ML20078L724
| ML20078L724 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 06/27/1983 |
| From: | Rogers J DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20078L617 | List: |
| References | |
| FOIA-83-434 NUDOCS 8310240047 | |
| Download: ML20078L724 (32) | |
Text
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. a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of }
DUKE POWER COMPANY, et al. )
Docket Nos. 50-413 50-414 (Catawba Nuclear Station, )
Units 1 and 2) )
J June 27, 1983 4:12 P.M.
I DEPOSITION Z:
JOHN C. ROGERS 8310240047 830810
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Evelyn Berger Assodates STENOTYPE REPORTING SERVICE P.C. BOX 19444 CHARLOTTT NORTH CARCLIN 4 29219
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APPEARANCES:
2 ROBERT GUILD, ESQ.
Columbia, S. C.
3 Counsel on Behalf of Intervenor, Palmetto 4 Alliance Corporation 5 RONALD L. GIBSON, ESQ.
Charlotte, N. C.
O Counsel on Behalf of Applicant, Duke Power Company 7
Also Present:
8 George U. Grier g Dt'ke Power Ccmpany Rouger Quellette 10 Duke Power Company 1
11 Glenn H. Be.ll Duke Power Company 12 Michael F. Lowe 13 Palmetto Alliance Phil Jos 14 Palmetto Allicance 15 Betsy Levitas Carolina Environmental Study Group 16 l 17 18 INDEX 19 WITNESS DIRECT CROSS 20 John C. Rogers 3 --
21 22 23 24 25 EVELYN SERGER ASSCCIATES. STENOTYPS REPORTING SERV 6CE. CHARLOTTE. NORTH CAROUNA
3 1
The deposition of John C. Rogers is taken at the 2
Corporate Offices of Duke Power Company, Charlotte, North 3
Carolina, on this the 27th day of June, 1983, in the presence of 4
Robert Guild, Attorney for the Intervenor; and Ronald L, Gibson, 5
Attorney for the Applicant.
8 All formalities as to caption, certificate and 7
transmission are waived. It is agreed that Lynn B. Gilliam, 8
Notary Public in and for the State of North Carolina, may 8
take said deposition in machine shorthand and transcribe the 18 same to typewriting.
II said deposition is taken subject alone to testimeny 12 for competency, relevancy and materiality; and all objections, I3
, save as to the form of quartions asked, are reserved until I4 the Hearing.
15 16 JOHN C. RCGERS, II having been first duly sworn to tell the truth, was examined 18 and testified as follows:
19 DIRECT EXAMINATION al BY MR. GUILD:
22 0 Mr. Regers, s'; ate your full name and business address 23 for the Record.
94 A John Clement Rogers, Catawba Nuclear Station.
_ O' What position do vsu hold at the Catawba Statien, sir?
EVELYN BERGER ASSOCIATES. STENOTYPS kEPOMTTNG SSRylCE, CHARLOTTE. NORTM CAROUNA
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A Project Manager.
2 0- You are employed by Duke Power Company; are you not?
3 A That's correct.
4 Q How long have you held that position?
5 A Sir; at Catawba for two years.
6 Q When did you become Project Manager, sir?
7 A 1971.
g Q 1981, sir?
9 A '71 I was Project Manager at McGuire; I'm sorry.
10 Q When did you become Project Manager at Catawba, sir?
11 A January 1st, '
81.
12 Q All right, who preceded you in the position of 13 Project Manager at Catawba?
14 A D. G. 3eam.
15 Q Rcw long had Mr. Beam been Project Manager, if you 16 know, sir?
17 MR. GIBSON: Excuse me, Bob; I am sorry not to 18 have remembered before we came in --
19 (Discussion off the Record.)
20 21 BY MR. GUILD:
22 0, Mr. Rogera, my name is Robert Guild, Counsel for 23 Palmetto Alliance in the Catawba Licensing case; and I wondered 24 if you are familiar with the fact that my clients have raised 25 m question about quality assurance in construction at Catawba.
Evg(TN SERGER ASSOCIATES. STENOTYPE REPORTING SERvtCS. CHARLOTTE. NORTM CAROLJNA
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, , Rogsrs - Direct. 5
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l 1 Do you understand that? !
1 2 A What is the nature again? ;
l 3 Q It is not a trick question. I am trying to see if 4 you at least have an understanding that Palmetto Alliance allega s 5 that the quality assurance at catawba was inadequate during 6 construction. Do you understand that to be the case?
7 A Yes, sir.
8 Q I want to show you a document, Mr. Rogers; and this j 9 is a reopense by Duke Power Company dated December 31st, 1982, to to some interrogatories served by Palmetto Alliancer and I ask 11 you to look at Page Three of that document, and there is an 12 indented, single-spaced quotation of the original text of 13 Palmetto Alliance, Contention Six.
14 Just taks a look at that if you would.
l l 15 A Here or all the way (indicating)?
16 Q All the way down, sir, if you would; that quotation.
17 All right, sir, have you seen that Contencion Six before, sir?
18 A Not to my knowledge, 19 Q All right, that taxt that you have just read reflects 20 a centention that Palmetto Alliance has filed in the licensing 21 case, Mr. Rogers, and one that has been further modified and has 22 been admitted for litigation by the Licensing Board that will 23 consider the Licensing Application by Duke Power Ccmpany.
24 Under the Board's order we are here today taking your 25 deposition to obtain some information concerning the subject EVELYN SERGER ASSOCIATES. STEN ^TYPt ptPORTING SERVICE. GM49LOTTE. NORTM CAPMUNA
Rogara - Diract 6
i specifically of quality assurance and quality control regarding 2 welding at Catawba.
3 I would like to be informal in asking you questions.
4 If I ask a question and you do not know what I am talking about 5
or do not understand something that I have said, please stop 6 me and try to clarify. Othe:: wise I will ask the question and 7 the answer will appear in the transcript and I will assume that 8
you understood the question the way I intended it and this way 9 it was asked.
10 Are you generally familiar with the documents that we 11 have been discussing for some time now as the Catawba Welding 12 ' Inspector concerns?
13 A Generally familiar.
14 Q By that you understand references to complaints by a l '. number of Quality Control Inspectors raised in late '81 and '82 16 concerning quality assurance and welding at the Catawba site? ,
17 A Rephrase that question, please.
18 Q Sure; I want to make sure we agree on a shorthand 19 teference so I don't have to go through the detail each time I 20 mm referring to it. You know what I am talking about when I 21 :
refer to the Catawba Welding Inspector complaints?
22 A Yes.
23 O And you wil3 agree that a number of Catawba Welding 24 ::nspectors filed technical and nontechnical concerns in late 25 1981 and early 1982, and the Company responded by organizing a EVELYN EERGER ASSOCIATES. STENOTYPE REPORTtNG SERVICE. CMARLOTTC. NORTM CAROUNA
Rogcro - Dircct 7 1 task force and investigating those complaints; and there is quit a 2 a bit of effort and paper work that reflects that-general subjecb?
3 A Yes.
4 0 You were Project Manager during that period of time 5 when those complaints were brought to light, were brought to Duk n 6 Management; and during the period since when those complaints 7 were investigated, were you not?
8 A Yes.
9 Q I want to understand from your perspective, sir, 10 first some of the way the construction and quality assurance 11 have been organized at Catawba now and in the past.
12 I understand from some of the documents that I' read, 13 Mr. Rogers, that Duke at some point reorganized the assignment 14 of Quality control Inspectors to generally, in my interpretation ,
i 15 take them out from under the construction Department and place 16 them organizationally under the QA, Quality Assurance Department.
17 A That's correct.
18 Q Tell my why that happened and what lead up to that' 19 change.
20 A That was a Management decisien that I did not parti-21 cipate in.
22 O All right, sir, by Management decision, who do you 23 mean in Management that made that decision; if you know?
24 A I don't know who made the final decision. The 25 decision was made at the Corporate level.
EvtLyh SFRGER ASSOCsATES. STENOTTPE REPORTING SamvlCE. CMARLOTTE. NORTH CAPOUNA
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. . Rogcra - Dircct 8 1
Q Above the job site?
2 A Yes.
3 Q .Who would have been responsible for making that 4
decision, if you don't know the people who actually did the 5
details, whose ultimate responsibility would it have been, sir, 6 if you know?
7 A I don't know who made the final decision.
8 Q How did you learn of the decision?
9 A We had an announcement that the decision was made.
10 0 Who made that announcement?
11 A My Department Vice President of Construction.
12 Q Who did you report to?
I 13 A R. L. Dick. .
14 Q Mr. Dick is who you reported to?
15 3 7,,,
16 Q When did this happen, if you can recall?
17 A Early '81; I think that is right.
18 Q What is your. understanding for the reason for the 19
- change?
20 A I don't know; I can't say the exact reason for the 21 change.
22 Q I want to know what your understanding is, Mr. Rogers .
23 What were you informed; what did you come to believe? What was 24 your understanding of the reason for the change, or if you 25 don't have any understanding, iust say that.
EVELYN SERGER ASSOC 4ATES. STENOTYPE REPORTING SanvlCE. CHARLOTTE, NORTN CAROUNA
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Rog2r0 - DirGct 9 1 If you don't know why they did it, it is all a 2 mystery to you, I appreciate your keeping it candid with me.
3 A It is an administrative change as far as administra-4 tion of t.he project control.
5- Q How was it explained to you and who explained it to 6 you, if anybody did, sir?
7 A I can't recall having an explanation.
8 0 All right, sir; help me understand then what the 9 change meant. Before the change who did the OC we3 ding 10 Inspectors report to, Mr. Rogers?
11 A The QC Supervisor.
12 Q Who was that?
13 A I don't know who it was at Catawba, I den't think.
14 Q Let me see if I can refresh your recollection then.
15 I want to show you a document dated March 25, 1983; and it is in re-16 sponse by Duke Power,'to Palmetto Alliance follow-up interrogatorie 17 On Page Nineteen and Twenty there appears a list of 18 names of persons at Catawba responsible for the OA Program.
19 Take a look at that and see if you can, from that, tell me who 20 the Welding Inspectors would have reported to prior to the 21 reassignment (indicating).
22 A They reported through Thies, I am trying to think 23 who was below " ties.
24 Q Who is the gentloman you have identified there?
I 25 A Thies was the Project Engineer reporting to the EVELY8e SERGER ASSOCIATES. STENOTTPE REPOFTING SERvtCE. CHAR'.OTTE. NO8tTM CAROUNA
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, , Rogars - Dircct 10 1 Project Manager.
2 Q What are his initials?
3 A L. A.
4 Q What is his title?
5 A Project Engineer.
6 Q QA Engineer?
7 A Project Engineer.
8 Q All right, sir, and who else did Mr. Thies or the 9
Project Engineer supervise besides the Quality Control Inspectory?
10 A He didn't supervise Quality Control Inspectors 11 directly. There was a man between him, and I am trying to find 12 out who it was. At McGuire where I was it was Milt Starnes; 13 that was where I was at that time.
14 He was over the QC Inspectors at McGuire who reported 15 at McGuire.
16 Q This was befora your time?
17 A Bofore my time.
18 Q The change occurred before yct became Project Manager?
19 A That's correct.
20 Q And at that time Mr. Beam was Project Manager?
21 A That's correct.
22 O Maybe I can expedite matters and ask him about this:
23 who did the QC Inspectors report to at that time before you beca me 24 Manager?
25 A The QA Manager is Larry Davison.
EVF. LYN SERGER ASSOCIATES. STENOTYPE RSPORTING SERVICE. CHARLOTTE. NORTM CAROUMA
Rogtra - Dir:ct 11 1 Q Is that who the QC people reported to after the 2 change and now report to?
3 A Yes.
4 Q And Mr. Davison has been in that position since you 5 came on the job?
6 A Yes.
7 Q All right, sir --
8 A No, let me back up: I believe Mr. Morgan was when I 9 first went there.
10 0 What is first name or initials?
11 A My memory went blank on me.
12 Q Sure, take a look. I think we have Mr. Morgan on tha< :
13 list. Is that R. A. Morgan; does that sound right?
14 A I have an R. A. Morgan on my list over here.
15 MR. GI3 SON: It is Bob Morgan.
l 16 THE WITNESS: My mind went blank on the first l 17 time; I think that is correct. Morgan was the QA 18 at the time I came down.
l l
19 0 Mr. Morgan would be the Project QA Engineer; does 20 that sound right? Would that be his title?
21 A That sounds right.
22 O Mr. Davison and Mr. Morgan are both in the Quality 23 Assurance Department, not the Construction Department?
24 A l That's correct.
I 25 Q All right, Mr. Rogers; are you aware of any complaintis EWELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NOMTM C4 RouMA
Rogcra - Dircct 12 1 or dissatisfaction amongst Welding Inspectors about the effect 2 of being put under QA as opposed as under Construction as they 3 were before your time?
4 A No.
5 Q All right, sir; Mr. Rogers, are you aware of in about 6 July of 1981, pay reclassification affecting Welding Inspectors?
7 A Yes.
8 Q Tell me what you know about that. Describe what 9 happened and why it happened to the best of your understanding.
10 A I knew of it, but I was not involved in OA organiza-11 tion or why.
12 Tell me what you know about it, sir.
O 13 A I know the position was re-evaluated. I don't know 14 in what manner it was re-evaluated. It was based on a re-15 evaluation of the studies, is my understanding.
16 How did you come to that understanding, Mr. Rogers?
O 17 Who told you or how did you learn about it, whatever you do 18 How did it ccme to you r sir?
know about it?
19 A I don't recall specifics.
20 Are you aware of any complaints or dissatisfaction Q
21 amongst the Welding Inspectors regarding that pay reclassification?
22 A I am aware that there were recourses concerning the f
23 pay. I've heard of recourses concerning the pay, l
l 24 Q Okay, tali me what you know about that.
25 A very little specifically.
EVELvN SERGER ASSOCIATES. STENOTYPE REPORTING SamveCE. CHARLOTTE. NORTH CAROUNA
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, , Rogers - Direct 13 1 Q How did those recourses come to your attention, 2 Mr. Rogers?
3 A Through normal management communication.
4 0 Tell me how that could be; I am not familiar with 5 that. Give me an idea how you learned that a bunch of your 6 Welding Inspectors were filing racourses?
7 A I can't be specific; I probably heard it through 8 George Grier.
9 Q All right, sir; what was your involvement in respondi ng 10 to those recourses, Mr. Rogers?
11 A None whatsoever.
12 0 Did you ever talk to the Welding Inspectora about 13 their ccncerns?
14 A No.
15 Q Why not?
16 A I had no relations With them.
17 Q Did you perform, make any inquiry or perform any 18 investigation about the complaints by the Welding Inspectors?
19 A No.
20 0 Mr. Regers, you are going to make my job very easy 21 here today.
22 MR. GIBSON: Mr. Guild, you made a statement I 23 don't have to object to.
24 25 BY MR. GUILD:
SWELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTH CAROUNA
Rogers - Direct 14 1 Q Mr. Rogers, maybe I just do not understand enough abo ut 2 your job, sir, to know where your responsibilities begin and 3 someone else's end, or what have you.
4 Let me see if I can shortcut this a little bit: we 5 agree, we know what the subject is we are talking about, these 6 Welding Inspector concerns. Were you aware there were complaint s 7
by Welding Inspectors concerning the support they were getting 8 from Management in doing their job?
9 A Not directly.
10 Q Did you learn about those concerns indirectly in one 11 itay or another?
12 A Yes.
13 Q How did that come to your attention, sir?
14 A I learned from the special task force.
15 Q How did ycu learn about that? Did you read the 16 report?
17 A I've not read the report.
18 0 You have overall responsibility for seeing that the 19 Plant is built; isn't that a fair shorthand characterization of 20 your jcb, sir?
21 A For the Construction Departrent, yes.
22 Q And whether or not the welding is done right is mmomething that you are responsible for; isn't it, sir?
24 A Performed right, yes.
25 0 And you understand that the Quality Assurance Program EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Rogerc - Dircct
. . 15 1 is designed to provide assurance that the welding is done right 2 and in the welding area?
3 A To confirm that the welding is done in conformance, 4
yes.
5 0 And you understand that the Licensing Board would not g license your Plant unless you have an acceptable Quality 7 Assurance Plan?
8 A Right.
9 0 Isn't it a responsibility of yours to see . tat there to is Quality Assurance?
11 A Yes. It is my responsibility to build the quality 12 into the Plant. Someone else confinns.
13 Q Is that Mr. Grier sitting down here on the end 14 (indicating) ?
15 A That would be correct.
16 Q So essentially problems in Quality Assurance, you 17 leave that to the QA Department and Mr. Grier?
18 A Yes, Administration has that responsibility.
19 Q And your concern in this instance is that the welding 20 gets down right?
21 A Right.
ye Q Did you learn of any information that caused you 23 poncern about the quality of the welding work done cut there?
24 A Rephrase the question.
25 O Did you learn anything during this period of tine, EVELYN SENGC4 ASSOCIATES. STENOTTPS HWPOEFTING SEnviCE, CHARLOM. NO8rTM CAROUN4
. . Rogers - Direct 16 1 late '81 into early '82, any information that came to your 2 attention that caused you concern about the quality of the 3 welding out there?
4 A The quality of the welding or quality of the inspec-5 tions?
6 Q First about the quality of the welding; that is your 7 concern you've said?
8 A Yes - No.
9 O All right, sir; let's ask about the second, and that to is the inspection part. Didn't the information come to your 11 attention that would give you information about the quality of 12 the inspection werk, the velding inspection work?
13 A No concerns that cane to me.
14 O Did ycu ever have a Welding Inspector complain to you 15 about being harrassed by Welding Craft or Craft Supervision?
, 16 A Complain to me?
l i
l 1; q Q Yes, sir.
i
! 18 A No.
l 13 Q Complain to anybody that brought it to you?
i m A There have been complaints come to me through our 21 Employee P. elations Department Program.
m O Yes, how did those come to you, sir?
23 A Ecw does that work -- I don't understand exactly. If 24 we have a complaint that involves Construction people, there 25 would be an investigation and a repert of the investigation comes EVfLYN SERGER ASSOCIATES. STENOTYPE RSPORTING SENv3CE. CHARLOTTE. NOWTH CamouMA
Regers - Dircct 17 1 to me.
2 Q All right, sir; did you participate in any investiga-3 tion?
4 A No, I did not.
5 Q Let me see if I can refresh your recollection a littl e 6 bit here. This is one of your Company's answers to our 7 interrogatories (indicating). It is the February 28th Supplemen bal 8 Responses.
9 Let me ask you to take a look here at Page Thirty 10 Seven, Item J; and it talks about NCA 15341 dated 8/4/82. Do 11 you know Mr. Rockholt?
12 A By name only. -
13 Q Take a look at that; it goes on the next page. Your 14 name gets mentioned there, and I want to ask you about that.
15 The word " investigation."
16 A Did I participate in the investigation, this letter 17 says it was investigated. I evaluated the investigation; I 18 didn't make the investigation.
19 O That answer was done by your lawyers or somebody said 20 that you, Mr. Rogers, investigated that incident. That is what 21 it says.
22 A It says the matter was investigated by J. C. Rogers.
23 Q And that is you?
24 A Yes.
25 Q Tell ne what you know about that incident new that EVELYN SERGER ASSOCIATES. STENOTYPE RSPORTING SERveCE. CHARLOTTE. NOWTM CAROLaNA
Eoe ra - Dir;ct 18 I you have had a chance to take a look at that.
2 A I reviewsd the investigation; I did not interview or 3 interrogate or have'any participation at all. I had no direct 4
contact with either the Construction employees or the QA 5 employees. That is what I mean by my interpretation of investi-6 gation.
7 Q You look2d at the papezwork?
8 A I looked at the results of the investigation.
9 O Hould that he somebody's paperwork to you?
10 A yes, 11 Q Who did the actual investigation if it wasn't you?
12 A The investigation coming to me, I don't recall and I 13 don't see it as recorded here; but it came through the Employee 14 Relations Department, ultimately through my staff member, Steve 15 Alexander, who in Manager of Human Resources.
16 Q That is kind of Personnel?
17 A Yes, Personnel.
18 Q All right, sir; may I take that back again?
19 A Yes.
20 0 Do ycu remember anything about this incident?
21 A Yes.
22 Q Uculd you describe what you learned about it; tell me 23 what you --
24 A I don't remember all the details. I remember the 25
'ncident.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE. CMARLOTTE. PeORTM CAROUNA
, Regers - Direct 19 1 0 Tell me what you do recall, and you can take a look 2 at the document if you like, but I would like you to --
3 A This I would have to go back and review the whola 4 case again and charge and counter-charge. I said regarding the 5 hold point on the document, if it was one date it would be an 6 TCI and on another date it would not be an MCI.
7 Q Cne party being a Welding Inspecter and the other 8 party being a Craft Employee?
9 A Yas.
10 0 Do you have any independent recollection about that 11 incident other than what is reflected there in that incident, 12 Mr. Rogers?
13 A I do.'t knew whether the investigation frem my Depart -
14 ment had additional words in it or not; but the basic substance 15 is here.
16 Q You don't have any information, independent information?
17 A No.
18 Q All right, sir; are there any other errors er 19 inaccuracies in that description other than the correct 1Cn you 20 made about you not typically participating in the investigation 21 but si= ply reviewing it?
22 A I don't see anything different frem that.
23 O All right, sir; thank you. Ucw I want to show you a 24 document, Mr. Pogers (indicating). This is a document called 25 t'RC Licensee Assessnent, NUPIG 0334. I have been calling it the EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMRLOTTE. NORTM CAROLINA
Rogers - Direct 20 1 SALP Report. Have you seen that document before, the 1981 SALP 2 Report?
3 A Yes.
4 Q It has an evaluation of the Catawba Report in here; 5 have you seen that?
I 6 A I've read it.
7 O Let me see if I can find it in here. I direct your 8 attention to Appendix B1, and first tell me, doesn't that reflect 9 that the Catawba Project was rated at that time below average to along with Si==er in South Te:tas and Midland and a few others?
11 A What was the question?
12 Q That document reflects that the Catawbs Project was 13 rated below average amongst projects under construction along 14 with a couple other Plants, including Simmer and Midland? You 15 knew it was rated below average?
16 A Yes, I knew that.
17 0 You join the company of Midland and Simmer Plant; 18 did you know that at that tire?
19 A I read the report. I read there were other plants; 20 yes, sir.
21 2 Under the Catawba evaluation you were aware that the 22 Review Board found weaknesses in Quality Assurance?
23 A That is what the report states, yes.
24 0 You are aware that they found there had been a rela-25 tively large number of iters of non-conformance when cenpared EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROWNA
Rogers - Direct 21 I
with other reactor facilities under construction?
2 A That is what the report says.
3 Q That evaluation was for a period just berore you were Project Manager?
5 A As far as June, '81; it was; yes, sir.
6 Q So you weren't Project Manager during the period of 7
ftime they were evaluating here?
8 A That's correct.
9 Q But you were aware of this report when you became 10 Project Manager?
11 A Yes.
Q What corrective action, if any, are you aware of 13 taken by Duke Power Company to correct the weaknesses found in 14 this report in construction at Catawba?
A I don't agree there were weaknesses.
16 Q You don't know of any weaknesses? You disagree with these conclusions by the NRC7 I mean if you do, that is fine.
18 A They are not documented there, the basis of the 19 weaknesses are not documented.
%~
Q My question is you disagree with that conclusion?
01 A I didn't intend to state that.
Q Do you agree with it or disagree with that, or do 23 You not know?
24 A Those are not specific enough. You asked the question 25 what specific actions had been taken.
EVELYN SERGER ASSOCIATES. STENQTfPs RepcRTtNG SERvlCE. CHARLOTTE. NORTM CAROUNA
Rogers - Dircct 22 1 O You stated you did not agree these were weaknesses.
2 If that is your position, that is fine. Then I guess the follow -
3 up question I was trying to get you to address, are you aware of 4 any corrective action that was taken to address those findings?
5 A There are no basic changes in the Welding Program.
6 O Any changes significant at all?
7 A No basic procedural changes.
8 Q How about changes of significance in the Quality 9 Assurance Program as it relates to welding?
10 A I can't speak to that.
11 Q Do you knew of any?
12 A I can't speak to that.
13 0 You just don't know; is that correct?
14 A I can't speak to that.
15 Q I'm not sure I understand the use of your word. If 16 it is a matter of you lacking knowledge, then I would like for 17 you to state so, Mr. Rogers. Otherwise I have to interpret your 18 answer as refusing to answer the question.
19 A What time frame are you talking about?
20 Q Any time.
21 A To present?
Z? Q Yes, sir; I'm talking about changes, corrective 23 action taken in the Quality Assurance Program as it relates to 24 aciding that address the identified deficiencies that the NRC 2 describe in that document.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERV CE. CNANLOTTE. NORTN CAROUNA
. i'.ogerc - Direct 23 1 A I can't recall from memory the deficiency specifics 2 as spelled out, the deficiencies there. The task force that 3
looked into the QA Program at Catawba resulted in certain 4
recocunendations; and those recommendations have been implemented .
5 Q Are those the recommendations that addressed correcti ve 6
actions for the deficiencies that were found in the SALP Report 7 as far as you know?
8 A They would address some of them.
9 Q How about the ones they do not acdress? Is there other 10 corrective action that you can tell me about now?
11 A There have been procedural changes which affect both 12 the QA Department and the Construction Department, clarification 13 of procedures.
14 Q And are those spelled out in the Task Force Report 15 and racommendations?
16 A I don't know the specifica -- the task force, yes, 17 Oh yeah. I am confusing with this report and the task force, 18 yes, there were procedural changes.
l 13 Q You are talking about procedural changes in Quality 20 Assurance. How about any procedural changes in Quality Assurance t 21 hdConstructionthataddresstheweaknessesthatNRCtalksabout i
22 in this document?
23 A Well, die weaknesses were not specific here. It does 24 isot state any specifics at all.
25 Q You are not aware of any that address those?
EVELYN SERGER ASSOCIATEF STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Rogers - Direct 24 1
A Any specifics, but those are just general there.
2 O You are not aware of any that address those?
3 A Any specifics would be encompassed in the general --
4 those are general. To say " deficiencies" if any specific 5
deficiencies are addressed, it would enhance the general.
6 Q That is the extent of your knowledge?
A Yss.
Q How about Catawba? Catawba received a relatively 8
large number of non-compliances when compared with other 10 reactor facilities under construction. Again, that was before your time; but were you aware of that observation by the NRC 12 when you became Project Manager, too many NCIs?
A Define "too many NCIs"?
Q Were you aware of their criticism?
A I was aware of the number of NCIs.
16 Q Were you aware of that criticism?
17 A Yes, they documented too many NCIs.
18 Q What did Duke do since you have been at Catawba to 19 address that finding of too many NCIs?
! 20 l A The number of NCIs address several things. They 91
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address activities to start with.
O Explain that for me, if you would.
93
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! A The volume of work accomplished is greater opportunity l 24
. for items of discovery that may be on a percentage basis on a 25 number of items completed, so the number of NCIs is not necessarily EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE, CHARLOTTE. NORTM CAmouMA
, Rogers - Direct 25 1 a time frame in the number of activities in the Plant.
2 Q Were people working faster at Catawba than the other 3 Plants as far as you know?
4 A I'm not familiar with the other Plants, the numbers 5 to me is not necessarily -- I know it is a detriment in a given 6 period of time.
7 Q All right, well, the NRC says most of these items 8 were attributed to weaknesses in the Quality Assurance and 9 lacking Management process.
10 They said there were problems.
11 A They do not define "too many" as it relates to other 12 Plants.
13 0 They do not attribute it to doing work at a greater 14 rate?
15 A I don't think so.
16 Q Co you?
17 A I cannot evaluate to me how much is too many? I 18 don't know.
19 Q As far as your experience you did not identify a 20 problem when you were at Catawba about too many NCIs?
21 A You are constantly striving to reduce the number of 22 NCIs in any case.
23 Q IInve you been constantly striving to reduce the .
24 number of NCIo?
25 A yes.
EVELYN SERGER ASSOCIATES. STENOTTPE REPORTING SamvK.E. CHARLOTTE. MONTH CAROUNA
, , Rogera - Direct 26 1 Q How?
2 A By improving the quality of the work.
3 Q How have you been striving to reduce the number of 4 NCIs by improving the quality of the work?
5 A State your question again, please.
6 Q Sure, you say you have been reducing the number of 7
NCIs by improving the quality of the work.
8 A I didn't say that.
9 !
Q Maybe I misunderstood what you said. Did you say thai:
10 you could do that or did you say that is what you are doing?
. 11 A I said thac is one way of reducing the number of 12 3CIs, by improving the quality of the work.
13 0 You are not saying you have not done that? If you have, 14 E want to know how you have done that.
15 A There is no way out of that box, sir.
16 MR. GIBSON: Speaking of boxes, my time says 17 it la five o' clock.
18 MR. GUILD: If we forebear slightly, we might 19 be able.to excuse Mr. Rogers pretty quickly if you 20 would be kind enough to bear with me.
21 MR. GIBSON: When you say "a few minutes," are 22 you saying less than five?
23 MR. GUILD: I don't know; I would be happy to
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24 have Mr. Rogers cm.e back.
25 IIR. GILSON: If you think you can finish in a gVELYN BERGGR ASSOCIATas. STRNOTYPE REPOprnNe SSRviCE. CNARLOTTE. NORTM CAROUNA
Rogers - Direct
_ 27 I
couple minutes, let's try to do that.
2 iiR. GUILD: I think we can if we try to cut 3
through these. questions.
4 MR. GIBSON: Let's go for about five more 5
minutes; is that all right with you, Mr. Rogers?
6 THE WITNESS: I'm not sure where they left us 7
with the question, or what the question was.
8 9
I BY MR. GUILD:
10 Q Are you aware of any program at Catawba since you 11 have been there that was designed to reduce the number of NCIs; 12 and if you are I want to understand what it is, sir.
I3 A You say " program"?
Q Yes; program, policy, activity, anything. You help 15
- ne out and we will try to get done in five minutes. Otherwise 16 it will be back tomorrow afternoon, Mr. Rogers.
17 A One thing, communications from our Supervision, 18 Management down through Supervision on the quality. Management I9 has been increased since the time I have been there. We have 20 i
nstablished a Quality Awareness Program.
2I It has been going on one year since I have been there, 22 Q All right, sir; tell me about the Quality Awareness 23
- ?rogram then. Who is in charge of it?
24 A People come in to my office.
25 Q You are?
EVELYN SENGER ASSOCIATES. STENOTYPE REPORTING SERVtCE. CHARLOTTE. NOWTM CAROUNA
,-.,.--,.----,..,----r-- - - - - , . . . - - , - , . , , - , _ . , . - - - - - - . . - - - - - - - - - - . . , ~ , - - , - - - - - - . - - - -
Rogers - Dircct 29 1
A Yes.
2 Did you delegate that to anyone in particular?
Q
)
3 A Yes.
4 Q Who did you delegate that to?
5 A Quality Awareness Teams formed in the Craft 6
Organization to cover all major crafts.
7 Q All right, how about in welding?
8 A There would be one in the welding area.
9 Q Who would be in charge of the Quality Awareness Team?
10 A They are rotated on a rotating basis.
11 Q Who is in charge now?
12 A I can't tell you.
13 0 Uho would know if you don't know?
14 A It would be a matter of record at the site. I think 15 nine teams, I think; and each one made up of a Chairman and 16 five or six crew members made up of various crews.
II O Do you have a document with you today to help you I8 remember who is on the Quality Awareness Team for welding?
A No.
oo Q I am interested in asking questions about that, if 21 that is what you have done to reduce the number of NCIs. This
.w
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is a list of other people whose depositions will be taken (indi-23 cating). Take a 1cok at that list and tell me if it is any of 94
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those people.
25 A I couldn t te11 you frem memory, I don't think.
8 EVELYN SE AGER ASSOCIATES. STENOTYPE REPORTING SERYlCE. CHARLOTTE. NORTM CAROUNA
Rogers - Direct 29 1
Q All right, sir; you got a Notice of Taking Deposition r 2
didn't you? Did you see your Notice, Mr. Rogers?
3 A Yes.
'. 4 Q Do you remember the Notice asking you to bring 5
documents with you that reflected your knowledge of the above 6
described matters in this case, Quality Assurance in Welding?
7
, MR. GIBSON: Mr. Guild, maybe I can do what you 8
are trying to do also and try to save some time here.
9 Are you focusing on the Quality Awareness as a 10 potential corrective action to reduce the number of 11 NCIs?
12 MR. GUILD: That is what I understood the 13 Witness to answer.
14 MR. GIBSON: As I understand that is a morala 15 type thing. I don't think it goes to the level you 16 are talking about. Why don't you focus on that and 17 it might save everyone scene time.
18 19 BY MR. GUILD:
20 Q I want to understand what addresses the number of 21 liCIs; and I thought you said the Quality Awareness Team addresses 22 that.
23 A I said it is an illustration of Quality Awareness.
24 Q If it is not related to the quality of work, I will 25 4eed Lw hav* Lisai.
swatyn samoan associarss. sismorvas manowfine samvice. cuantorva. monfm cAnouma
Rocarm - Direct u 1
MR. GIBSON: You may be attaching a real 2
significance to it as a program that focuses on NCIs; 3
and I'm not sure I heard that.
4 5
'BY MR. GUII.D:
6 Q Does it in your judgment reduce the number of NCIs by 7
Improving the quality of the work?
8 A I think it improves the overall quality of the work.
9 Q Do you think it improves the quality of the welding 10 Work?
11 A I think so, yes.
.12 Q By reducing the number of NCIs?
13 A If it reflects the quality of the work, that is a 14 possibility.
15 Q I need to know that if that is your position.
16 A I gave that not to address the NCIs, but as a means 17 to improve the quality of the work.
18 MR. GUILD: I'm afraid we got ourselves to the 19 point where we need to know more about that subject.
20 MR. GIBSON: So we will resume tomorrow at 21 approximately three o' clock with Mr. Rogers.
22 MR. GUILD: I notice you did not bring any 23 documents with you, sir. If you could find out that 24 information about the Welding Quality Awareness Team, 25 that .;O^ald be a help and We cGnid t&lk si,Gni Lh&L 5 EVr. LYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CNARLOTTE. NORTM CAROUNA
Reg?rs - Direct 31 1 little bit more. I appreciate it. Thank you, sir.
2 FURTHER THE DEPCNENT SAITH NOT.
3 4
(Whereupon, the Deposition was adjourned at 5 5:09 p.m.)
6 7
8 9
I have read the foregoing transcript of ry 10 Deposition and acknowledge thit it is an accurate and 11 correct statement of the proceedings.
12 13 14 15 John C. Rogers 16 17 18 19 This is to certify that John C. Rogers appeared 20 before me and affixed his signature to the above 21 statenent.
22 23 24 Notary Public 25
- 17 Cen~.ission E::piru :
EvELYN SERGER ASSOCIATES. STENOfvPE NEPO8r11h4 SEsmCE. CHARLOTTE. P*ONTH CAROuMA
. - 32 1 CERTIFICATE 2 STATE OF NORTH CAROLINA 3 COUNTY OF MECIEN3URG 4 I, Lynn B. Gilliam, do hereby certify that the 5 Deposition of John C. Rogers was by me reduced to machine 6 Shorthand in the presence of the Witncas, af terwards transcribed 7 upon a typewritor under nrf direction; and that the foregoing is 8 a true and correct transcript of tha proceedings.
9 I further certify that these proceedingo wara taken 10 at the time and place in the foregoing caption specified. I 11 further certify that I am not a relative, counsel or attorney 12 for either party or otherwise interested in the outcome of this 13 action.
14 IU UITNI:3S iiHEREOF, I have hereunto set my hand at 15 day of July, 1983.
Charlotte, North Carolina, on this the 16 17 LYNN B. GILLIAM I8 Notary Public 19 20 My Commiss on Expires: May 12, 1338, 21 22 23 24 23 i
systvm eenosa asscciates. sisNortpa mepontiNo senwice. cManLotta. MontM camouma 1
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