 A
Yes, I met with him shortly af ter I 21 d eli ve r e d this book.
22 Q
Do you r e c all M r.
Lee writin g a memo on 23 or before De ce mbe r 4 that initiated the review of
'# 'th e task f orce ?
I i
25 l
A Am I aware of it ?
LYNN B.
GILLI A M STENOGRAPv4 REPORTER l
li
ll i
Addis - Dirset 112 O
Would that memo have gone out before or af ter your meeting with M 'r.
Lee?
A Wha t was th e date ?
4 O
December 4 3
A I m e,t with him or d elive re d this on the 3
l4th.
He did not work with me on the task force.
7 rea y
on now; n
a e ar und the 8
same time, but the task force, I b e li e v e,
came from M r.
Owen's area, not my area.
io ii Q
A ll right, so you met with Mr.
Lee on 12 or about the 4th and read your report to hi m ?
is]
A By the time I discus sed it with him he wa s
iijvery well aware of the issues.
14 15 O
It appears to you he read it?
l 16 A
Yes.
i 17 Q
What did Mr. Lee say on the s ubj ect ?
l is A
I don't r e m e mbe r.
l 19 Q
Give me the best of your r e c olle c tion 20 what he said.
l 21 A
You know, I r e ally don't r em e mb e r that l
22 long ago exactly what he said o the r than taking th e 23 i
info r mation and being sure he understood it, w hi c h l
l 24 is the way Mr.
Lee is.
25 O
Did he.give you any ins truc tion s ?
LYNN B.
GILLI A M STENOGR APH REPORTER
f Addis
'Diroct 113 I
o A
No.
2 Q
Did you make any recommendations to hin3 ?
3 A
A ll of my information is here, the points 4
s we covered e a rli e r about the e mplo y e e s having th e 6
right kind of c o mm unic atio n about the decisions, 7
about the wage and salary decisions.
s Q
Was that the s ub j e ct of your discussion 9
to the best of your r e c olle c tio n how to communicate io, the wage and salary situation more ef f e ctively ?
are usually employee ii A
My communications 12 l c o m munic a tion s and unde rs tanding.
13 Q
Was that y ou r disc u s s io n ?
14 A
- Yes, 1 don't u s u ally get involved in matte rs 15 of which I don't have a wo r kin g knowledge.
16 Q
Do you recall any discussions that 17 r efle c te d a decision on his part to inve s tig at e the is technical concerns of the W elding Ins pector s ?
A I don't r e me mbe r the task force timing 3'
20 being di s cus s e d with me.
It may have been.
21 O
How about the task force concept or 22 general work plan and mis sion ?
23 A
I remember hearing about that.
I l
24
(
l Q
Would that have come up at that me eting ?
25 A
I don't know.
~
LYNN B.
GILLI A M STENOGRAPH REPORTER
\\
A ddis Diroct 114 1
Q You just don't r e c all ?
2 A
I don't recall.
3 Q
W ho else was present at that me eting ?
4 A
M r.
Guild, I don't rememb er.
I know Mr.
5
- Owen was present at a couple'of me e tin g s I was 6
involved in.
7 U s u ally the initial recourse discussion is 8
b e twe en me and the President; but there were subse-i 9
quent discussions to that m e e tin g.
10 Q
Do you r e c all on at le a s t one occasion, 11 likely the fi r s t, that you w o.u ld have met alone with 12 M r.
Lee on the subject?
13 A
That u s ua lly happens.
As far back as
'81, 14 I' m not sure I can remember exactly.
15 Q
Those don't happen every day, do they?
16 A
Recourse procedures?
17 O
To the Pr esident ?
18 A
W ell, they have some frequency.
19 Q
We have already talked about how they are 20 not common oc currence s; sre they ?
21 A
I guess I can restate my p oin t; two checks, 22 one is that I u s u ally meet with the President once a 23 month and the second is I don't r e me mb e r as f ar back 24 as '81 about which day I talked to whom.
5 Q
All ri ght, did you ever carry a dozen Step 4
gygLYN SERGER ASSOCIATES. STENOTYPE REPOfrflNG SERWCE. CHARLOTTE. NORTH CARCUNA
A ddio Direct 11 5 1
Three recourses to Mr. Lee at one time before or 2
since?
3 A
No, I h a v e n ' t.
4 Q
Did you ever carry more than one Stop 5
Three recourse to Mr.
Lee before or since ?
6 A
Y e s,- I have.
7 O
When?
8 A
T hi s year.
9 Q
How many e mplo ye e s were involved in that to one?
11 A
Two.
12 O
Is that the mo s t other than this incident?
13 A
Let me clarify; are you a s kin g about 14 employees ' conce rn s about the same issue?
15 e
y,,,
16 A
No, but I have had more than one Step 17 Three at o nc e; yes.
18 Q
But never more than one about the same 19 issue 7 20 A
We have had as many as two.
21 Q
A nd this was a do z en, and it does not 22 s tic k in your mind?
23 A
The s p e cific dates do not s tick in my mind,
l
~
24 Q
I just want to know what you talked about, j
25
(
Ms. Addis.
l EVELYN BERGER ASSOCIATES, STENOTYPE REPORTING SERVICE, CHARLOTTE NORTM CAROUNA
~
A ddis Diroct 116 9
1 A
It is right her e (indicating).
2 O
Let's tell me about it.
3 A
1.just did.
4 O
What did M r.
Lee say?
5 A
Excuse me, I said the inf o rm a tio n th a t I 6
dis cus s ed with him wa s to insure that he understood 7
what wa s in this inf o rma tio n.
8 Q
- Yes, right, I got that part.
T ell me what 9
he said.
10 A
I don't remember what he said.
11 Q
How many othe r occasions did you meet 12 with him ?
13 A
I remember at least two.
14 O
A ll ri ght, tell me about thos e me e tin g s,
15 plea s e ?
16 A
There was a meeting involvin g discus sing 17 this matte r with M r.
- Owen, Mr. W e ll s and some other 18 staff me mbe r s were present.
19 Q
What other staff m emb e r s, to the best of I
20 your r e c olle ctio n ?
21 A
Mr.
D avis on.
U Q
Larry D avis on ?
23 3
y,,,
24 Q
How about Mr.
G rie r ?
A No, not Mr.
G ri e r.
EVELYN SENGER ASSOCIATES. STENOTYPE REPORTING SSpVICE. CHARLOTTE. NORTH CAROUNA
A ddis Diroct 117 l
1 O
How about M r.
Henry?
2 A
No.
3 Q
I think that's it.
When would that have 4
- happened, i: \\v e me an approximation if you can r ec a ll ?
5 A
Well,.it is roughly within a fo ur week 6
period there.
7 Q
In D e c o m'b e r perhaps?
8 A
A f te r December 4 up until right around 9
Christmas.
10 Q
Are you aware g enerally that the fir s t 11 task force issued a report before the close of that 12 year sometime around th e last week of D e c embe r ?
13 A
- Yes, but I haven't seen it.
I know they 14 were working very hard to give it what they consider ad 15 to be proper a t t en tion, b ut I was not involved in the 16 technical aspect.
17 Q
I am trying to refresh you as to the time 18 f ram e.
It would have been De cember ?
19 A
Iwas involved in this pay procedure, what 20 the employee s were using the recourse procedure f o r.
21 The time I got started at Step Three was in early 22 D ec e mbe i.
23 Q
What was the subject of th e m e e ting,
th e 24 second me etin g where M r.
Owen and Mr.
W ells and 25 M r.
D avi s on and you r s elf w ere there with M r.
Lee?
EWELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
A ddi s Diroct 118 1
A We dis cus s e d the salary issue.
2 O
Wha t was the di s cus sion ?
3 A
The re s olution came out in the analysis of 4
it, but the wage and salary d'a c i s i o n a b o u t the pay gra de 5.
was accurate.
6 Q
That wasn't your input, was it?
7 A
No, the wage and salary ad ministrato rs and 8
the management d is c i d e d that.
9 Q
Who r elate d that e xp e r ti s e at this m e e tin g.
10 if anybody?
11 A
Mr.
F ain may have been there.
12 O
F - A -I-N ?
13 A
- Yes, his memo is in here.
His opinion, 14 at least the wage and salary a d mini s t r a tio n o p i.n i o n,
15 was a v aila bl e to man a g eme nt.
l 16 Q
Wha t did Mr.
Lee say at this me eting ?
17 A
I don't r e m e mb e r ex ac tly what hi r. Lee 18 said: I can't quote him.
l 19 O
I don't want you to quote him.
T ell me 20 the s u b s ta n c e.
l l
21 A
His fi ndin g was that the wage and salary 1
l 22 d ecision that the company had made was accurate, and
~
23 I do not r e me mb er him--I rememb e r hi m asking questl.onc 24 about it, about the pay grade.
l 25 The company has a c ommit m en t to internal EvtLYN SERGER ASSOCIATES. STENOTYPE REPORTING SSRvlCE. CHARLOTTE. NORTM CAROUNA
A ddis Dir'oct 119 1
quality and external competition; and I remember him 2
inquirin g well enough to s a ti s f y in his own mind that 3
thos e commitments were m e t.
4 O
All ri ght, did Mr.
Lee say anything on the 5
subject of th e technical concerns of the Welding 6
Inspectors 7 l
l 7
A I r e ally don't re m embe r.
Af ter I turned 8
over this inf o rm atio n.
I remember that they had 9
- decided, and I am not exactly sure who decided that to th e r e would be a technical kind of task force, whi c h 11 diff erentiated perhaps any of the te chnical conc e rns 12 that the e mplo ye e s had presented through me or Mr.
13 W ell s,
l l
14 Wha t was decided with that on a priority l
15 level, that is no longer in my area at all.
16 Q
You don't know of M r.
Lee expressing con-17 corn or interest or involvement of the eff ective ne s s o f 18 the Quality A s surance work at C atawb a ?
l l
19 A
I think the entir e company is.
W Q
- Yes, you were s ayin g-- about whe th e r there 21 was an expressed concern?
22 A
Yes; I think there is a very definite im.
l l
23 pression that I got was that Mr.
Lee was very concer n-24 ed about these employees and the pay grade issues M
and e v e r ythi n g they had to say.
...ovo.
.....ociar.
.r aorves as o maa eavec= caam.orra acara c^aoua^
Addis Direct 120 1
O Concerned about eve rything ?
2 A
Their p e r c e ptio n s and belief s about how thoy 3
felt about their work.
4 Q
Did he express that concern?
5 A
- Yes, he did.
6 O
Wha t did' he say?
7 A
In my area I think that he was very much 8
inte re st ed and advised a c tu ally that some attention be 9
given to e mplo ye e r e l a tio n s matters, the working 10 r ela tion s hip, all of the concerns of e mploye e s.
11 He wanted those attended to and tha t was 12 very clear to me.
13 O
Was anything clear about his expression of 14 concerns about the e ff e ctivene s s..o f Quality Assurance l
15 at C a tawb a ?
16 A
Not to me.
17 Q
Not in the meeting at which you were 18 present?
19 A
No, I don' t remember him expr e s sing any 20 doubt in front of me about the qu a lit y.
21 Q
How about the matter of encouraging or 22 p r o vidin g s o me s en sitivity or preference for W e ldin g 23
~
In s p ec to r s who might ch o o s e to transfer 'back to Craf t 24 po sition s ?
25 A
What was the qu e s tio n ?
.v.tva. ao.a anociar....r.aom awoahao seawe. cuaatom. aoara caaouaa
A ddis Direct 121 1
Q Mr.
Lee on that subject?
2 A
What was his po s ition ?
3 Q
D o yo u r e call hi m expre s sing anything on 4
that subj e ct ?
5 A
The decision was made that e m ploy e e s who 6
felt they wanted to m o v e' into C raf t positions were 1
7 given that o p p o r t unit y on a priority basis.
8 Q
Did he express that to -you ?
9 A
It was the consensus.
I'm not su re which to manager made the statement, but it was agreed to.
11 Q
You don't r e c a ll whether M r.
Lee s aid 12 anything on the. subj ect ?
13 A
I am a war e that the consensus that that wou ld 14 he an appropriate thing to do was reached.
15 Q
In one of the meetings in which you were 16 proeont?
17 A
- Yes, this was based on some of th e 18 e mplo ye e s f e elin g that their career path de ci s io n was 19 not co mf o rtable for the m.
20 Q
In light of the pay adjustments ?
21 A
T o t all y.
22 Q
A ll right, that is two m ee tin g s with Mr. Le e 23 that you can r e c all.
Can you r e c all others on that 24 subject?
A I can't1 there may have been, but I can't 25 EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SEfMCE. CHARLOTTE. NOMTH CAROUNA
)
A ddis Direct 122 I
recall.
2 O
You stated that you r e c a ll c o mmu ni c a tin g 3
M r.
L e e 's decision.
How did you do that and what 4
did you do?
5 A,-
That was in discussions also in working 6
with his clerical staff.
I tried to help them be sure 7
that they had the p ro pe r mailin g addres se s and some 8
of the t hin g s.
9 Q
Did you draf t the lette r he maile d to the 19 W eldin g Inspectors ?
11 A
I worked on the co nt en ts, a nd language that 12 those
.e m p lo y e e s would best understand in my opinion; 13 but th e r e were s everal people involved.
14 O
Did you draf t a proposed lette r ?
15 A
S e c tio n s of some s' the in f o r m ati on, ye s; 16 at least I propo s ed it.
I' m not r e ally sure who made 17 what s e c tio n s with Mr.
Lee and my s elf.
18 It was his le tt e r though, I can t e ll you 19 that.
20 Q
But you assisted him in trying to f ormulate 21 eff e etive communications ?
22 A
On an o pinion level.
23 Q
What role did you have, if any, Ms. Addis, 94 in further work on responding to the W eldin g Inspector concerns?
EVELYN SERGER ASSOCIATES. STENOTYFE REPORTING SERVICE. CHARLOTTE, NORTM CAROUNA
A ddi s Diroct 123 1
A N o n's after the recourse procedure and the 2
Pay rate issue was resolved.
I was no longer 3
involved.
4 Q
Were you involved beyond a s sis ting in 5
co mpo sin g this lette r ?
6 A
No.
7 O
Were you aware of a number of meeting s 4
8 that occurred between management and the W eldin g 9
Inspectors subsequent to M r.
L e e 's r e s olution of the 10 third step of the recourse procedure?
11 A
I was aware that the plan to concentrate 12 on c o mmu nic atio n s and the E mploye e Relation - matte r s 13 were in place and management in that area intended to 14 use the exp e rtis e of their own staff to make those 15 e ff o rt s.
Is I was aware o f that.
17 O
Were you involved in any of that ?
18 A
No.
19 Q
Were you in volv e d in any implementation of 20 the fi n al report of the weldin g, C at awb a W eldin g Task 21 Force?
r A
No.
23 Q
Were you involved in any of the e f f ort s of
/
24 the consultant s that were retaine d by the company with 25 re spe ct to the Catawba Welding Inspector Task Force ?
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CARouh4
_ _ _,. _ _ _ _. _ _ _ _. = _ _.
Addis - Direct 124 1
.A No, I wa s n ' t.
~
~
2 O
Have you be en involved in prcc es sing any 3
subsequent recourses f ro m Welding In s p e c to r s at 4
C at awba ?
5 A
One.
6 O
Who was that?
7 A
A young man concerned about not b ein g 8
p ro mo te d.
9 Q
Was he one of the Welding Inspectors who 10 raised initial conc erns here?
11 A
No, he wa s n't.
12 Q
Somebody diffe rent ?
13 A
(The Witne s s nodded her head a ffir ma tiv ely. )
14 Q
Do you know what has happened to the 15 C at awba Welding Ins pectors who exercised the r e c ou r,s e 16 procedure, Ms. A ddis ?
17 A
No, I have had no other recourse f rom tho s e 18 g e n tle m e n at all.
19 Q
Nor have you had any othe r inf ormation l
N that would help you answer that que stion ?
21 A
No, sir.
M Q
Do you know whether or not the Catawba 23 Welding Inspectors' concerns, either technical or non 24 technical, have been resolved to their s ati s f a cti on ?
25 A
To their s atis f a ction ?
EVELYN SERGER ASSOCIATES STENOTVPE REPONTING SEMICE. CHARLOTTE. fv0RTH CAROUNA
A ddis Direct 125 1
O Yes.
2 A
No, I don't know.
3 Q,
Do you care?
4 A
C e r tainly.
5 O
Do you make it your business to fin d out?
6 A
As I said, the personnel profe s sionals with -
7 in the QA Department are providing the functional 8
services to th e m, not th e corporate o f fic e.
9 Q
Who might I ask?
10 A
It would be in the Personnel area of Mr.
11 Alexander.
12 Q
It is N e il ?
13 A
C.
N.,
right (the Witn e s a nodded her head 14 a f fi r m a tiv e l y.).
15 O
A ll right, if I can have ju st a moment--
l 16 Ms.
A ddis, if we can go back for a moment, I show you this December 3rd,
- 1981, memo f rom you to Mr.
17 18 Owen (indi c a tin g ).
19 Look through there and tell me in light of 20 your subsequent involvement in thi s 'i s s ue,
if ther e is 21 anything in there not factually correct or if it has 22 come to your attention those are not ac c ur ate 23 t r an s c ription s of c oncerns brought by Welding 24 Inspectors, or if there is anythin g else that is in-M accurate and therefore should be corrected to that so svstra...
4..ocar....v ~orm ronnuo.. vic. cuantons. ~onra cinoun.
A ddis Direct 126 1
that I may have a full unde r s tanding of what you 2
c ommunic at e d 'to Mr.
Owen at
.t h e ti m e and what, in 3
- fact, h a d b e e 'n communicated. to you.
4 A
One thin g that comes to mind is the 5
diff e r en c e between a notation of talking to somebody 6
on the 23rd ve rsus the 2 4th, if that is a ma t e rial kind 7-of situation.
8 Given some ti me I can probably decide whic h 9
one is incorrect.
typographi-10 Q
Othe rwi s e we as sume there is a 11 c al error since there is a n i n c o n s i s t e,n c y between the 12 note s ?
13 A
Unles s my secretary kept the document she 14 typed it from, I would have a little bit of t rouble.
15 O
W ell, the document she typed it from shoul d 16 be the d oc um e nt included in the file ?
17 A
No, it would have been o u tli n e d.
18 O
You would have draf ted this entire memo 19 in hand from using as a source the notes that we have 20 now in the file?
21 A
T h at 's right.
22 O
And that handwritten draf t of this memo 23 would have be en de sc ribed as a matter of course?
24 A
U su ally s he does.
M Q
You don't but u sually she does af ter she EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVCE. CHARLOTTE. NORTM CAROUNA
Direct 127 A ddi s I
c omplet e s the memo ?
2 A
T ha t's right; one. thing'I can state, and I 3
can take the time to read all of this, is that th e
.4 quotations o u tlin ed here are from the notes that I 5
mad e or thin i n f o r m a t i o n' 'was written down direc tly 6
af t e r..talkin g t o the s e f ellows.
7 It was read back to them to be sure l'
8 und er s tood the real essence of what they were s ayin g
~
9 as well as I could relate i t, saying it as they s aid 10 it to me.
11 It is not intended to be ele c t r o ni c ally l
12 recorded and totally in sequence, exact quote of what 13 that per son would have written down for him s elf.
Id That is what I heard them s a yin g.
15 O
Have any of them s ub s eque ntly corrected 16 your under standing or giv e n you any inf o r mati on that 17 would lead you to amend the remarks that you r efle c t1d 18 in this memo?
19 A
No.
20 O
hi s. A ddis, has anybody ever instructed you 21 to characterize the W eldin g Inspector concerns as 22 simply a pay disputei 23 A
No.
f 24 MR.
G UILD :
A ll right, thank you very much.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERV 1CE. CMARLOTTE. NORTH CAROUNA
~
o o
128 1
MR.
GIBSON:
No que s tion s.
2 FURTHER THE DEPONENT SAITH NOT.
3 (The D e po sitio n was concluded at 4
4:11 p. m. )'
5 6
I, Brenda Gail Addis, hereby c e r tif y 7
that I have read and understand the foregoing l
8 transcript and b eliev e it to be a true, accurate and 9
c o m pl e t e transcript of my te s timony.
10 11 12 Brenda G ail A d di s 13 14 This Deposition was signed in my 15 presence by Brenda G ail Addis on the day of 16 J uly, 1983.
17 18 19 20 Notary P u b li c 21 C E R T I F I C A TE 22 STATE OF NORTH C A R O LIN A 23 COUNTY OF MECKLENBURG 24 s
I, Lynn B.
G illi a m,
do hereby c e rtif y 2a, EVELYN SERGER ASSOCRATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
129 i
1 that the proceeding s were by me reduced to m a c hi n e s
2 s ho rthand in the presence of the Witn e s s, af te rwards 3
tr an s c ribed upon a t yp ew ri t e r under my direction; and 4
that the f or e going is a true and correct transcript 5
of the proceedings.
6 I further c er tif y that these proceeding s 7
were taken at the time and place in th e foregoing 8
c a p ti o n s p ecifie d.
8 I further c er tify that I am not a 10 r ela tiv e,
Counsel or A tt or ne y for either Party or 11 otherwis e inte re st ed in the outcome of this a c ti o n.
12 IN WIT NE S S WHEREOF, I have here-l 13 unto s et my hand at Charlotte, North C a r o li n a,
on thi a l
14 l
the day of July, 1983.
15 16 17 18 LYNN B.
GIL LIA M 19 Court Reporter 20 21 22 23 My Co mmi s s ion expires M a y 12, 1988.
24 25 i
d EVELYN SERGER ASSOctATES. STENOTYPE REPORTING SERvlCE. CMARLOTTE. NORTM CAROUNA
.