ML20078L738
| ML20078L738 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 06/28/1983 |
| From: | Desi Beam DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20078L617 | List: |
| References | |
| FOIA-83-434 NUDOCS 8310240053 | |
| Download: ML20078L738 (81) | |
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1 GIIED SDm!S OF JHIRICE NOCLEMt REGIA'IGtY CCBamutTrM BEFGtE ME ATCHIC Sh7ETY AND LICERENG BCNID 4 #
"s In the matter of: ). * , c!
DUKE PCHER C014%NY, ET AL ) Docket Mos.
(Catamba Nuclear Station ) 50-413 thits 1 and 2) )
50-414
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a 8310240053 830810 PDR FOIA PDR AHLERS83-434 r\.
Evelyn Berger Assocists .
STENOTYPE REPORTING SERVICE P. O. BOX 19444 CHARLOTTE. NORTH CAROLINA 30819 - . .
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The deposition of D. G. Beam was taken on the 28th day 2
of June 1983 at the legal offices of Duke Power Company, 500 3
South Church Street in Charlotte, North Carolina.
4 APPEARANCES:
5 For Duke Power Company -
Ronald L. Gibson, Esq.
951 South Independence Blvd.
6 Charlotte, North Carolina 7
For Nuclear Regulatory -
George Johnson, Esq.
Commission Office of the Executive 8
Legal Director Mail Stop 9604 9
U.S. Nuclear Regulatory Commiss Lon Washington, D.C. 20555 For Palmetto Aliance -
Robert Guild, Esq.
II 2135 1/2 Devine Street Columbia, South Carolina 29205 13 (The deposition commene,ed at.8:20 a.m.) ,
14 D. G. BEAM, 15 having been first duly sworn, was examined and deposed as 16 ggyyg,,,
II BY MR. GT'ILD :
I8 0 Would you state your name for the record, please?
19 A I am D. G. Beam.
O And your address, please?
21 A 120 Forest Drive, Belmont, North Carolina, 28012.
22 S Mr. Beam, have you formerly been employed by Duke Power 23 Company?
24 A Yes.
Q In what capacity most recently. mir?
EVELYN SENGER ASSOCIATES. STENOTYPE REPOWme SERVICE. CHARLOTTE. MONTM CAROL 3NA
4 ,
d) 1 A Project manager, Catawba.
2 0 And when were you last serving that capacity?
3 A June 1981.
4 0 And tell me just briefly the circumstances under which you 5
left that job.
6 A I retired.
7 0 Are you employed now?
8 g yo, 9
0 You are retired?
10 A I am retired.
II G Are you serving in any kind of consulting capacity with 12 the company?
13 A No.
I4 0 With Duke Power Company?
15 A No.
16 0 or any other consultir g work you do?
I7 A No, I have done some last year.
I8 G What was'the nature of that work, sir?
A Nuclear construction.
20 0 For whom did you do that?
2I A WPPSS, Washington Public Power Supply System, WPPSS.
22 G Some people call that supply system these days?.
2 A It is better known as just the supply system.
24 0 Worser known as WPPSS.perhaps. What was the nature of yout 25 consulting work for them, sir?
IVELYN SERGER ASSOCIATES. STENOTYPE REPONTING SERVICE. CHAFE.OTTE. MOPTH CAROUMA
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1 A Schedule, budget, feasibility.
2 0 When did you become project manager at Catawba station, 3 Mr. Beam?
4 A '74.
5 g Were you manager at the time construction commenced at 6 Catawba?
7 A Yes.
8 g All right, sir. Pardon me for not starting this way, 9 but my name is Bob Guild, and I am counsel for Palmetto Alliance.
10 You may know we are the intervenor in the coerstinc licensing 11 proceeding for the Catawba station, and we hcve filed for litiga-12 tion a contention that has been referred to as contention 6, 13 that relates to quality assurance in construction at Catawba.
14 Are you generally aware of those facts?
15 A Generally aware. Contention 6 didn't mean nodting to me 16 but geatrally aware by the news media.
17 0 I am going to show you a document which is a company 18 response to a set of questions, interrogatories that Palmetto 19 Alliance served on the company. It is dated December 31st, 20 1981, and it's entitled " Applicant's responses," and there is a 21 page 3, and following is a quotation of the text of contention 22 6 as it was originally filed in the case and as it was 23 received for litigation originally by the licensing board. If 24 you would just take a few moments, Mr. Beam. It is the indented 25 quotation that appears beginning on the bottom of page 3 and EVELYN BERGER ASSOCIATES. STENOTYPE MPORTING SERvlCE. CMaRLOTTE. NORTM CAROUMA e
e 4 1
over to page 4. And just take a moment to familiarize yourself 2
with that. That's going to be the subject of our questioning 3 today.
4 MR. GUILD: Counsel, while Mr. Beam is looking at the My name 5 document, can we3dentify the people in the room?
6 is Bob Guild. I am counsel for Palmetto Alliance. And also 7 for Palmetto Alliance is Phillip John.
8 MR. GIBSON: Glenn Bell and George Grier, and Roger 9 Quellette from Nuclear Production, and I am Ron Gibson, counse3 10 for Duke Power Company and applicants.
- 11 Mr. Guild, it appears Mr. Beam has finished reading the 12 portions noted. We reiterate our position that questions 13 should be limited as indicated by the board's orders ruling on 14 your motion for an extension and ruling on the motion for 15 sanctions.
16 MR. GUILD: Yes, thank you, Mr. Beam.
l 17 4 Had you seen that contention before, sir?
18 A. No.
19 0 Mr. Beam, I want to try to first get some understanding ce 20 of the way the construction department and the quality assuran 21 department at Catawba Nuclear Station were organized during 22 the time you were project manager.
23 I show you a document. This appears as figure 17.1 from 24 amendment 6 to Topical Report, QA-1, which is the Duke Quality 25 Assurance Program. I ask you, sir, if you can identify that EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROud
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d D 1 document.
2 A Yes. l 3 0 All right, sir. What is that, please?
4 A That's the organization of the construction department.
5 0 All right, sir. And does that accurately reflect the 6 organization of the construction department when you were proje ::t 7 manager at Catawba?
8 A Part of the time.
9 G How about when it didn't?
10 A Early.
11 G That, I understand, is the most recent revision of that 12 document, so it would be the most recent?
13 A Manager of construction resources.
14 0 What does that mean?
15 A '. It is not -- this position was not in place at early 16 Catawba.
17 G Read that position again, sir.
18 A Manager construction resources.
19 0 All right, sir. What would that job involve? If it wasn't 20 in existence beforehand, help me understand who did the same 21 work, how it was organized before.
22 A Well, it as just between the project managers and the 23 vice president, R. L. Dick.
24 Help me understand.. What is that position now and 0
25 what does that position entail? What does it do?
EVELYN BERGER ASSOCIATES, STENOTYPE rem SEnvet. CMARLOTTE. m CAROLINA
1 A I think today this is Jim Grogan's title, I believe.
2 O G-r-o-9-a-n?
3 MR. GIBSON: Just answer to the extent you know, Mr. Beam.
4 I realize he is asking you about present involvement and you 5 are not there, but answer to the extent vou know.
6 A All right.
7 0 And, Mr. Beam, I want to try to keep this informal but g we are making a transcription of this and so I need your 9 answers orally. I can see the document you are pointing to 10 and the rest of us can too, but ultimately this is going to 11 be on a piece of paper. Cherokee wasn't there at the point 12 where Catawba started, is that correct?
13 A That's correct.
14 0 That's a change. And the manager of construction resource:s 15 is a new position?
16 A That's correct.
17 g And when did that position come in, if you recall, just 18 generally?
l 19 A I don't know.
20 0 Was it during the time you were manager at Catawba?
l 21 A Yes.
l 22 O Any other changes that n t different?
23 A The split of station manager -- manager station support 24 division was not prevalent early at Catawba.
25 g What are the two positions you are indicating?
EVELYN SERGER ASSOCIATES, STENOTYPE REPORTING SERVICE, CMARLOTTE, NO8FfM CAROUNA
. S 1 A Manager station support of Oconee division and the Mount 2 Holly division.
3 g All right, sir. And there was not that split before 4 early on?
5 A That's correct.
6 S And who performed that function earlier on by name or by 7 title? How was it done before that split?
8 A Manager of construction services was F. M. Kennerly.
9 0 Any other changes?
10 A No.
11 O Now, I have written in psncil here a couple of names. Under 12 vice president construction, who holds that position, sir, if 13 you know?
14 A t. L. Dick.
15 g And under Catawba project manager, you formerly held that 16 position, Beam, correct?
17 A Right.
18 0 And presently Rogers?
19 A Right.
20 g All right, sir. Now, sir, I want to show you another 21 chart. This is figure 17.1, sheet 4 from amendment 6 of that 22 same document, and can you identify that, sir?
23 MR. GIBSON: Excuse me, Mr. Guild. It says 17.1-3.
24 0 Yes. Can you identify that, Mr. Beam?
' 25 A No.
EVELYN BERGER ASSOceATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTN CAROUNA
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1 4 Okay. The document is entitled " Construction Department 2 Organization, Catawba Project." You haven't seen that ;
3 organizational chart before?
4 L no, 5 4 If you hadn't seen that paper before, that is fine, sir, 6 but I understand that to be a recent document but help me under -
7 Stand how that compares with the organization of the construc-8 tion department as you know it, construction department 9 organization, Catawba project. Does that organizational chart 10
, reflect the organization of the department when you were project 11 manager?
12 A No.
13 g Tell me the differences, if you can -- first of all, let 14 me show you another docutaent. This is figure 17.1-7. It is 15 entitled " Typical Construction Department, Project Organization."
16 It's from an earlier version of this saae report. Can you 17 identify that, sir?
18 A Yes.
19 G All right, sir. Now, that second document I showed you, j 20 does that reflect the organization under you as project manager 21 when you were at Catawba? -
22 A No.
23 0 Tell me what the differences are there then. How does 24 that differ from the organization of the department when you 25 were there, sir?
EVELYN SER SER ASSOctATES. STENOTYPE REPONTwee SERwsCE, CHARLOTTE MONTM CAROUNA
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, 1 A Yes.
2 O Sure.
3 A What area are we speaking of?
4 0 I would like to understand from you, sir, if there were 5
changes during the period when you held that position, give me 6
a general idea when those changes occurred and how they compare 7
with that structure that I am showing you. I am just using 8 '
these as an illustration. If it would be easier for you to 9
just take a piece of paper and start from scratch instead of 10 trying to move these boxes around, that would.be fine as well, 11 but you just tell me what is easier to explain. I want to 12 understand how the department was organized when you were there ,
13 sir.
14 A All right. Early at Catawba I had five reporting to me, 15 the general superintendent, project engineer, safety, resident 16 cashier.
17 g Mr. Beam, let me give you a bigger piece of paper.
18 A No, this is fine right here. Just bear with me just a 19 moment.
20 0 Sure.
21 A Security.
22 g All right. That's fiva. All right, sir, and they all re-23 ported directly to you, sir?
24 L y,,,
- Which of those reporting areas was responsible for quality 4
EvtLvN 3ERGER ASSOCIATSS. STENOTYPE HEPOfrTtfoS SERvtCE. CMARLOTTE. NORTH CAROUNA
, o 1 assurance on the job at Catawba?
2 A Resident engineer -- project engineer, I mean.
3 0 Would this have been in 1974, when the project began, 4 approximately?
5 A The only way I can answer that, due to the financial 6 difficulties of '74, the plant was delayed, and let's say that 7 was prevalent mid '75.
8 O This structure was there in mid '757 9 A Yes.
10 g All right, sir. When did construction actually begin at 11 Catawba?
12 A Ground was broken under a limited work organization May 13 16th, 1974.
14 0 And was there a slowdown or a halt in construction that 15 you just referred to?
16 A There was a complete halt. The site was sewn in grass and l
17 mowed off.
18 g For what period of time, sir, approximately?
19 A Eight-nine months, plus or minus.
l 20 0 All right, sir. Until early or mid '757 21 A I believe June of '75.
i 22 O And then construction commenced again?
23 A Yes.
24 0 And so in effect construction began in earnest in 25 mid '75, is that a fair characterization?
EVELYN SERGER ASSOCIATES. ETENOTYPE REPOftTweG SERVICE. CHARLOTTE. NORTM CAROLAA
1 A Yes.
2 g So when we are talking about organizational structures 3 at the beginning of construction, we are really referring to 4 mid757 5 A Yes.
6 g All right, sir. Now, again at that point the project engineer 7 at Catawba station was responsible for the quality assurance 8 work, is that right?
9 A Quality control.
10 g So help me understand now. By quality control, what do 11 you mean, sir?
12 A The quality control organization reported to the project 13 engineer.
14 g And who hold that position at that time, sir, if you 15 recall?
f 16 A Project engineer?
17 Yes, sir.
6 18 A D. L. Freeze.
19 4 Now, give me2a. working distinction that you would use 20 between quality control and quality assurance, and we are 21 talking about this organizational staff, sir.
22 A Quality control was the inspection arm. Quality assurance 23 was the audit arm anI the functional director of quality contro L.
24 4 All right, sir. Mr. Freeze as project engineer supervised 25 the inspection arm, quality control, is that right?
EVELYN BERGER ASSOCIATES. STENOTYPE REPOHTHe8 SSWWDCE. CHAMLOTTE. MONTM CAROLINA
1 1 A Not directly but yes.
2 0 In what form did he do it? Help me understand. If he 3 .didn't do it directly, how did he do it?
4 A The supervision of quality control reported to the project 5 engineer.
6 O All right, sir.
7 A There was a level of management between the project 8 engineer and the quality control arm.
9 % All right. And what would that level of management have 10 been called? Give me a title or a title and a name if you can, 11 during this period of time.
12 A The title was quality control -- no, it wasn't. It was la welding inspector -- no, it was quality control supervisor.
14 All right.
0 15
, A That don't sound right.
16 C. All right, sir, let me see if we can find another one 17 l
here among these company pepcrs and see if this is a better 18 I have a document here that is figuma17.1-8 from description.
19 amendment 1 to this same Topical Report on quality assurance.
20 Can you identify that one, sir?
21 A No. This is after my time.
22 0 This is after '81, when you left?
23 A (The witness moved his head up and down.)
24 0 I believe, if that doesn't reflect it accurately, we are 25 going to try from scratch. Maybe you can do a better job than EVELYN SENGER ASSOCIATES. STENOTYPE HEPOHTHeG SERvlCE. CNAHLOTTE. NOfrTN CAHOUNA
1 the people who draw the picture for the reports. That should 2 have been from the '74 time frame, Mr. Beam.
3 A Well, it looks like it could be except --
4 0 Tell me what looks wrong or right about that and then 5 we will go from there.
6 A All right. I guess that --
7 4 What is troubling you, Mr. Beam, about that, according to 8 your recollection, how -things were organized? -
9 A This is an organization for QAt 10 g Yes, sir.
11 A Not QC. And this QA, I believe, was prevalent at the time 12 Catawba started.
13 g All right, sir. Now, who was: responsible at that time,
'4 say mid '75, for quality assurance at Catawba site?
15 A Bob Morgan was my first reaction. We are going back to 16 '74 or '75. I still believe it was Bob Morgan.
17 g All right, sir. And would Mr. Morgan, or if it wasn't,
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18 would someone else, the position of project QA engineer, in 19 charge of QA at the site?
20 g gg, y, 21 g All right. That project senior QA engineer was not in 22 charge of quality control, the inspection arm, is that right?
23 A He was functionally in charge of quality control.
24 g All right, I see. Now, in what respect was he not in 25 charge of quality control? Help me understand the distinction i
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. o I between functional and what other type of supervision we are 2 talking about.
3 A Another type of supervision was administrative.
4 4 All right. How about giving me your working understanding 5
of those two terms and how you mean them, sir.
6 A QA could direct QC in their day-to-day task. Administration 7
was pay, discipline, promotion with input from QA.
J 8
G Let's take a hypothetical. Let's say I am a welding 8
quality control inspector at Catawba site in this period of 10 time, mid '75, and I have, as I understand you, two bosses.
11 I have got ultimately Mr. Morgan, or whoever else held that 12 position of project senior QA engineer, and I have also got I3 a project engineer who we believe is Mr. Freeze at the time, I4 ultimately. Now, in what ways would I as a welding inspector 15 be reporting to each of those two gantlemen?' What would I I
I6 look to each of them for supervision on?
II A Well, the time frame is bad. We will have to get into I8
'76.
I8 G Okay, 20 A You would look to the QC staff for job assignment, 21 dirsction as to reporting hours for your tools and supplies, 22 like I said, your pay, hiring, firing, administrative-type, 23 and you would look to QA for the actual route to take, the 24 method of carrying out the inspection according to procedure.
25 0 All right, sir. % s the distinction between those two -
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1 types of supervision, the administrative and the functional, 2 clear at all times in your ' judgment?
0 A Yes. / -
4 Q Who was respondible in this administrative functiondl 5 distinction for scheduling cons'iderations, Mr. Beam?
6 A Scheduling Ch work? \
7 Q Yes, sir. ,
7 8 A .I would say that was a joint effort between project engineerg 9 and senior QA engineer.
10 0 Joint effort between QC and QA?
11 A Yes.
12 O And is it fair to concludeL. oint effort between constructi on 13 and quality assurance?
. I 14 A fYes. x 15 % 23acause the QC organination reported tio the project t-16 engineer, who reported to yoa, and that was' construction?
17 L yes, ;
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18 0 Whereas-the QC also reported to Mr. Morgan?
19 A Yes.
i 20 The --
0 t 21 A Senior QA engineer.
22 % Senior quality assuranceLongineer, and that is the quality 23 assurance department?
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24 A Yes.~ %' l, 25 And that senior quality insurance engineer reported off 0
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1 1 site to the corporate quality assurance manager?
2 A That's correct.
3 S Who was Mr. Wells at the time, is that right?
4 A Yes.
5 G And is Mr. Grier now?
6 A That's correct.
7 0 Now, did that form of organization exist at Catawba site 8 during the remainder of your period of tenure as project managar, 9 sir?
10 A No.
11 0 Tell me when it changed and how.
12 A Which organization?
13 G Both of them now. I am interested in the quality control 14 function as it reports to whoever supervised it, QA, construction.
15 A What we are talking about, not site organization but QA, 16 QC organization.
17 G To the extent I need to understand the site organization 18 changed too for this purpose, help me to understand that too.
19 A Not lone p;. tor to my retirement, QC was moved into QA, 20 and I an s qq . ' . don't have -- I believe late winter or early 21 spring of '81 but I am sorry, I can't --
22 G All right. We can pin that down in time otherwise. ,
23 Describe how that change took place and what the change actuall:(
24 meant in terms of the change in organization, sir.
25 A QC, as a unit, was moved from the construction department av tvu .. .. ...ociar... stenorrea ==,oarw.e .savies. caaawits aoava c^aoun.
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i 1 into the QA department.
2 4 All right, sir. The quality control inspection function 3 then no longer reported to the senior QA engineer?
4 A No.
5 G No longer reported to Mr. Morgan?
6 A No --
7 0 or whoever held that position?
8 A Well, they did, yes.
9 0 All right.
10 A I mean they were combined.
11 % I am sorry, let me restate that. I lost that track as 12 well. At the point of this most recent change, just before 13 your retirement, quality control no longer reported administra-14 tively to Mr. Freeze or his successor, the project engineer?
15 A That's correct.
16 B And instead, they reported -- they were moved under 17 quality assurance, and that would have been under whom?
18 A Under Morgan.
19 0 Under Mr. Morgan, who was the senior --
20 A Senior quality assurance engineer.
21 0 All right, sir.
22 A I am trying to rack my brain hera. It might have been 23 Davison at that time.
24 0 All right. Larry Davison? I think we can help you with 25 some time in there. This is the March 25th responses to EVELYN SERGER ASSOC 4ATES. STENOTYPE REPORTWe6 SERVICS, CMARLOTTE. NORTH CAROUMA
l 1
Palmetto Alliance's response to interrogatories. On page 19 2
and 20 I think we have a list of persons who were responsible 3 for quality assurance work at Catawba site during the period 4
we are talking about, and if you flip over to that second page, 1
5 I think you will find Mr. Davison's name and maybe Mr. Morgan 6 as well, with some dates. Maybe that will refresh your 7 recollection.
g A This verifies that he was at that time senior QC engineer, 9 QA -- is this what he went from?
10 g You have got me, sir.
11 A In '81 he was QA manager of projects.
12 G That's Mr. Davison you are talking about?
13 A Yes.
14 0 All right. And read that title again for me now at that 15 time.
16 A QA manager projects, plural.
17 0 L. R. Davison?
13 A Yes.
19 4 And was he stationed at Catawba site? Did he work for 20 Catawba?
21 A Up until my retirement, I believe Mr. Davison had an 22 office uptown here.
9 23 % Worked here in Charlotte?
24 A Yes.
25 0 All right. But he was the boss of the quality control EVELYN SE RGER ASSOCIATES. STENOTYPE REPONTING SERVICE. CMAIE.OTTE. NOftfM CAROUNA
I welding inspectors and the other QC inspectors at the 2 Catawba site at that point?
3 A I believe at that point he was boss of QA in' the field.
4 % Now, Mr. Davison on this document is shown as holding the 5 position of senior QC engineer for a period of one month, c February 1st, 1981, to March 1st of '81. Would that senior 7 QC engineer position been the title of the job that used to 8 supervise QC7 9 A Yes.
10 0 At the site? <
11 A Yes.
12 0 All right, sir. Did Mr. Davison's responsibilities remain 13 the same during that period of time, and they just changed his 14 title? Can you help us understand what that might have meant?
15 A No, it meant that he was in QC at the beginning, did becomat 16 QA.
17 g I see. And that was the point where he became the person 18 responsible for supervising quality control work at Catawba?
19 A Yes.
20 g All right.
( 21 A Which included quality control.
22 0 Yes. For the first time?
23 A Yes.
24 G Up until that point, had Mr. Davison supervised the quality i 25 control inspection function at Catawba?
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1 A Yes.
2 g In what respect had he done that?
3 A As senior QC engineer.
4 g So then, how did Mr. Davison's responsibilities with regarcl 5 only to supervision of quality control at Catawba, how did 4 6 they change at that point, if they did?
7 A To include QA.
8 g All right, sir. Now, tell me a little bit in some more 9 detail, Mr. Beam, what exactly was changed when, as you say, 10 the quality control staff was moved froa construction to quality 11 assurance. Was there a physical change in the way the site 12 was organized? Let's say, for example, the office where the 13 quality control inspectors worked out of, was that changed?
14 A Yes, it did. We built -- we used part of a model shop, 15 I believe, and just - we built a better facility.
16 g All right, sir. Putting quality assurance and quality 17 control together in the same facility?
18 A Yes, same building.
19 0 And before that change, Mr. Beam, where did the quality 20 control inspectors work out of?
21 A They were headquartered in what was originally built as 22 a mess hall building, later changed to a model shop, and then 23 QC was given a portion of that, and QA was in the main building, 24 main administration building, and during the rennovating there, 25 those two buildings were joined and offices - well, it was
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1 easier to put them together.
2 0 All right. Let's take welding specifically. Where did the 3
QC welding inspectors work out of before the change?
4 A In the QC portion of the same building we were just speaking 5 of, 6 g All right. And where did the welding work out of?
1 A Across the street from another building.
8 G How far distance just physically from where the QC welding 9 inspectors were?
10 A Fifty yards.
11 g All right, sir. Any other physical changes, tangible 12 changes, resulted from this organizational change of QC at 13 this point?
14 g yo, 15 G Help me understand, Mr. Beam, how this change took place 16 and why it took place, as best you understand why it did. ,
17 A When I say "we," I am talking about the vice president and 18 staff.
l 19 G Who would that be, sir?
20 A The project managers.
21 g Vice president?
i 22 A And his project managers.
23 g l Who was the vice president? Who do you mean?
24 A Bob Dick.
25 G Mr. Dick?
EVELYN SERGER ASSOctATf S, STENOTYPE nsPORTING SamvCE. CHARLOTTE. NORTH CAROL 8MA
I A Had talked of this and I - the time, you know, you would 2
,,y, ,,17.,-maybe this isn't the time. Anyhow, it just got 8
time that QC should come under and be a part of QA. The time, 4
the change in time, it was the appropriate thing to do for a 5
better functioning organization.
6 All right, sir. What specific improvements were expected from the change, if you know?
A All right. We would remove construction, the actual 8
building process, from the administrative task of fooling with 10 QC. It would give QA full authority to control the inspector team.
12 4 All right, sir. Why was that a good thing, in your I
judgment, if it was?
A It was a good thing because as we discussed earlier, it 15 was functioning that way. I mean QA had that functioning 16 i authority from day one, and it just seemed the. thing to do, i
I G All right. Let's look at the other side of that coin.
18 Why wasn't it organized that way from day one?
19 A In my opinion QA, QC group, it started small, grew medium, 20 it turned into large, and in a growing process changes must be 21 made to better manage.
22 O And this was one of those changes?
23 A Uh-huh, yes.
24 O All right, sir. Now, when you talk about the QA, QC, 25 growing, was.it growing in terms of numbers of persons assigned EVELYN BERGER ASSOCIATES. STENOType Ram SERVICE. Cs4ARLOTTE. M MN
1 to the function?
2 L Yes.
3 0 More inspectors?
4 A More inspectors, more administrators.
5 g More engineers?
6 A Yes.
7 g All right, sir. Can you give me just a ballpark feel for 8 what those kind of changes meant? How about just a feel for 9 the numbers over this period of time?
10 A Well, the beginning of Catawba, QA probably had four or 11 five, and QC had twelve or fifteen, and I believe at my 12 retirement I believe something like in a combined effort there 13 there must have been a hundred plus.
14 g All right, sir. Now, that hundred plus would be all of 15 the quality assurance at the sita and all of the quality control 16 together?
17 A Yes.
18 And when you talk about at the beginning, QC, the 12 G
19 to 15 would be the total inspectors?
20 A Yes.
21 And the QA, four to five, would be the QA engineers?
4 22 A Right.
23 g And staff?
24 A Yes.
25 g At the beginning number, would that have been in mid '75, EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVCE. CMARLOTTE. NORTM CAROUNA
1 approximately, when construction actually really got going?
2 A Late '75 or early '76.
3 0 All right, sir. What caused the QA and QC functions to 4 increase in numbers over that period of time?
5 A Workload.
6 4 Was that simply the QA, QC, workload or was that tracking 7 the construction workload as well?
8 A They are the ame.
9 G All right. So the increase in workload followed the increase 10 in workload for construction?
11 A Sure.
12 0 Do I understand right, more welds being welded so you 13 needed more welding inspectors?
14 A Yes.
15 0 And more QA engineers to look at the welding function?
16 A. Yes.
17 G Now, I am going to show you this same figure again here 18 we are looking at. This is I believe from the '74 period of time 19 but this is the quality assurance department organizational 20 chart, and in that dotted box --
l 21 MR. GIBSON: Excuse me, would you read those figures 22 in the record?
23 MR. GUILD: Figure 17.1-8, and that is I believe from i
24 amendment 1 from that same Topical Report.
25 O Down here, at the bottom, Mr. Beam, in the box that says EVELYN SERGER ASSOClATES. STENOTYPE fBSPOfrTING SSpMCE. CHARLOTTE. NOfrTM CARouMA
-. , . . - - - . _ _ _ _ . _ _ _ . _ ., _ _ _ _ _ _ _ _ _ . . . . . _ ~ . _ _ _ . . , _ _ , - . , _ . . - . . . . _ . , _ _ . . . _ . , _ . . , , , _ . _ . . _ _ _ - . . _ , _
. o 1 " Field," and this identified as " Typical Project QA Organization."
2 Where is the QC inspection function, if it appears on that?
3 A Right here (indicating).
4 O Site, what doas it say there?
5 A It says senior QC engineer.
6 G And under that?
7 A Site QC staff.
8 0 And those are the inspectors?
9 A Yes.
10 S All right, sir. Now, there is a line connecting that 11 senior QC engineer and the site QC staff to the project 12 senior QA engineer, and that line has the title " Functional" 13 attached to it. Does that reflect the functional reporting 14 that you have described?
15 A Yes.
16 0 Now,if we are going to try to depict the administrative 17 reporting to construction that existed at that time, where woul i 18 the OC, senior QC engineer and QC staff fall?
19 A Under the project engineer.
20 g Which would be on a separate organizational chart?
j 21 A Yes.
22 G Reporting to you as the project manager?
23 A Yes.
l 24 4 All right. Mr. Beam, I want to show you a document that l,
[ 25 is entitled "NUREG 0834 NRC Licensee Assessments, August of '81 ."
l l
l
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l t -
l.
1 1 Can you identify that, sir?
l 2 A No. l l
3 0 Mr. Beam, this is what has been referred to as the SALP )
4 report, systematic assessment of licensee performance, and appendix .
5 B-1 of that document reflects the SALP review groups rating 6 of the Catawba facility under construction as below average for 7 power reactors under construction. Have you seen that report 8 before or that rating before?
9 A I believe I read that in the paper. I have not seen this 10 report.
11 S All right, sir. This report was published after your 12 retirement, correct?
13 A Yes.
14 0 August '817 15 A Correct.
16 S But it was for an evaluation period that is indicated in l 17 this appendix B-1 as 9-1-79 through 8-31-80, and you were 18 project manager at Catawba during that period, were you not?
19 A That's correct.
20 % Now, I want to ask you a few things about it so if you 21 haven't seen this report before -- it's only several paragraphs 22 on that page, but take a moment and examine that. We are 23 under the heading " Catawba 1 and 2," please.
24 Now, the ranking includes seven facilities that are 25 rated below average, including Catawba, and Catawba is rated l
l avstvw sanoen associaras, sTsworres murown=e seawes. c6anLorra. e camouma
l 1
in this slot along with Midland, South Texas, Zimmer, Washingtoa l
2 Nuclear Project Number 2, one of the WPPSS projects. The NRC )
3 makes a number of findings of weaknesses that I want to ask 4 you about, Mr. Beam. Their first paragraph states the Catawba 5 facility displayed evidence of weaknesses in the area of 6 quality assurance, including management and training. Were you 7 aware of criticisms by the NRC of weaknesses in the areas of g quality assurance?
9 A I knew that we had some citations from NRC for communication 10 breakdowns in a few areas.
11 g All right, sir. The final paragraph of that report states 12 Catawba received a relatively large number of items of non-13 compliance when compared with other power reactor facilities 14 uniler construction. Most of these items of noncomplianca were 15 contributed to the weakness in the licensee's quality assurance 16 management overview process. Were you aware of that criticism 17 by the NRC, not necessarily in this document, but that critician?
18 A No.
19 0 Had anybody with the NRC or with the company ever discusse :1 20 the subject of too many NCI's with you at Catawba?
21 A As you stated it, I am not sure.
22 Q Please explain.
23 A Numbers of NCI's is evident that your program is working.
i 24 You would sure be worried if there were none. We were audited 25 by a team from region 2 NRC. I don't think the exit interview EVELYN SENGER ASSOCIATES. STENOTYPE REPORTHeG SERVICE. CHARLOTTE. NORTH CAROUNA
l 1 there was specific enough to say that I had heard just what is 2 in that report.
3 0 When was that audit - this would have been an inspection 4 by region 27 5 A Yes.
6 4 When would that have occurred, if you recall?
7 A I would say fall or winter of '80 8 0 All right, sir.
9 A Or winter of '82 10 g Of '81 you mean?
11 A I mean '81, yes, somewhere in that time frame.
12 MR. GIBSON: Can we let the record reflect that Mr. George 13 Johnson, counsel for NRC staff, is now with us, has been here 14 for the last five cr six questions.
i 15 MR. GUILD: Good morning, Mr. Johnson.
16 MR. JOHNSON: Good morning.
17 MR. GIBSON: Let him take two seconds and go to the 18 water fountain.
19 MR. GUILD: Mr. Johnson, I am going to show you a notice i 20 for taking of deposition of James O'Reilley.
21 MR. GIBSON: Are applicants being served with that also as t
22 a part of the service list?
23 MR. GUILD: If we could get a couple of copies made. I 24 didn't have a copying machine available to me. I would be happr 25 to give you a copy.
EVELYN SERGER ASSOCIATES. STENOTTPE REPORTNeG SENS. CHARLOTTE. NORTH CAROL 8MA
1 MR. GIBSON: We will do that during a break.
2 MR. GUILD: Do you want to go off the record?
3 (Thereupon, the deposAtion went off the record at 9:20 4 and was resumed at 9:22.)
5 MR. GUILD: Maureen O' Brian is here for Palmetto Alliance 6 and Johnson for the NRC staff.
7 G You were beginning to tell me about NRC inspection in the 8 fall of '80, winter of '81, where the subject of the number of 9 NCI's was dealt with in some form or fashion.
10 A It was a general audit. I believe it lasted about two 11 weeks. It was a general audit, and evidently what you showed 12 me that I had not seen is part of that audit.
13 0 What I showed you may reflect that audit but this is not an 14 inspection report. This is the 3 ALP report that I will offer 15 based on previous NRC inspection.
16 A But during that time in the exit interview, I don't 17 remember that anything very derogatory coming up.
l 18 G From the region 2 people?
19 A Yes.
20 G All right, sir. Well, you understand this SALP report i 21 includes comparisons of plants and not just region 2, but this 1
22 plant with plants all around the country?
23 A Yes.
i j
24 G All right. Now then, before the break you were talking 25 about the subject of NCI's, and you were saying you would be EVELYN SERGER ASSOCIATES. STENOTYPE REPOsmMG SERVICE. CMARLOTTE. 4 WITH CAROU9GA
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l I worried if there weren't any NCI's. Let me understand what 2 significance, if any, you attach to the number of NCI's and 3 what NCI's do for you as a project manager.
4 A Well, as I stated, it proves that the program is working.
5 g All right.
6 A I don't know where too many -- I don't know the magic 7 number, what's too many and what's too few.
8 0 Let's see if I can come up with a comparison or a metaphor ,
9 Mr. Beam, and ask you what your reaction is on it. The FBI 10 publishes uniform criminal statistics every year, and they say 11 this year there were ten percent more murders than there were 12 last year, and the police department says that means we caught 13 ten percent more. We are doing a more effective job of law 14 enforcement. We are doing our job. If we didn't find those 15 listed, we would wonder who was catching whom. The other side 16 of that coin is, there may in fact be more murders committed.
17 We look at NCI's, Mr. Beam, and one explanation for having a 18 lot of NCI's is that you are doing a good job inspecting the 19 work and you are finding problems and correcting them, isn't 20 that fair? But one explanation might be that you are doing 21 more substandard work. Isn't that also a possibility, too many 22 NCI's or more NCI's?
23 MR. GIBSON: I object to the use of that hypothetical.
24 However, I am not instructing the witness not to answer. He 25 may answer or respond as he wishes. Go ahead, Mr. Beam.
l EVELYN SERGER ASSOctATES. STENOTYPE REPORTING SERV 8CE. CMARLOTTE. NORTM CANOLsNA i
1 A As I recall, a large number of NCI's dealt with dotting 2 the I's and crossing the T's. They still need to be caught.
3 They don't need to be left unattended to, and they must be 4
crossed out. The NCI was a vehicle that everyone used in order 5
to make sure that nothing got dropped in the crack or fell into 6
the gap or the void, and I never - I guess I never looked at 7
NCI's as being a detriment to good construction.
8 Is it fair to understand what you just G All right, sir.
9 said is the NCI's were of minor significance?
10 A No, I said a lot were, yes. No, NCI's require corrective 11 action, regardless of whether they were administrative or 12 whether they were workmanship.
13 0 When you say dotting I's and crossing T's, are you 14 basically referring to administrative problems?
15 A Uh-huh - no. You forget to dot an I or cross a T, that's 16 not a problem. I think everyone forgets to dot an I.
I 17 0 I say administrative efficiency or omission or something',
18 A I think it was human.
19 S All right. But it's not a workmanship problem?
O A No.
21 l g And that's the distinction you are drawing. You need to 22 catch those things, but they don't show bad work?
23 A That's correct, and I don't know what percentage was that 24 type. I am just saying that part of the NCI's were of this natare.
5 0 And that might account for the large number relatively?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTWe4 SERVICE. CMARLOTTE. NORTM CAROUNA
1 A A portion; no, I didn't say that, a portion.
2 0 Well, just give me your feel. I am really asking for 3 your judgment, and youtare in a position to know, if the NCR 4 is saying, well, we just stack up the numbers of NCI's at 5 Catawba as the concluding paragraph said, had numerous by
! 6 comparisons, just numbers, is your explanation in part, Mr.
7 Beam, that that number may reflect that at Catawba NCI's were 8 written for administrative matters, dotting I's and crossing T' s, 9 and not reflecting bad work?
10 MR. GIBSON: Object to the form. He may answer to the 11 extent that he desires to.
12 O If there is something about my question, I am not using a 13 word right or I am being unfair, please tell me, Mr. Beam.
14 I am looking for your opinion, is what I am looking for, sir.
15 A I would have t.o repeat myself. I did not relate a severe 16 workmanship problem by the sheer numbers of NCI's that were 17 issued.
l g
18 Yes. Okay. Now, I understand you to say that but let's 19 shift one more second now. Assume for a minute that the NRC, 20 when they issued that SALP report, was making a comparison of 21 work at one plant versus work at others, and they said bad things l
22 abouti Catawba. In part let's assume because they line up 23 the number of NCI's at Catawba and they compara that raw number 24 to the number of NCI:s to other plants around the country and 25 Catawba had more, as they said, what I want to understand is,
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. o 1 do you believe that your opinion that the explanation for that 2 comparison may be that at Catawba NCI's were used to write up 3 a large number of administrative problems that didn't reflect 4 bad work, whereas by comparison at other plants NCI's may have 5 been only used to deal with workmanship issuer?
6 MR. GIBSON: Objection. He may answer.
7 A Does the report say that that's what it was based on? ,
8 G Let's take a look, okay? What do you mean by that now?
9 A That the report was based solely on the number of written 10 NCIAs.
11 g Well, let's look at that. This is page B-ll again, and 12 all you have is what you have in front of you too and I am 13 going to show you. Catawba received a relatively number of 14 large items of noncompliance when compared to other power 15 reactor facilities ur. der construction. Most of these items 16 of noncompliance were contributed to weaknesses in the licensee i
17 quality assurance and management overview process. Now, they 18 seem to say, don't they, Mr. Beam, that they were comparing 19 the number of NCI's at Catawba with other reactors under 20 construetion, don't they?
21 A No, I don't see it that way.
22 0 All right. How do you see it? I am not reading the same 23 language you are. I want to understand what you think about it .
24 A I don't think that NCI's in sheer numbers would be a basis 25 for such an evaluation.
EVELTN BEfMBER ASSOCIATES. STENOTYPE REPORTING SERVICE CMARLOTTE. PORTM CAROUNA e
.m--, - - - - .----r-. --s-- -
1 0 Why not?
2 A I don't think it is that - the numbers don't mean that ,
3 much to the workmanship of the job.
4 g All right, sir. Do you believe -- is it your opinion that 5 NCI's -- that an NCI means the same thing at one plant as 6 compared to another? Is it a fair comparison to compare five 7 NCI's at Catawba with five NCI's at some place else, in your 8 opinion?
9 A I doubt it but I don't know.
10 g Well, I want your opinion.
11 A I said I doubt it but I am certainly not in a position 12 to know.
13 g Why would you doubt it if you do? Help me understand 14 why it wouldn't be a fair comparison if you don't think it is.
15 A I don't think they are written for the same things at all 16 sites.
17 g Help me understand why they might be written at one place 18 and why they might be written at another.
19 A A strong desire to do the absolute best building that 20 you can come up with. ,
21 4 All right.
22 A Which is some prevalent in the Duke organization.
23 g So you might write more because you are doing a better 24 job. You catch things that were not caught some place else, 25 is that right?
svrun . ...ociars.. .remorm a.co mme eavice. c wrra. nonrw camou=.
, o 1 A Yes, yes.
2 0 The dotting I's and crossing T's kind of things?
3 A Yes.
4 0 Was there an effort made at Catawba when you were project 5 manager, to try to observe trends in workmanship occurring, 6 recurring problems in workmanship and take corrective action 7 where trends and recurrent problems were identified?
8 A Yes.
9 0 Did the nonconforming item system form a basis for noting 10 trends and recurrent problems?
. . 11 A One of the bases, yes.
12 0 Was it a pretty fundamental important basis for doing 13 that? Help me understand what others there might be besides 14 the NCI system.
15 A Well, the graph that was issued weekly, biweekly, monthly, 16 whatever, showed you trends in-NCI's resolution rate, i 17 and then there was a staff meeting -- at my own staff meeting 18 the QA, senior QA engineer was at my staff meeting. The j
l ig communication and flow of information was free between con-20 struction management and the QA, QC group.
21 4 All right, sir. Let me stop you there so I can follow 22 this. There was a regular report that provided information 23 to you and construction management on the number of NCI's and 24 the resolution rate?
25 A Yes.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTHee SERWCE. CHARLOTTE. NOWTH CAROUNA
, . - - - , ,-,,n- - , , . - .- - , , , , . , , - . ,- - - - , - - - , . . . . - . - - . . , . , . , - - . . - - - - - - . -
1 0 Describe the format of that report.
2 A Nothing but a chart.
3 0 It was a chart?
4 A Yes.
5 g What data was on the chart?
6 A The number issued versus the number resolved, and --
7 g overtime?
8 A Quarter maybe, back to a quarter or a half a year or a 9 year. I am not sure.
10 0 A bar graph they have like each month they would show the 11 number?
12 A Uh-huh.
13 g All right, sir. And how often was that report prepared?
14 L I don't remember whether it was two weeks, a month. I 15 don't think it went over a month.
16 @ All right. So at least every month you would see a report f
17 of that sort for the previous month?
j 18 A I think we used those just about every meeting.
19 0 How often would you meet?
20 A Once a week.
l 21 G All right. Is there a name for that report, and if so, j
22 do you remember what it was?
23 A Excuse me, it was every two weeks.
! 24 0 Every two weeks. What was the meeting that you are l
25 talking about here?
EVELYN SERGER ASCOCIATES. STENOTYFE REPORTN64 SERVICE CMAIE.OTTE. NORTH CAROUNA
I A My staff meeting.
2 g All right. What was the name of this report that you are 3
talking about?
4 A Trend analysis.
5 Of noncomforming items?
4 6 A. Of noncomforming items.
7 4 Mr. Beam, you didn't bring any of those trend analyses 8 of NCI's with you today, did you?
9 A No, I didn't.
10 0 Do you have any of those documents in your custody any 1
11 longer?
12 A No, I do not.
13 0 Where would those be if you don't have them? Do you know?
14 A They are in the file system.
15 G At the plant, at Catawba?
16 A I would guess.
17 g What department would maintain those, if you know?
I 18 L QA.
l 19 g All right, sir. Do you ever recall the NRC advising you 20 that NCI's at Catawba were being written for two minor matters?
i i 21 A No.
22 g Do you believe that they were aware of how nonconforming 23 items were used at Catawba?
24 A Yes.
25 g Do you recall any criticism or suggestion or advice from a mn. .. .. ... cun.. .n om. .c.. c .um.. n. ca.oua.
T e
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a 1 the NRC about the nonconforming item system of Catawba, 2 Mr. Beam?
3 A Restate it, please.
4 G Do you recall any advice or criticism or suggestion by the 5 NRC to your people regarding the NCI's as they were used at 6 Catawba?
i 7 A NRC was not good in advising, no.
l 8 G Can you tell me what you mean by that?
9 A NRC did not give advice.
10 g Do you think they should have?
11 A Well, I thought a few timus it might be hal > *ul cut I 12 never received that help.
13 G All right. What did they do?
14 A They made their inspectioil, wrcto their y ccris .
15 0 Did they criticize you?
16 A Oh, yes.
17 G Is my understanding -- I think I am getting your drift 18 but I don't want to put words in your mouth. They may have 19 criticized you but they didn't advise you on how to do better 20 or what to do different?
21 A That's correct.
22 g Do you think the criticism could have been more construc-23 tive if they had advised you how to do different?
24 A I doubt it.
25 0 There was an NRC resident inspector at Catawba for only EVELYN SERGER ASSOCIATES. STENOTYPE REPORTts.G SERVICE. CHARLOTTE. NORTH CAROUNA
l l
i 1 a portion of your tenure there as project manager, isn't that 2 right?
3 A That's right.
4 0 Came on in 1980?
5 A That sounds good.
6 0 Towards the end of your tenure?
7 A Ye8.
g Q Did the presence of a resident at Catawba have any effect l 9 on work there, in your opinion?
10 L No.
11 0 Did that resident provide you any advice on how to do more 12 effective quality assurance?
13 A No.
14 Q Did he provide you any advice on how to do more effective 15 quality control?
16 A In a roundabout way.
17 0 Tell me about that.
18 A You had the advantage of on a weekly basis, rather than 19 on an unscheduled random-type inspection, you had the advantage 20 of being more current than lagging by two weeks, three weeks, -
even four or five weeks occasionally. That was an advantage 21 22 of having a weekly exit interview.
0 All right. How was that an advantage to you?
23 24 A It let us as managers see the probleme that he saw on a 25 more current basis, and of course remedial action could be take n EVELYN BERGER ASSOCIATES, STENOTYPE REPORTING Samv1CE. CHAMLOTTE. NORTM CANOUNA
- 40-1 earlier.
2 g In time, more timely?
3 A Yes, more timely.
4 0 You could correct problems before it was too late to do 5 anything about them in some instances?
6 A It was a current thing. It was better after the resident 7 came, as far as keeping current.
8 0 Give me an example of how that would improve things or 9 how it did improve things.
10 A We had a weekly meeting rather than a random meeting.
11 g Apply that on a specific instance of, you know, something 12 that the inspector criticized you for, if you can. Give me 13 an example, hypothetical or a real-life example if you can 14 remember one.
15 A Gosh, I can't recall, you know -- I just stated my prefer-16 ence, that it seemed like better that it was more -- you stayed 17 more Current than under the random type.
18 g I want to understand what you mean by that so if you have 19 an example you could use, either a hypothetical one or an 20 actual one that. sticks in your mind, that would be helpful 21 just to illustrate what you are saying. Take a minute, and 22 if you can think of one, that would be helpful.
23 A Other than the timeliness of making the problem, awareness 24 of the catawba construction management, I can't think of anythi ng 25 specifically -- I mean your inspection team, your enforcement EVELYN BERGER ASSOCIATES. STENOTTPE REPORTING SERV CE. CHARLOTTE. NORTM CAROUNA
o .
1 and inspection division, they were people out there that were 2 looking - I mean they were the type looking just for the 3 problezas, and that's what they were finding, and those problems 4 that we had not found, we were appreciative for.
5 g Okay. During your tenure as project manager, Mr. Beam, 6 did you ever change the system in any significant way on which 7 nonconforming items were written up?
8 A Not to my knowledge.
9 0 Did you ever change the NCI system to focus less on 10 dotting I's and crossing T's, reduce the number?
11 A Not to my knowledge.
12 g I see. And through this period of time you would know 13 if there had been a change that was a change that was directed 14 by management, wouldn't you?
15 A Not necessarily. .
16 g Why not?
17 A Because it could have been done by QA.
18 0 QA could have done a change, submitted a significant chang e 19 in the way the QC inspection function was performed, the way 20 noncor. forming items were written up, without you being told?
21 A Without me being involved in the decision-making process 22 but maybe it passed my desk.
23 0 But I mean it could have happened in a way that you 24 wouldn't have known about it. It's possible?
25 A It could have happened without being an earth-shaking event i
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NO8tTM CAROUNA
1 in my life.
2 g All right. It might have passed on your desk and just not 3 have been something that anybody brought to your attention, 4 is that fair?
5 A well, I didn't necessarily look for changes on dotting 6 Ie s and crossing T's.
7 g Right. As far as you know, the system was applied on a 8 consistent basis during the period we are talking abcut?
9 A Yes.
10 g Now, I want to talk some.in some specifica, first in some 11 general terms, but about the subject of welding inspection at 12 Catawba. How did the welding inspectors at Catawba differ 13 .from other inspectors, if they did, in their qualification, 14 Mr. Beam?
15 A I don't know.
16 0 Do you know in a general way?
17 A No.
18 g I am not trying to hold you to specifics, but do you 19 have -- is my question just one that doesn't ring a bell at 20 all?
21 A Uh-huh. You just have difference between welding 22 inspectors and other inspectors.
23 g Yes. You are not aware of any difference in qualificatior,s?
24 A Huh-uh.
25 g During the time you were project manager?
EVELYN SERGER ASSOCIATES. STENCNYPE REPORTWeG SERVICE CHARLOTTE. NORTM CAROUNA
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1 A You don't mean -- wait a minute. Restate yourEcif again.
2 g Sure. I want to understand if you are aware of any 3 difference in qualification of welding. inspectors from other 4 inspectors, say, inspectors i the civil area, the electrical 5 area, utility, 6 A Well, let me say that'ye6, I knew of the civil and the 7 electrical and the mechanical'and the welding, all had to have 8 experience in that particular field.
9 4 Each of the inspectors had to have some experience as 10 a craft in their particular field?
11 A No, no, they didn't have to have craft experience. They 12 had to have equivalent of several things, but these qualifica-13 tions of those inspectors was out of my field.
14 g All right. Whose field would they have been in?
15 L QA's.
16 g Were you aware of a pay reclassification or proposed pay ,
17 reclassification while you were pro 3ect manager that affected 18 welding inspectors?
19 A Yes.
20 0 What do you recall about that?
21 A I knew it was in the mill. I don't believe it was l
22 implemented at my retirement.
23 g Would it have happened approximately in July of '81, i i
24 just after you retired?
25 A Yes.
l l
EVELYN BERGER ASSOCIATES. STENOTYPE REPOffTING SERVICE. CMARLOTTE, NORTM CAROUNA
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1 O Why were they in the process of reclassifying the welding 2 inspectors?
3 A They weren't reclassifying.
4 0 What is your understanding as to what they were going to 5 do? What was in the middle?
6 A There was an evaluation made of the position and that 7 pay was going to be adjusted according to guidelines that were 8 used throughout the company for assigning pay to positions.
9 0 Yes, sir, go ahead. There was an evaluation made.
10 A Position analysis, position evaluation.
11 G Yes.
12 A And that pay would be assigned according to that position.
13 0 And did you understand that that would result in a re-14 duction in the pay classification for welding inspectors?
15 A Yes.
16 g What was your understanding of the basis for that re-17 evaluation?
18 A The basis for the reevaluation was the same as it was for 19 anyone at Duke Power Company. Positions were always being 20 analyzed and assigning pay according to that position. It 21 wasn't just welding inspectors.
22 O Right. Why did .it have this e.ffect on welding inspectorsP 23 A Which effect?
24 0 The effect of reducing their pay.
s A According to the evaluation, it resulted through whatever EVELYN SENGER ASSOCIATES. STENOTYPE REPOffTING SERVICE. CHARLOTTE. N05rTH CAROUNA
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I they were overpaid.
2 0 Do you remember why? Can you give me a-general description 3 of why it resulted in showing they were overpaid?
4 A Management's earlier understanding of the requirements.
5 We are in a growing situation.
6 0 Right.
7 A Requirements change.
8 0 Right.
9 A Management philosophies change; requirements of individual s to change.
11 O Right. What were those changes as they affected the welding 12 inspector position, Mr. Beam, if you know?
13 A The welder inspection -- the change of welder inspection 14 was no different frcen the change in any other classification 15 that got reevaluated.
16 0 Right.
17 A They were just one of other reevaluations.
18 0 Yes. I appreciate your answer but I want to focus on the 19 welder inspectors and I want to understand why it happened 20 that it affected them in turning out to show they were overpaid 21 and resulting ultimately after your time in reclassifying 22 by hearing the pay grade, if you know.
23 A Well, it might go back to sometime in the past, when we 24 thought that a welding inspector must be a top-line welder.
25 0 And they were at Catawba, weren't they?
1 A I don't know whether that is all inclusive or not.
2 g All right, sir. That's fair.
3 A They were at earlier sites I am pretty sure because every-4 body thought that a welding inspector must be the very best 5 welder you have got on the site. I don't know whether that 6 solely is the reason or not but our own thinking at that time 7 was that he had to be the best welder you had.
8 0 All right. And they were the best welders at earlier site s, 9 Oconee site?
10 A Uh-huh.
11 0 McGuire perhaps?
12 A Perhaps.
13 g What is your opinion about the welding inspectors at Catawba?
14 Do you still have that philosophy they should be the best welde r 15 before you are a welding inspector?
16 A I don't know at this time I share that philosophy or not.
17 I am not sure that I did.
18 G All right.
19 A I would guess that people teach welding that aren't first-20 class welders in our colleges and universities, community 21 colleges today.
22 O Right.
23 A And I think they are probably good teachers.
24 O All right. How about at Catawba, people teach welding 25 at Catawba that weren't first-class welders?
.m.. . . .. .....m .. m.m. - ; . 4 .. .-m. - -
1 A I doubt it.
2 O You try to have first-class welders teaching?
3 A I think most of our instructors were above average. ,
Above average. How about your welding inspectors? Were 4 O 5 they first-class welders?
6 L I think most of them were but I am not sure whether we 7
varied from that before my tenure ended or not.
8 0 But can we agree that you varied from it after your tenure?
9 A I am not sure whether it was or not. I just can't remember 30 whether we had any of the technical school-type qualifications 11 in there. I am just not sure.
12 O All right. So you had a management philosophy early on 13 at Catawba and at least early on in practice, actual practice, i4 at other sites of having the very .best welders become welding 15 inspectors, true?
16 A Uh-huh.
17 0 All right. You have to say yes or no so the machine can l ig pick it up, 19 A Yes.
0 Why did you have that? Give me a general idea why you 20 .
(
21 thought that was important at the time.
A The lack of knowing better.
22 23 I
O Okay. And is it fair to contrast that with other crafts?
24 Did you think you had to have the very best electricians to 3
be electrical inspectors, or is it fair to my there was a ,
l EVELYN BERGER ASSCCLATE S. STENOTYPE RSPORTMG SERVICE. CMARLOTTE. NORTM CAROUNA l
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I difference for welding?
2 A I expect we thought that about the electricians too.
3 g What about all of the other crafts as well?
4 A I suppose we varied first in maybe the civil area.
5 g All right. Give me an example just so I can understand 6 What you mean.
7 A Well, a checker of rebar.
8 G Didn't have to be the best rod buster?
9 A Best reinforcing handler.
10 g Is that fair?
11 A Uh-huh.
12 g All right. Is it fair to say thCt we2 din r 92c probably 13 the best example of a craft where you tacqht sch. cone had to 14 be the top craftsunn in order to inspect work in that craft?
15 A I don' t believe so.
16 0 All right. Is there a better example?
17 A I think the same philosophy held over 1 am pretty sure 18 again earlier in thesaectrical and most likely in the mechanical.
19 0 All right. Do you know whether or not they reclassified 2 electrical and mechanical inspectors to downgrade their pay 21 based on the finding that they are paid too much?
22 A Their positions was reevaluated. I don't know whether it 23 resulted in a downgrade of pay or not.
24 g All right. Now, what was it that you learned over time, 5 Mr. Beam, that altered this management philosophy about the EVELYN SERGER ASSOCIATES. STENOTYPE RSPOstrING SERVICE. CHARLOTTE. NORTM CAROUNA
1 qualification of inspectors as it applies to welding inspectors 2 specifically?
3 A That requirements change, tech schools are putting out great 4 people today that are highly technical, and that you had less 5 and less reliance on visual. You had more mechanical means --
7 g ' Radiographic -- help me understand what this means.
8 A Radiographic, many of the mechanical means and less visual 9 was used.
10 0 For inspecting welds?
11 A Yes.
I 12 4 It required less judgment?
13 A Yes, I would say it required less judgment.
14 0 All right, sir. So the technology proved that you had l is some better ways of doing it and you didn't have to have as 16 qualified people to exercise this judgment?
I 17 A Early in the game it seemed to me so much depended on te visual and just sheer knowledge.
19 0 For welding inspection?
2o A Yes, uh-huh.
21 G And that's where you needed someone who actually was a 22 top craftsman to do the judgment, do the visual?
. 23 A That's right.
24 0 After the reevaluation that you saw in the mill, am I 25 understanding you, that the , judgment by man was that you could 1
EVELYN SENGE R ASSOCIATES. STENOTYPE REPONTING SENveCE. CMAALOTTE. NO8rTM CAmOLamA
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1 take someone from a tech school and they could be trained 2 specifically as a welding inspector by using these mechanical 3 means, and they wouldn't be required to exercise as much judg-4 ment as you thought welding inspectors had to do in the past, 5 is that fair?
6 A I believe that's fair.
7 g All right, sir. Now, when you saw this reclassification 8 in the mill, as you say, before you left, was it your opinion 9 that the reclassification was proper for welding inspectors?
10 A Yes.
11 g You believe that you could get the work done right and 12 the inspection function performed effectively with people who la were paid less and who were not top welding craft?
14 A Yes.
15 g Now, I have seen some reference to a Hay study. Do you 16 know what I mean by that?
17 A Hay?
18 g Hays study or the Hay study as being I think maybe a 19 consulting firm or something that did some of this reclassifica -
20 tion, the analysis, the position analysis. Is there such an 21 organization? Did they do such?
22 A Yes.
23 0 Who were they, and what part did they play in all of 24 this, if you know?
25 A I don't know that Hay per se played any role in this emr ...a.. .noei r... mmom.' m rin. ==,c.. ca =orr . no- c..oun.
1 particular reclassification.
2 O All right. What did they do, if you know? What involve-3 ment did they have with Duke Power Company?
4 MR. GIBSON: Objection. I am going to limit his answer to 5 anything to his knowledge that he knows of Hay people involved 6 with the welding inspectors or welding at Catawba. I am not 7 sure but I think he answered that he didn't know if they had any 8 involvement.
9 MR. GUILD: Just to speed this up, counsel, I have seen to references in a lot of documents in welding inspe~ctions' 11 thinking that Hay had something to do with this reclassification.
12 I may be wrong. I may be right.
13 A I may be wrong.
14 G Do you have any idea what the Hay people did do so we can 15 clarify what their role is, if you know, Mr. Beam 7 16 MR. GIBSON: Go ahead and answer to the extent you know, 17 Mr. Beam.
18 A Hay was under contract with the company to assist them i
, 19 in pay evaluations.
L s O All right. And do you know whether they had anything to l
21 do with evaluating the pay of welding inspectors?
a A I think not.
23 0 That's a fair statement. Mr. Beam, I am going to show
- 24 you a document. I don't expect you have seen it, but this is an i 3 attachment called attachment 1. It is to a 1etter that was l EVELYN SERGER ASSOCIATES. STENOTYPE leEPORTING SERvtCE. CMAHLOTTE. NORTH CAROUNA e
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1 sent to me by counsel for the company, forwarding some documenta 2 regarding the subject, and the title of the attachment is 3 " Descriptive Index of Documents Produced in Response to 4 Interrogatory 9 (Background for Task Force) ."
5 Item number 10 is indicated as follows: The following are 6 handwritten notes from QC and QA inspectors which set forth
' 7 their specific problems and concerns. I want to just observe a that these are welding inspectors and others who after your 9 tenure ^ filed-resources . about problems they had at the to Catawba site, and you have heard about that, haven't you?
11 A Yes.
12 0 The answer is yes?
13 A Yes.
14 0 Again, this is after your time that'they did this. Now, 15 the list of names -- again this appears at'.the bottom here.
16 And they are letter A through T.
17 All right, sir. Now, I want to ask you, sir, do you 18 recognize the name Dean Bentley?
19 A No.
33 4 All right. T. A. Gardner?
21 A There was a Gardner in engineering, but T. A., no.
22 0 All right, sir. William H. Burr?
23 A No.
24 0 Boyce Crisp, B-o-y-c-e?
g; A No.
EVELYN BEIDGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CNARLOTTE. NORTM CAROUNA e
- 1 MR. GIBSON: Excuse me, is that Boyce Coffin?
2 MR. GUILD: I am sorry, Boyce Coffin. That is D on this l Lst, 3 Boyce Coffin.
4 A No.
5 G All right, sir. C. D. Crisp?
6 A No.
7 4 B. Deaton?
8 A No.
9 G Harold Eubanks?
10 A No.
11 Q A. S . Gantt, G-a-n-t-t?
12 A No.
13 0 V. C. Godfrey?
14 A The initials, the Godfrey name, if that's a welding 15 inspector, no.
16 G I think it is. Larry Jackson?
17 A No.
18 G Richard Jones?
19 ' A No.
20 g Kenneth Carriker, Kenneth W. Carriker?
21 A No. ,
22 % Ronald Kirkland?
23 A I know we had a Kirkland inspector, civil, I believe.
24 0 If I said he was a welding inspector, would that refresh 25 your recollection?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERYtCE. CHARLOTTE. NORTM CARQUNA e
- 1 A I don't think so. I remember a name Kirkland, and I 2 thought he was civil.
3 G All right, sir. John McCoy?
4 A No.
5 % John Rockholt?
6 A No.
7 0 Ransome Sims?
8 A No.
9 O Mickey Stanridge?
10 A No.
11 S Lindsay Hovis?
12 A No.
13 Q Beau Ross?
14 A Yes.
15 0 You recognize the name Beau Ross?
16 A Yes.
17 G Who is Mr. Ross?
u3 A Supervisor of welding inspectors.
n) G All right. How about J. R. Bryant? He is the last on 20 the list.
21 A No.
22 0 All right, sir.
A Not as an inspector. I don't know what Mr. Bryant's name 23 24 is.
25 0 Different man. All right, sir, Mr. Ross is -- I am sorry, E WELYN SERGER ASSOCIATES. STENOTYPE REPORTING SEfMCE. CMARLOTTE. NofrTM CAROUNA
1 a welding inspector supervisor?
2 A Yes.
3 g was he in this position while you were project manager?
4 A Yes.
5 0 All right. Did you have occasion to observe Mr. Ross's 6 ' work, either directly 'or indirectly? I understand you didn't look 7 over his shoulder.
g A I didn't look over his shoulder.. I was in a position to 9
assist in the evaluation of Mr. Ross.
10 0 What capacity did you assist in evaluating him?
11 A Just in discussing his performance with his second or third-12 level supervision.
13 0 Who is that? Who would his second or third-level supervision 34 have been?
15 A Larry Davison or D. L. Freeze.
16 O All right. By second or third-level supervision, they are more than one level removed above him, is that what you 17 mean, sir?
18 3g A Yes.
I g Q Who would Mr. Ross have reported to?
A Larry.
21 O Directly to Larry --
22 A No, no, that's wrong, Charles Baldwin.
23 24 0 Charles?
g A Baldwin.
EVELVM BERGER ASSOctATES. STSNOTYPE REPORTING SERVICE. CHARLOTTE. NOmM CAROUNA e
- 1 Q Baldwin, okay. So his first-line supervision was Charles 2 Baldwin, and second would have been Larry Davison, and third 3 would have been D. L. Freeze?
4 A Right.
5 G And that was consistent the whole time you were on that 6 Catawba site, as best you recall?
7 A Yes.
8 G All right. 'Tell me what your role was in participating 9 in the evaluation of Mr. Ross.
to A To assure uniformity, fair pay, equal pay for equal job, 11 extend competitiveness.
12 G All right. How did you evaluate Mr. Ross's work?
13 A tTell, I didn't evaluate.
I'4 0 Right.
15 A But I concurred, and I needed input.
16 G Yes.
l
! 17 A And so I didn't really evaluate but Mr. Ross was a is competent individual. .
t l 19 4 He was competent in his position of supervising welding m inspector?
21 A Yes.
22 G Now, how were evaluations made of someone in Mr. Ross's g position? Give me an idea of what the mechanics were or the 24 vehicle was for evaluating somebody in his job.
25 A Starting of course with immediate supervisor, wrote out his, EVELYN SERGER ASSOCIATES. STSpeOTYPE REPORTING SERVICE. CHARLOTTE. NOfrfM CAROUNA e *
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r 1 how he performed from his job evaluation sheet. There is anoth'er 2 name for that, and that moved up the ladder as it came on up 3 finally for my approval.
4 g That was for supervisors?
5 A Yes.
6 0 You didn't evaluate all craft people on the job, for example?
7 A No.
8 0 But supervisors of Mr. Ross's position would come to you?
9 A Yes.
10 0 An'd how frequently would that evaluation be?
11 A As needed or no more than once a year.
12 g once a year, but more frequently than once a year?
13 A Could be.
14 g And do you know whether Mr. Ross was evaluated on a 15 yearly basis?
16 A No.
17 S You just don't remember?
l 18 A At least a year.
19 4 At least a year?
20 A I just don't know whether he came up.
l l
21 % I understand. What kind of ratings -- what was the rating 22 standard for evaluating people in supervisory positions on a i
23 scale of one to ten, excellent, poor, good, what was the i
24 standard?
l 25 A Marginal, fair, competent, distinguished at the other end.
EVELYN SSRGER ASSOC &ATES. STENOTYPE REPORTING SSRWICE. CNARLOTTE, NORTM CAROWNA
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- 1 g Something between distinguished and competent?
2' A Yes, commendable.
3 g All right, sir.
4 A That ain't right.
5 0 Is that right?
6 A I don't know.
7 0 To the best of your recollection?
8 A That's to the best of my recollection.
9 0 All right, sir. To the best of your recollection, how 10 did Mr.' Ross rate? How was he evaluated?
11 .A Competent.
12 O Consistently competent?
13 A Consistently.
14 0 Did he ever rate higher than competent, as best you 15 recall?
16 A I don't think so.
17 O Did he ever rate lower than competent?
18 A I don't think so. That is recall.
19 G Yes. How would you characterize competent on a scale of 20 one to ten? Is that five or seven?
21 MR. GIBSON: I object to using a different format from the 22 one he has described that has been used, Mr. Guild. If he wants 23 to try --
24 0 can you do that in fairness? I am trying to understand 25 what your system means. In the Army everybody is excellent, EVELYN BERGER ASSOCIATES. STENOTYpt REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA e *
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1 and if you are not excellent in the Army, you are bad.
2 A I can't do it on a one to ten. I.can tell you that 3 competent is meeting every requirement of the job.
4 G All right, sir. Let's see if I can put it in this context .
5 If we are going to draw a -- in school they used to have the 6 Bell curve, and the curve was how many people scored at which 7 percentile, and you are just going to roughly tell me where 8 competent fell. Most people get competent, or is competent 9 something you especially see reserved for a good performance?
10 A Competent meets all of the requirements of the job, is 11 fully acceptable.
12 0 All right, sir. And how many, for a person in a supervisory 13 position-like Mr. Ross, would other supervisors on an average 14 score better or worse than competent?
15 A I don't know. I didn't understand you.
16 G Let me back up a second. The example I tried to just give 17 really kind of flexed my problem in my attempt to understand.
18 In the Army if you are not excellent, you are bad. Everybody 19 has to be excellent or you're in trouble. Is that the way 20 it works at Duke Power Company? Does everybody have to be 1
21 whatever your. top-notch, classification was?
l Z! A Distinguished.
I 23 G Distinguished. Do you expect everybody is going to be 24 distinguished or you ought to be ashamed of yourself or what z5 does it mean?
EVELYN SERGE R ASSOCIATES, STENOTYPE REPORTING SERvtCE. CHARLOTTE. NORTM CAROUNA e
- 1 A My philosophy was, if you couldn't walk on water, you 2 wouldn't get distinguished.
3 g Did anybody walk on water?
4 A No.
5 g Did any of your supervisors walk on water?
6 A No.
7 g Did any of your supervisors walk six inches below the 8 surface and get the next level down?
9 A No.
10 g Is competent pretty typical of what you expected of your 11 PeoPle?
12 A Competent, a grading of competent meant that they met 13 every requirement of that job.
14 g All right, sir. Did a grading of competent mean they 15 could expect to be given increasing responsibilities and 16 Promotions and raises in pay, Mr. Beam?
17 A Yes, generally.
gg g All right, sir.
19 A They were progressing.
go O They were progressing, all right. In your tenure as project 21 manager did Mr. Ross progress?
22 A Yes.
23 g And he progressed to the position of supervisor of welding 24 inspector?
A No, he went to I believe they changed the title. We 25 EVELYN BERGER ASSOCIATES STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROUNA e *
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I changed the title, and I don't know exactly what it was, and 2 he had two or three supervisors reporting to him.
3 S Persons with the title supervisor?
4 A Yes, uh-huh.
5 0 All right. And can you remember what his title was?
6 A No, can!t.
7 G All right. He would have been directly under Mr. Davison?
8 L Yes.
9 0 And below him there would have been --
10 L Two or three supervisors.
11 0 Who were directly over the welding inspectors?
12 A Yes.
13 0 And was that the senior position that Mr. Ross occupied 14 while you were project manager, that was the top job he held?
15 A Yes.
16 O All right. And how long did he hold the top job where he 17 had two or three people reporting.to him?
18 A All my time.
19 @ All your time. From going back to day one on the project?
20 A Day one we didn't have welding. Whenever welding came --
21 no, Beau came sometime early, n 0 Did he uphold the supervisory position during his whole 23 tenure?
24 A Yes.
25 0 Are you aware of any criticism of Mr. Ross for the way he EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERytCE, CHARLOTTE. NORTH CARCUNA e 8
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1 did his job?
2 A No.
3 0 Did you and Mr. Ross ever speak about the welding inspector 4 work at Catawba?
5 A Yes, general, just general comments. I knew Beau and we - -
6 nothing specific, just small talk.
7 g Right. Did you and he ever talk about the subject of the 8 proposed reclassification of welding inspectors?
9 A No.
10 0 Did he participate in that review and proposed reclassifica-11 tion?
i- 12 A No.
13 g was his input solicited? Did anybody ask his advice or 14 what he thought about it?
l 15 A I don't know, l
l 16 0 Not that you know of?
17 A Not that I know of.
18 g Was that analysis, that reevaluation, was that done by l
l 19 you or persons under your supervision?
20 A No.
21 0 Who was it done by?
22 A Corporate.
23 0 Quality assurance?
l l 24 A The board.
l g
25 Personnel people?
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1 A Yes. It was personnel involved. Some of personnel was 2 represented, yes, corporate personnel.
3 0 How about construction?
4 A They were represented.
5 0 And who represented construction?
6 A I.
7 0 You did?
8 A I did.
9 0 Okay. You say +--
10 A I represented from the Catawba site.
11 4 Yes. And were there other representatives in construction?
12 A Yes.
13 S From the other sites as well?
14 A Yes.
j 15 0 And this was the committee that did the reevaluation?
16 A Yes.
I 17 g Did it just work on the inspector and welding, or the 18 welding inspector reevaluation or was it responsible 1br other 19 reevaluations too?
20 A The whole shooting match.
l
- 21 0 All right, sir. And was this a periodic reevaluation, one .
l 22 of many or one of several or something?
l 23 A One of many.
24 0 But this was the one that resulted in the decision to l 25 reclassify the welding inspectors?
EVELYN BEHOER ASSOCIATES. STENOTYPE REPORTING SERVICE CHAMLOTTE. NestfM CANOUNA ,
l . .
i 1 A Yes.
2 g Which had not been implemented at the time you left but 3 was in the mill, as you describe it?
4 A Yes.
5 g Who was most responsible for providing the information 6 and recommending the reclassification of the welding inspector 7 position?
8 A That's unanswerable.
9 G You just don't remember?
10 A Those things come out of the woodwork.
11 g Okay. It is a committee decision, is that right?
12 A That's right.
13 0 It's always hard to figure out who to lay the blame on 14 when it's a committee.
15 MR. GIBSON: Object to the form of that question.
16 MR. GUILD: I withdraw that.
17 0 What I want to understand, Mr. Beam, is there someone that 18 y'all said, " Staff person, go out and I went you to take 19 responsibility of taking a look, gathering the data, coming up j
29 with this internal equity, external competitiveness data on 23 welding inspectors," is there someone that you look to that you 22 recall?
23 A No.
24 g And what would have been the source of your information that was the basis for the welding inspection decision? Where 25 EVELYN SERGER ASSOCIATES. STENOTYPE REPOONG SERwsCE. CHARLOTTE. NORTH CAROUNA 4
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1 did you get it from?
2 A The same as any other evaluation.
3 0 Yes.
4 A Your committee works over what, in our service area,what 5 is prevalent, what is like plants in other ways, wherever we 6 can get our information, and you spend agonizing hours coming 7 UP with an evaluation that is externally competitive and g internally fair.
9 7 Okay. Now, with regard to the welding inspector's position, 10 can you remember where you were getting the information about 11 the external factor, the external competition?
12 A No.
13 g All right. Is it fair to conclude that there was evidence 14 that satisfied y'all that you didn't need to be paying welding 15 inspectors as much as you were paying them, to be externally l
l is competitive?
i 17 A Yes.
I 18 g Somebody who was doing like work was getting away with 19 Paying welding inspectors less than you were at Catawba?
l g MR. GIBSON: Object to the form of the question. He may 21 answer.
22 4 Is that right?
l A I don't know. I can't remember what others were paying.
23 24 g would let's say Daniel have been a source of comparison?
3 Use an example, s
EVELYN SENGER ASSOCIATES. STENOTYPE REPCM1NG SEnveCE. CHARLOTTE. NORTN CAROUNA s
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A I don't believe Daniel was welding inspectors. I am not 1
2 sure of that.
3 % okay.
4 A They usually contract their inspection. I believe. I 5 may be wrong on that.
g Help me. I don't know. I just ask that out of ignorance.
6
- Who would be a source of comparison? Who does welding 3
inspection thatwould have been a likely source of comparison, 9 if you know?
10 A U. S. Testing, Froehling and Robertson.
11 O Froehling and Robertson? ,
12 A Uh-huh.
13 g They do welding inspection?
14 A Uh-huh.
15 g on a contract basis?
16 A I think they do, yes. There is a bunch of them.
17 g Give me some more. Give me a list.
A Four I's. I don't know what the four I's stand for, 18 19 industrial inspection. I don't know what four I's stands for.
20 g IIII, right?
l 21 A (The witness moved his head up and down.)
22 O Anybody else come to mind?
23 A No.
l 24 g All right, sir.
A There is others, Law Engineering.
3 EVELYN BERGER ASSOCIATES. STENOTYPE nePORT1Ne SERVICS, CMANLOTTE. NORTM CAROUNA e
e
, 1 g Law Engineering, all right. And these others do welding i
2 inspection on nuclear projects, some?
3 A I don't k. tow.
4 g All right.
5 A U. S. does.'
6 S U. S. does. All right. Then on the internal equity side, 7 that'J the other input to the classification process, right?
8 A Uh-huh, yes, sir.
9 S Tou were comparing welding inspectors with who, for 10 purpose of the internal equity comparisons?
11 A With like inspectors in other fields.
12 0 Inspectors in other crafts, all right. And the welding 13 inspectors were being paid more, is that fair?
14 A I am not sure that that is true.
15 0 All right. Well, if they weren't being paid more, then 16 there was no need to make a change on the internal equity 17 basis, isn't that a fair conclusion?
t ig A No. Maybe the electricals were overpaid too.
19 0 Did you reclassify them all?
2o A I don't know.
21 g All right. You just don't remember whether you reclassifi ed 22 them or not?
23 A I just don't remember.
, 24 g Can you remember anything else about the internal equity 3 comparison that dictated reclassifying welding inspectors?
EVELYN SERGER ASSOCIATES. STENOTTPE REPOR11NG SERVCE. CHARLOTTE, NORTH CAROUNA e
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1 A Reclassifying didn't dictate reclassifying welding 2 inspectors. Welding inspectors were reclassified because of a 3 study made on the present pay practices in the construction 4 department.
5 g Right. Now, let me just -- I want to get your opinion 6 on some matters. Before you left, you knew that a reclassifica ,-
7 tion of welding inspectors was in the mill, and as we have g discussed, the reclassification was resultant in reducing the 4
9 pay grade of the welding inspectors for the reasons that you i 10 stated. Did you anticipate or did others anticipate this might.
, 11 have an effect on the morale of welding inspectors?
12 A Personally I thought there would be a certain amount of 13 shock, yes.
14 G All right. And was that opinion, as far as you know, shazed 15 by others who participated in this decision, the committee 16 at you are taMng abouM A I don't know whether it was shared or not. I think it 17 18 was a reality that everybody knew that the possibility was 19
- E**
29 G Right. I mean you don't cut somebody's pay without expect -
23 ing they are going to be unhappy about it.
MR. GIBSON: Object to the forta. There has been no 22 g3 showing at all that anybody's pay was cut. He can answer the I
g4 question.
g Was that a fair statement?
25 I evetvu esnoen AssociAres. svenorvas aspoortime seavice. cwAaLoTTs. NostTw CAaOLIMA l
1 A I don't know whether the pay was cut or not except what '
f-. -
l .,
2 I read in the newspaper.
3 0 You understood it was?
4 A What?
5 0 You understood it was from what.you read in the newspapert 6 A I don't know whether it was I understood it was cut or not ..
7 Like I said, it was after my time.
8 G They reclassified the position of welding inspector that 9 might ham slowed the rate of increase if they didn't cut to the pay, isn't that fair? You don't need to look to your j 11 1"WY'I*
12 MR. GIBSON: He has already answered that three times.
(
13 MR. GUILD: I am trying to help you, Lawyer. You 14 objected to the form of the question.
15 MR. GIBSON: Ask the question, Mr. Guild.
16 MR. GUILD: I didn't have a question pending.
M. GIBSON: Wat was your quesdon?
l 17 l
l 3g MR. GUILD: Don't make me ask it again, Ron.
g MR. GIBSON: One more time. Since it has been asked g three, it won't matter. Go ahead and ask it again.
Q Whether it was a cut in pay or not a cut in pay, and the 21
! point was, if it resulted in a lowering in pay or reduced a rate of pay, you expected reasonably it was not going to set 23 g4 well with the people who were getting cut, isn't that fair?
E g A I personally did.
EVELYN SENGER ASSOC 84TES. STENOTTPS pePORTING SERVICE. CHARLOTTE. NORTM CANOt.INA e *
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1 g And did you anticipate that that morale effect, if I-2 can characterize it thattay, might also have an effect on the 3 effectiveness of whether those welding inspectors were doing 4 their job?
5 A No.
6 g All right. Your experience, Mr. Beam, doesn't it often 7
follow that bad rorale has an adverse effect on people's work 8 performance? '
9 A In my experience, bed morale has an effect on quantity of to work produced.
11 Q But not the quality of the work?
12 A I don't see the relationship.
33 g You haven't seen a rela _tionship in your experience?
g4 A That's right, yes.
15 g You may do fewer welds or do fewer inspections or fewer i
i 16 feed of rebar or whatever it is?
l i
g7 A Production will go down but I don't necessarily agree 18 with the quality..
0 I want your fair opinion now. Is quality -- is your 39 g experience that quality is never affected or it just is not 21 quite often affected as production levels are affected by 22 morale problems?
g A I don't remember quality being affected by morale problemo .
3 G All right, A Morale problems, I think, are temporary. Production, g
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NOWTH CAROUNA e *
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1 you can see production, and that is strictly opinionated.
2 O Production rates are something that you keep tabs on and 3 you can see those go up or down and you can connect those with 4 morale pretty directly, can't you?
5 A. It is not that easy in construction though. It's more or 6 less a seat-of-the-pants evaluation.
7 0 Well, is it fair to say it's hard to detect quality 8 work? It is easier to detect quantity? You measurs quantity 9 pretty directly, don't you?
\
to A I think it's easier at a nuclear plant. Quality is 11 easier than quantity.
12 g How do you do that?
13 A With the many means you have at your disposal.
14 0 Conformity?
15 A The many mechanical means of inspection. There are so mary 16 tests that it goes through.
17 0 Right. Well, in the instance of welding inspectors, Mr.
~ 18 Beam, if welding inspectors did have a pay cut or reclassifica-39 tion that they saw as a cut, and the morale was adversely 20 affected, wouldn't one measure of lower work performance be an increased number of nonconforming items, flunked welds?
21 l
l 22 A Not necessarily.
23 0 It's possible?
l 3 A Possible.
25 g W uldn't it, if it were just the production levels, s
EVELYN SENGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CNANLOTTE. NORTM CAROUNA
1 I wouldn't bad morale and the welding inspector line be reflecteil, 2 if your observation is right, in reduced number of inspections?
3 A Yes.
4 g Was Mr. Ross aware of the pending reclassification of 5 welding inspectors as far as you know?
6 A I don't know.
7 g Do you believe it was general k70wledge among supervision
,8 that might have included Mr. Ross, that this was in the works?
9 A I don't know.
10 g I am not asking you to swear what is in the man's head.
11 I just want your opinion. Do you think it: is general knowledge ?
12 Do you know?
13 L I don't think it was at that time.
14 0 All right, sir. You knew Charles Baldwin, didn't you?
15 A Yes.
, 16 0 What did you think of Mr. Baldwin's work?
17 A It was good.
is 0 How was Mr. Baldwin evaluated?
19 A Competient.
20 0 Consistent, as far as you remember?
21 A As far as I remember it.
22 g Are you aware of any criticism of Mr. Baldwin's work?
23 L No.
24 0 All right. Did you have an opportunity to observe Mr.
25 Baldwin's work either firsthand or indirectly?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CNARLOTTE. NORTH CAROUNA a '
,. 1 A Indirectly, i
2 g All right. You would have been aware of any criticism 3 if there were any?
4 A Not necessarily.
I 5 g All right. But none came to your attention, that you rectll?
6 A That I can recall, no.
7 g All right. You knew Mr. D. L. Freeza?
8 A Ye8-9 g What did you think of Mr. Freeze's work?
10 A Mr. Freeze was competent.
11 g Are you aware of any criticism of Mr. Freez<a?
12 A Yes.
('
33 g Of what sort? Feel free to consult with your lawyer, 14 if you like, but there is a pending question.
15 (The witness consulted with his attorney.)
16 MR. GIBSON: Mr. Beam has advised me that that criticism g7 he referred to related to relationships between Mr. Freeze and 18 Personnel in the craft in construction,which would therefore t
19 not be involved within the scope of these depositions so I am l
- instructing him not to answer that question.
go 21 MR. GUILD: Well, I think it's obviously relevant for 22 discovery purposes, Counsel.
23 MR. GIBSON: Ask another question, Mr. Guild. He is not 24 going to answer that question.
3 MR. GUILD: I insist he answer that question. Are you EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
j i instructing him not to answer that question?
2 MR. GIBSON: As I have indicated, I instruct him not to 3 answer.
4 MR. GUILD: I ask that the record reflect that the witness 5 consulted with his counsel and on the basis of that consulta-6 tion --
. 7 MR. GIBSON: The record reflects that. Ask another 8 question.
9 0 All right, sir. Are you aware of the work of Larry Davisen?
10 Do you know Mr. Davison?
11 A Oh, yes.
12 g What did you think of Mr. Davison's work?
13 A Good.
14 0 How was he evaluated?
15 A Competent.
16 G Consistently?
17 A There might have been one or two evaluations during a is growth period that he could have been evaluated higher. I am 19 not sure.
20 0 Was that during your time as project manager?
21 A Yes.
22 g And what would have been the basis for his rating higher, 23 if you remember?
24 A When things are expanding, you can see evidence of 23 progression easier than you can at a status quo-type organization, EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVK.E. CHARLOTTE. NOfMM CAROUNA l
I l
l
- 1 and during the growth period there where Larry had a chance ,
1 1
2 to really excel, there might have been -- but, you know, you 3 lose that gain once you reach the status quo. I am not sure.
4 I just said I think there would have been two evaluations there :
5 of Larry that were commendable.
6 g And what period of time were you referring to?
7 A The '76 to '81.
8 4 Would likely have been the period at which the quality 9 control was moved over under QA?
10 A I don't believe so, no.
11 g Before that period?
12 A Yes.
13 0 Are you aware of any criticism'of Mr. Davison?
14 A What's criticism?
15 g Well, people complaining about him.
16 A Directly, no.
17 g Indirectly?
18 A Yes.
39 g What's the nature of the criticism that you became aware go of indirectly?
gi MR. GUILD: Let the record reflect that the witness is 22 consulting with his counsel again.
(The witness conferred with his attorney.)
33 g MR. GIBSON: Go ahead and answer that.
25 g Have you had a chance to consult with your counsel now?
swatvN esmoaR ASSOCIATES STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAmouMA a
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1 A The criticism that was brought to my attention of Davison 2 is nothing more than administrative -- we didn't like the 3 Promotion he made. He promoted somebody that somebody felt 4 like they should have been promoted.
5 g Who is that P. hat you are talking about?
6 A This was a common thing. When you say criticism, and I 7 look at it at the broad sense, and I have to answer yes.
8 g Fine. I want you to be honest.
9 A I am trying my best to be just that. Still, somebody is 10 always happy, and somebody is always unhappy when anybody 11 gets promoted. Nobody has ever agreed that it shouldn't have 12 been them, and I have heard on Larry, he promoted the wrong 13 man.
34 g Who was that that you heard? I am not asking you to 15 verify that's the : ruth or anything else.
A I haven't got the slightest idea. I had a relationship 16 17 of small talk down in the rank supervision and employees that just sort of invited this small talk-type thing. But if you 18 ig ask me criticism, yes..
20 g Right.
gg A But I heard about everybody.
gg C Yes. Any other criticism of Mr. Davison that you are 23 aware of?
24 A No.
g Do y u know a Mr. Allum?
25 EVELYN SER3ER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CARQUNA e *
,- 1 A No.
2 0 R. Allum?
3 A I saw his name on the schedule to be here, I think.
4 4 Yes, that's right. You don't know the name though?
5 A No.
6 g All right. Are you aware of any friction or conflict 7 be.: ween Mr. Beau Ross and Mr. Baldwin?
8 A No.
I g g Mr. Beau Ross and Mr. Freeze?
. 10 A No.
11 g Mr. Beau Ross and Mr. Davison?
12 A No. Surely there was some.
13 0 But you don't know of any?
14 A No.
15 g Why are you sure there was some?
16 A There is always friction between a supervisor, a subordinate 17 and a superior.
gg g But there is nothing that is specific to those two that 19 you are aware of at all in the nature of friction?
gg A No.
gg g Conflict. And you don't know Mr. Allum, so you are not 22 aware f any friction between him and Mr. Ross?
i A I don't know who Mr. Allum is.
33 g All right, sir. We began this deposition, and I think you 34
,,a.
acknowledged that while it was after your time, you were aware EvsLYN eEmoER ASSOCIATES. STENOTYPE REPOprTING SERVICE. CHARLOTTE. NORTH CAROUNA 4
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,- 1 of what I refer to as the welding inspector complaints or the 2 incidents that led to a larga number of welding inspectors to 3 file recourses and make complaints of technical and nontechnical 4 nature at Catawba. You are aware of that, aren't you?
5 A The way you ask it, I think my answer is no. I am aware that there was some dissatisfaction in the welding inspecting 6
7 group after I retired.
8 g All right. And do you have an opinion about the cause of 9 that, as you characterize, dissatisfoction?
. icy A As an opinion, it could possibly have come from the reclassification group. It didn't have to come from that, to 11 12 my knowledge.
13 g All right. Do you :have any other information about that?
14 A No.
15 0 All right, sir. I want to show you a document and ask you if you can identify it. It's May 19th, 1980, letter.
16 MR. GIBSON: Mr. Guild, this May 19th, 1980, letter 17 3g concerns other matters and we are instructing Mr. Beam not to l
f gg answer any questions regarding Mr. Hoopingarner or any other i
20 matter not relating to welding inspecting at Catawba.
21 MR. GUILD: I would ask the witness to answer the g question.
I MR. GIBSON: .I am instructing him not to answer unless you 23 l 24 have a question directly related to welding inspectors at l 3 Catawba. .
(
I avrLYN esRotR AssociATas. sTaNOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA
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3 MR. GUILD: You are instructing the witness not to answeri 2
MR. GIBSON: As I said twice, I am instructing the witness.
3 not to answer any questions as to Mr. Hoopingarner or any other 4
matter not related to welding inspecting at Catawba.
MR. GUILD: I would like this letter marked for identifica.-
5 6
tion and we would note -- I note my position, Counsel, that we would intend to pursue, first, the question of identificatic n 7
of this letter and then the substance of Mr. Beam's knowledge 3
f the circumstances concerning compi.iints made by Mr. Hoopin-9 garner and his involvement and knowledge of those complaints
. 10 and the circumstances of Mr. Hoopingarner's termination.
11 g MR. GIBSON: If you have a matter related to quality control and quality assurance in welding at Catawba, we may pursue that matter but anything beyond quality control and g quality assurance in welding at Catawba will not be pursued with Mr. Beant.
16 MR. GUILD: I would like this marked for identification g
18 can we do that?
19 MR. GIESON: You may take to the board any matter you wist .
(Titereupon, deposition exhibit 2I number 1 was received and marked for identification.)
22 23 MR. GUILD: All right. Thank you, Mr. Beam. I appreciate 24 your coming down today and answering these questions.
25 MR. GIBSON: Mr. Johnson, do you have any questions of Mr.
EVELYN SERGER ASSOCIAT 4 'TENOTYPE REPORTING SERVICE. CHARLOTTE. NORTN CAROUNA e '
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<- 1 Beam?
2 MR. JOHNSON: None.
3 BY MR. GIBSON:
4 0, Mr. Beam, are you aware of anything that would cause you 5
to question whether Catawba Nuclear Station is safely built?
6 A No, sir.
7 MR. GIBSON: That's all.
8 (Witness excused).
9 (Thereupon, this deposition was concluded at 10:48 a.m.)
. 10 * *
- 11 12 13 14 15 l 16 l
I 17 18 19 20 21 22 23 24 l
25 EVELYN SERGER ASSOCIATES STENCTYPE REPORTING SERWCE. CHARLOTTE. NORTM CAROUNA 2 '
1 I, D. G. Beam, hereby certify that I have read and 2 understand the foregoing transcript and believe it co be a 3 true, accurate and complete transcript of my testimony.
4 5 D. G. BEAM s This deposition was signed in my presence by D. G. Beam 7 on the day of 1983.
8 9 NOTARY PUBLIC 10 11 CERTIFICATE 12 I, Ann P. Harris, court reporter and notary public, do 13 hereby certify that the foregoing 80 pages are a true, accurate 14 and complete transcript of the proceedings during the deposi-15 tion of D. G. Beam; that Mr. Beam was duly sworn prior to the t
l 16 taking of his deposition, and that the parties were present as 17 stated.
18 I also certify that I am not of counsel for nor in the 19 employment of any of the parties, and that I am not interested ,
l 20 either directly or indirectly, in the outcome of the lawsuit.
21 This /06 day of July 1983.
O d s' /
22 (lo v a /. d4mm Ann P. Harris - Notary Public 23 State of North Carolina County of Mecklenburg l
24 i
My commission expires:
June 30, 1986
( 25 i
l EVELYN SERGER ASSOCIATES. STENCTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA y r
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