ML20078L743
| ML20078L743 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 06/29/1983 |
| From: | Allum A DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20078L617 | List: |
| References | |
| FOIA-83-434 NUDOCS 8310240056 | |
| Download: ML20078L743 (114) | |
Text
b !
I\-.
l 1
- . .d
( UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: ) Docket Nos.
)
DUKE POWER COMPANY, et al ) 50-413 (Catawba Nuclear Station ) 50-414 Units 1 & 2) }
- h. s: i L:~ U I, Barbara V. Haas, Commissioner and Notary Public, proceeded to take the deposition of A. E. Allum on the twenty-ninth day of June,1983, beginning at 1:15 o' clock
( p.m. in the offices of Duke Power Company, South Church Street, Charlotte, North Carolina.
DEPOSITION OF A. E. ALLUM
- d
- 4401 CO!iiCL Rd.
MSSOCidteC Po. Box uo.83 .
o Choriotte NC. zsur Court l\CpOrterS 7o4 364.Ti7s
[ 7,l 8310240056 830810 PDR FOIA AHLERS83-434 PDR d
ob a s
( -
1 A. E. ALLUM, being first duly sworn, testified as follows:
2 (By Mr. Guild)
EXAMINATIONL 3 Q. Mr. Allum, would you state your full name and business 4 address for the record, please?
-5 A. Arthur Allum, Duke Power, Post Office Box 223, Clover ,
7 Q. That is at Catawba Nuclear Station?
8 A. Yes, sir.
9 Q. What position do you hold with Duke Power, sir?
10 A. Technical Supervisor.
11 Q. Is that your formal title?
12 A. Yes, sir.
13 Q. Do you work in the Quality Assurance Department?
Id A. Yes, sir.
15 Q. Would you formal title be Quality Assurance Technical to Supervisor?
17 A. QC Techniccl Supervisor is the general title.
18 .Mr. Allum, my name is Robert Guild, and I'm counsel for Q.
19 Palmetto Alliance. My clients are intervenors in the Catawba 20 operating license case. Are you aware, sir, that we have 21 raised questions concerning the adequacy of quality assurance 22 at the Catawba site?
23 A. I am.
24 I want to show you a document that i's da'ted December 31, Q.
25 1982, and it's Duke Power Company's response to questions 2
4
o 1 e I
1 that were ask ed by Palmetto Alliance on that subject. I 2 want to point out to you beginning at page three and extending 3 over to page four a quotation of the text of what has been 4 referred to as contention six which is this quality assurance 5- issue. Take a few moments, sir, and read that to yourself, 6 and I want you to familiarize yourself with it, if you would 7 please. While you are doing that, Mr. Allum, let's, if we 8 can reflect those present in the room. Again, my name is 9 Robert Guild and I'm counsel for Palmetto Alliance. With 10 me is Billy Garde of the Government Accountability Project, 11 Michael Lowe of Palmetto Alliance, Philip Jos of Palmetto 12 Alliance.
13 MR. JOHNSON: I'm George Johnson of the Nuclear 14 Regulatory Commission.
15 BE. CODDINGHAM: I'm Anne Coddingham, counsel 16 for applicant.
17 MR. BELL: Glenn Bell, QA Department Duke.
18 MR. HENRY: Mayne Henry, Quality Assurance Departmen; 19 Duke Power.
20 MR. McGARRY: Michael McGarry, representing the 21 applicants.
22 Have you seen those contentions before, sir?
Q.
23 A. The cont'ensions we have?
24 Q. What Ihave just showed you. Have you' seed those before?
25 A. No, sir.
3 J
q s ,
k
. 1 Q. No?
2 A. No, sir.
3 Q. Mr. Allum, I'm going to ask you a series of questions on 4 the subject of those contentions particularly as they relate 5 to your knowledge concerning quality assurance and welding 6 at Catawba, and what I'm trying to find out is information 7 that will help me gather evidence on the question for use 8 in this case. 'If I ask you a question, and you don't under-9 stand a term I'm using or I'm just not being clear, just 10 stop me, please, and ask for clarification. I would like 11 to be as informal as we can, so I want to make sure we are 12 communicating effectively. If you don't, the transcript 13 that is going to be later produced of this deposition will
(
Id simply reflect your answer, and I will presume that you 15 understood the question the way it was asked and that your 16 answer was responsive. Relate, if you would, Mr. Allum, your 17 general work history with Duke Power ; when did you go to is wcrk for the company and what different jobs you have held 19 and when.
20 A. I have worked for them five years and ten months, and 21 I was Ecrmerly at Cherokee in the same position as I am now.
22 I have been at Catawba for two years.
23 Q. The position you held at Cherokee, what was the title?
~ ~
24 A. Technical' Supervisor.
25 Over Quality Control?
Q.
4
r_
i- 1 A. Yeb, sir.
2 Q. You work in the welding area?
3 A. I have worked in welding and in the welding area. I do 4 not presently work there.
5 Q. I'm scrry, you do not work in welding now?
6 A. Right.
7 Q. So, what area are you working in?
8 A. Mechanical.
9 Q. How about when you were at Cherokee?
10 A. Mechanical and welding.
11 Q. When did you come to Catawba, Mr. Allum?
12 A. May, 1981.
13 Q. What was the job that you took when you came to Catawba?
14 A. Technical Supervisor.
15 Q. In what craf t, sir?
16 A. I had, at that time, the radiographers, the non-destructiv a 37 testing personnel, document control inspectors and receiving ,
~
18 inspectors.
19 Q. Did that include welding inspectors?
20 A. No, sir.
21 Q. When did you' have responsibility, if you did, over 22 welding inspectors?
23 A. January, 1982.
24 Did your job title change then, sir? #-
Q.
25 A. No.
5
b i d_ 1 Q. Just your responsibilities, area or responsibilities?
2 A. Right.
, 3 Q. How long did you have rerponsibility thereafter for 4 supervising welding inspection?
5 A. Until the thirteenth of this month.
6 Q. That's the month of June,1983?
7 A. Right.
8 Q. How did your responsibilities change in June of this 9 year?
10 A. I just went -- took over mechanical group.
11 Q. Why did you change, sir?
j 12 A. Because it was a vacancy in that area.
13 Q. Promotion?
14 A. No, sir.
.15 Q. Was it a demotion?
16 A. No.
17 Q. Just a straight lateral transfer?
18 -A. Right.
19 Q. Did ou get a pay increase?
20 A. No.
f I
21 Q. Then, why did 'you make the transfer?
22 A. That was the job.
. 23 Q. Someone asked you to?
24 A. Yes. -
25 Q. Who did that?
6 e
't i'- 1 A. Joe Willis was my supervisor.
2 Q. What is Mr. Willis' position?
3 A. Inspection Superintendent.
4 Q. What is his responsibility?
5 A. He is responsible for all the QC inspection, QA inspec-6 tion personnel at Catawba.
7 Q. How long has Mr. Willis been in that position, do you s know?
9 A. Septem ber , 1982.
10 Q. What is your understanding of the reason why Mr. Willis 11 wanted you to transfer to mechanical?
12 A. Because he was being transferred and the person in the 13 mechanical slot was going to his slot, and he needed someone
(
14 with experience in mechanical.
15 Q. Mr. Willis was being transferred?
16 A. Yes, sir. ,
17 Q. Where was he transferred?
18 A. He is going to Nuclear Production QA.
19 Q. Let me understand. Mr. Willis was transferred in June
. 20 og 83 to Production?
! 21 A. Effective one July, he will be the Operations QA, Senior 22 QA Engineer at Catawba.
23 Your position, you move then to mechanical?
Q.
24 Yes, sir.
~
A.
( 25 And, who will occupy or who does or will as of that date Q.
. 7 l
l h.. ,
5 a
! I occupy the position of Inspection Superintendent?
2 A. Jerry Goodman.
3 Q. Where did Mr. Goodman come from?
4 A. Mechanical Supervisor.
5 Q. You are going to take that position?
6 A. Yes, sir.
7 Q. Tell me about the circumstances, Mr. Allum, in which a you became Technical Supervisor with responsibilities over 9 welding inspection at Catawba?
10 A. The circumstances were I was assigned that duty. We
, n were making a reorganization changing responsibilities, and 12 I assumed responsibility for the welding inspection.
13 Q. Who had those responsibilities before you, sir?
[
14 A. Charles Baldwin, 15 Q. You came in over Mr. Baldwin?
16 A. Over him, no, sir. I relieved him. We swapped duties.
17 Q. What did Mr. Baldwin do?
18 A. He'tcok over the NDE and Radiography Group and Document 19 Control Inspectors.
20 Q. The job that you held?
21 A. Yes, sir.
22 Q. Why did you swap jobs, Mr. Allum?
23 A. W e are routinely broadening our areas. That is a good 24 way to do it. -
~-
25 Q. Is that a routine transfer?
8
,. g- _ c. _
% 1 yc .
~
9'. 1 A . , 'Zqs , sir. x 2 Q. ~4 hat was- thea- reorganization that you had r eference to h 3 at that time? .
d A. We tobk the receiving inspectors and put them in a
- w. 5 separate area, and put the welding inspectors were in one T 6 , gfdup and the , document control, NDE and RT group were under
~
'- 7 one aIea.
8
~
, Q.' How did that differ from the way they were organized
,s. -
9 before? 4
+
- 10 A. i We ut receiving [lnspectori'that had previously been 11 in my organization, and they went to the Civil CC Engineers' -
x
.s ..
12 l, organization. m 4 - , t '
i 13
' (Q. How about the welding inspectors?
I 14 A._ IThey were -- became my responsibility.
15 You got a new job. Was there any reorganization that Q.
16 you are referring to that had affect on welding inspectors 17 aside from the change in jobs you had?
18 A. Just . changing'the organization as f ar as who had what i l' areas and who was responsible for what areas.
20 But, otherwiseno reorganization that affected the Q. .
21 welding inspectors?
l
^ %
22 A2 No. ~ -
~ ...
23 Q. IEo you have background expnrience as a welder, Mr.s ;
' ~
24 -
~
Allum? :.
.s \ . z-
~
25 ~
ff A. Yes7 sir. ; 1 9
d G '
\
- 4. f
, R_
, a f- .
..s - 1 ,
+
)
1 Q. Give me just a brief description of what your ,exp crience 2 isinthat) area, sir.
3 A. In welding area, I was certified by the Navy as a
- 4 nuclear welder.
5 Q. What kind of work did you do, sir, for the Navy?
6 A.. I' Was on a nuclear submarine for about twelve years as 7 an electrician, a welder responsi ble for NDE. I was 8 e Hull Repair Of ficer, Quality Assurance Officer, Nuclear 9 Systems Reapir, Quality Assurance, NDT Officer on different i
10 ships. I was the Director of the Navy's Non-destructive 11 Testing of Metals School in' San Diego. I was Director of 12 the Navy's Ships Test Examiner Certification Agency in San 13 Diego.
14 What kind of certification testing was that agency Q.
15 responsible for?
16 A. We were responsible for certifying all of the people ,
17 who give certification examinations to certify non-nuclear 18 inspectors for work on shipboard applications.
19 By non-nuclear, they didn't work on nuclear-related Q.
20 systems?
21 A. We were responsible for the te st examiners in non-nuclear.
22 We were responsible for training inspectors for nuclear and 23 non-nuclear ' areas, all ar eas in NDT, NDE.
24 Q. By NDT, you mean what, s ir? -
25 A. Non-destructive testing.
10
,, .- -- -.,s ,- - , . - , - - - .-.
( 1 Q. NDE?
2 A. Non-destructive examination.
3 Q. What's the diff'erence?
4 A. Same th ing.
5 Q.What experience had you had -- did you have, Mr. Allum, o as a welder on nuclear power construction?
7 A. Nuclear power?
8 Reactor construction?
Q.
9 A. I was a welder in the Navy in their nuclear power plant.
10 What you just described?
Q.
11 A. Yes.
12 Any civilian nuclear power reactor construction?
Q.
13 A. No.
(
14 Are you certified to perform nuclear safety related Q.
15 welding for work at Catawba.
16 No.
A. ,
17 Q. - At the time you became responsible for supervising the 18 welding quality control at Catawba, Mr. Allum, were any 39 ot the welding inspectors that you supervised certified to 20 weld at Catawba?
21 A. No, sir.
22 Had any of them been previously?
Q.
23 A. Yns , s ir .
24 Q. How many welding inspectors did you super'hise?
25 A. We had about thirty-four at that time.
11 4
O t 1
I 1! Q. This is about January of '82, i s that right?
2 A. Ye s, sir.
3 Q. Thirty-four ?
d A. About thirty-four.
5 Q. Approximately how many of those had previously been 6 certified as welders at Catawba?
7 A. I don't know.
8- Q. Do you have any estimate at all. I will not hold you 9 to figures, but I would appreciate an estimate if you have 10 it.
11 A. I don't have that information.
12 Q. IIalf of them? Don' t kno w?
13 A. No.
. .('
id Q. Was it common that they would have been certified pre-15 viously as welders?
16 A. At some time, the majority had been certified as welders.
17 Mr. Allum, are you familiar with the reorganization that Q.
la took place some months before you became responsible for l' the Catawba welding inspectors that resulted in the quality 20 control inspectors being reassigned for purposes of at least 21 administrative responsibility to the Quality Assurance Depart-22 ment?
- 23 A. Yes, sir.
24 Q.- Again, when did that happen, do you remember or know?
25 A. February 1, 1982, I believe. 1981.
12 d
g - ,e ww v w-r~m-- e v - . , - - , , ,, r - , y --, --~~w. w --
r,--m-m -&v.--enm- - - , -w e- -e-
/
t 1 Q. At that point in time, you had responsibility for NDE 2 and other inspection at Catawba?
3 A. At that time, I was at Cherokes, d Q. Was there a similar reorganizationat Cherokee?
5 A. Yes, sir.
6 Q. What is your understanding why that reorganization took 7 place, Mr. Allum?
8 A. Well, the reason was, as I understand ic, to have a 9 closer relationship with QA and to not have the inspection 10 and construction in different organizations.
11 Q. I'r sorry, to not have inspection and construction in 12 different organizations?
13 A. Righ t. Did you say not have?
14 Q. Yes.
15 A. To have.
16 Q. Separate the two functions, is that right?
17 A. Yes, in different organizations.
le Q. Do you believe that was a positive goal?
19 A. Yes, s ir .
20 Q. Why?
21 A. It put us in closer contact with the Quality Assurance 22 organization and the background of procedures requirements 23 and things o'f that nature.
2d O. Did that reorganization have any affe'ct oh the performance 25 of the welding inspection function at Catawba?
13 L
f 1 A. No, sir. I wasn't at Catawba, again, when that reorgan-2 ization took' place. I was at Cherokee.
3 Q. You came to Catawba in May?
4 A. Yes, sir.
5 Q. And, you worked in supervising NDE and mechanical inspec-6 tors?
7 A. NDE and radiography, receiving and document control, a Q. So, you had an opportunity to observe work at Catawba 9 beginning in May?
10 A. Yes, sir.
11 Q. You worked closely with welding craf t.?
j 12 A. Ye s , s ir .
13 Q. I'm asking you to express y oui opinion on that reorgani-Id zation. I understand your testimony you weren't at Catawba 15 when the reorganization took place, but shortly thereafter; 16 and is your opinion still that it would have no affect 17 on the performance of the welding inspection function?
i 18 A. That 's right.
19 Help me . understand a little, Mr. Allum, the layman's under Q. -
l 20 standing of the distinction between the kind of work that i
- 21 would be inspected by welding inspectors as compared and 22 contrasted with the kind of work that would be inspected by 23 the inspectors who were under your supervision when you first ,
24 came on the job; that is, the work for 'wh'ic'h'Ecu did radio-25 graphic and non-destructive examination.
14 J
o . - -
1 A. Welding inspection is a visual inspection. The non-2 destructive testing is either magnetic particle or liquid 3 penetrate, ultrasonic or radiography.
4 0 . Non-destructive is broader class and includes radiography?
5 A. Yes, sir,we separate the two fer organizational purposes.
6 Q. Give me that list again. Non-destructive, then, is 7 magnetic partile --
8 A. Liquid penetrate and ultrasonics.
9 Q. Wrat is it that you are inspecting by those means, sir?
10 A. The integrity of the welds.
11 Q. You are also inspecting welds?
12 A. Yes , s ir .
13 Q. Give me just a layman's understanding of what welds you
(
Id would inspect by visual means and therefore would be performed 15 by welding inspectors, and what weld you would inspect by 16 the non-destructive means?
37 A. All ASME welds receive visual inspection. ASME weld s
'I s require additional non-destructive examination, l'
20 A. Those are ones that are built to ASME code.
21 Q. What does ASME stand for?
22 A. American Society for Mechanical Engineers.
23 Q. What welds would be huilt to ASME code and what would not?
24 A. Primarily system welds would be AS$E weldi in a broader 25 category.
15 I
1 Q. Referring to primary' cooling system in the reactor?
2 A. Yes , s ir .
3 Any other systems?
Q.
d A. Lots of other systems.
5 Q. Is it fair distinction that safety-related welds, nuclear 6 safety-related welds are to ASME standards and non-safety
- 7 related welds are not?
8 A. Yes, sir.
9 Q. I' yas using that term as a layman's term of art. Is 10 there a term used on the job site that distinguishes ASME il code welds from non-ASME code welds?
12 A. No, there are designated with what class of weld they 13 are.
(. Id O. What designation did you use or do you use on the job?
16 You call them code welds?
Q.
17 A. Yes.
18 g, .Would those be welds on pipe?
39 A. Yes, sir.
20 Would it be welds on any other structures?
Q.
21 A. We do ASME -- no.
22 I'm talking about ASME. That is mostly pipe welds?
Q.
23 A. Pipe welds.
24 Exclusively piping welds?
Q. - -
25 A. Yes, sir.
16
o .
'( I How about pipe hangars?
Q.
2 A. Yes, sir.
3 Q. Those are ASME code?
4 A. Parts of them.
5 Q. What parts of them roughly generally? Is there a general o rule of what part pipe hangar welds would be code welds and 7 which sculdn' t?
8 A. I don't know that I can answer that.in leyman's terms.
9 Q. If you can, tell me why you can't?
10 A. We have code welds, code hangars, and we have construc-11 tion hangars that are not -- somebody has put a temporary 12 construction hangar and it's not a code weld.
13 Q. I'm talking about pipe hangars now?
14 A. I'm talking about pipe hangars, too.
15 Q. If it's a pipe hangar, and it's a permanent pipe hangar, 16 and it's hanging a pipe that is safety-related, would that 17 hangar be safety-related as well?
18 A. 'Yes.
19 Q. And, the welds on that hangar would be safety welds?
20 A. Yes.
21 And, they would be welded to code?
Q.
22 A.. Yes.
23 Q. How about hangars chat are over safety-related equipment?
24 Would they be code, required code welding? -
25 A. I don't think I'm qualified to make that statement.
, 17
-~
o .. .
a
( - 1 Q. The welds on code -- the welds which ASME code standards j 2 are required, do I understand that they would be inspected 3 both visually by welding inspectors and by non-destructive l
- 4 means by the NDE inspectors?
5 A. We have welds that fit both categories that do require 4
6 NDE as well as visual. All of them require visual inspection.
7 Q. Give me an understanding of the class of weldc, the a type of welds that would require both?
9 I'm not sure that we made any that required RT. We A. f to do have some that require NDE and PMPT.
11 Q. What does that last term mean?
12 A. Magnetic particle or liquid penetrate. t 13 Q. Visual as well as magnetic particle or liquid penetrate?
14 A. Yes, sir.
15 0 What kind of welds would that be?
16 A. As specified on one of our design drawings that we need 17 that inspection.
la Q. Can you give me a layman's understanding of what type 19 of welds that might be?
20 A., I don't guess I could.
21 12 How about visual and radiographic?
22 A. Same criteria except we have some that require visual 23 and radiographic or visual and magnetic particle or liquid 24 penetrate, and we have those options available. i
.25 Q. What kind of welds typically would require both visual 18 o
k
t i 1 and radiographic?
2 A. Our piping welds on safety-related piping.
- 3 Q. For those safety-related welds, welds on safety-related d piping, both inspectors would be required to perform inspec-
. 5 tions?
6 A. Right.
7 Q. During the period of time you have been at Catawba, what a were the systemc or areas of the facility that were being 9 worked on that required visual welding inspection?
10 A. Most all of them.
11 Q. Let's start with,when you, in May of '81, when you came 12 to the facility. What was the areas of work that were 13 requiring visual welding inspection?
Id A. All areas of welding.
15 Welding .was being performed on all the systems in the Q.
16 plant in all areas of the plant in May of '81?
17 A. That was currently in construction. The list of which 18 ones were being worked on, I can' t give you.
19 I'm not asking for a detsiled list. I'm only asking Q.
20 you to answer generally question, Mr. Allum, to the best of 21 your knowledge and recollection; and I appreciate this goes 22 back in time, but I'm trying to get a feel for what parts 23 of the plant were beingt worked on at least in the safety-24 related welding area, and can you give-me a general under-25 standing of where that kind of work was being done at that 19 9 y - _ - - . - .- _ . . - . ,
~~ ~
I
I time?
2 A. The entire plant.
3 Q. How would I find out specifically what areas of the plant 4 were being worked on at that time, sir?
5 A. I imagine process control sheets would give that and 6 the dates would be all I can tell you.
7 Q. In January of '82, when you took responsibility for super--
a vising the welding inspectors, Mr. Allum, what areas of the 9 plant were they working in and what systems were they working 10 in, sir?
11 A. All areas and basically all systems that were under 12 construction at that time.
13 Q. What areas and what systems were under construction at 14 that time?
15 A. I can't tell you that. I don't know.
16 Q. You just don't remember?
17 A. Right.
le Q. Were those welding inspectors under your supervisor working 19 in both Units 1 and 27 20 A. Yes, sir.
21 Were they working on safety-related systems?
Q.
22 A. Yes, sir.
23 There were approximately thirty-four welding inspectors Q.
24 at that time? -
25 A. Yes, s ir .
, 20
, - . 7 , .., - . - ,- ,
Am . . w. .e.,
I t.
1 Q. Do you have more than thirty-four at any point before 2 or since then?
3 A. More since then.
d Q. How many now approximately or how many at the maximum 5 and when would that have been?
6 A. I have about forty-five right now.
7 Q. Is that the max imum there would have been on the job?
8 A. I hould think so.
9 Q. How many wolders whose work they inspect now approximate-10 ly?
11 A. I don't know.
12 Nbuld it be more than one hundred?
Q.
13
{ A. Yes, sir.
14 Q. Would it be several hundred?
15 A. I would only be guessing, four hundred, five hundred.
16 An approximation?
Q.
17 A. Yes.
la Q. Is that the maximum number of welders there have been l'
on the job?
20 I have no way of knowing.
A.
21 By comparison, when you became responsible for the welding Q.
22 inspection function, Mr. Allum, in January of '82, were they 23 inspecting work of fewer welders or were there fewer welders 24
~
on the job then?
25 A. I don't know.
21
I 1
Q. You j u st don ' t . know?
2 A. I would think there was, but I don ' t know.
3 How many Q. total quality control inspectors at Catawba d
approximately?
5 A. Two hundred.
6 Is that a maximum?
Q.
7 A. I don't know.
e Q. You don't know if there have been more than that in the 9
past?
10 A. I doubt it. I don't know.
11 Q. How does that two hundred compare with the number at 12 Cherokee maximim?
13
< A. Cherokee was never at this level.
I 14 Q. There verenever that many at Cherokee?
IS A. No.
16 Q. Were you familiar with the pay reclassification of welding ,.
37 inspectors at Catawba?
18 Yes, sir.
A.
19 Q. You were at Catawba when that reclassification occurred 20 in July of '81?
21 A. Yes.
22 Q. Describe for me generally your understanding of what 23 that reclassification consisted of?
24 A. I was a reassessment of the pay scale 'for-inspector 25 personnel.
22
1 Q. By whom?
2 A. By our pay and allowance committee.
3 Q. Did you participate in that?
4 A. Not as such, no.
5 Q. Did you express your opinion about that or did they 6 solicit your views?
7 A. Yes.
8 To whom did you make those known?
Q.
9 A. Mrs. Kit Summerlan.
10 Do you have any idea how to spell her name?
Q.
11 A. Summerlan.
12 Q. What was hnr ' job?
13 She was the employee relations specialist or supervisor
{ Id A.
at Cherokee.
15 What was your opinion about that reassessment and re-Q.
16 classification?
17 A. I thought they were classified according to the job they 38 were doing.
19 Before the reclassification?
Q.
20 A. I thought the pay classification that was -- came out 21 ' of the committee was equitable for the job they was doing.
-22 Q. So, you agreed with the reclassification?
23 A. Yes, sir.
24 You still feel that way?
^
Q.
25 A. Yes, sir.
23
(
l O. Why was that reassessment and reclassification performed, 2
Mr. Allum?
3 A. Because the position analysis were rewritten, and the d
pay review committee reviewed the position analysis and 5
the duties assigned on the position analysis, and it was
'6 an evaluation made because of the duties they were required 7
to perform rcsponsibilities.
8 Q. What changed from the former classification?
A. The requiremer.t that the credit they were giving for 10 being former welders or mechanical inspectors or different
' areas.
12 Q. The changes from what to what, Mr. Allum?
33 A. We had required them -- we had sometime as a welder before
(- ,
they went into inspection.
15 Q. Before?
16 A. Yes.
37 Q. And, then after?
18 A. It's not a requirement.
I' O. How much welding experience had you required previously 20 for welding inspector?
21 A. There was no formal position analysis report at thab time.
22 Nhat there was was a homespun requirement or guideline that 23 we have two years welding experience.
24 Q. Informal guideline for two years welding. experience?
25 A. I believe that's correct.
24 1 , -
( 1 Q. By that, you mean it wasn't stated specifically in a 2 written' job description per se?
'3 A. As far as I know there was not a written job description d for welding inspectors or any inspectors that had been 5 approved by the pay review committee prior to that time.
^6 Q. Was there a written one that hadn't been approved?
7 A. Not that I know of.
8 Just wasn't any written ne at all that you know of?
Q.
9 A. No.
10 Q. What type of two years welding experience was generally or 11 customarily required of a welding inspector?
12 A.- There was no specifics that was required.
13 Q. What was customary requirements?
Id A. I really can't tell you that. I don' t know.
15 Was it, you know, welding out on the street on somebody's Q.
16 auto body shop or was it specific nuclear-related constructior.
37 experience?
18' A. I don't know.
I' O. You just don't know?
20 A. No.
21 The welding inspectors prior to the reclassification, Q.
22 they all met this informal two years experience requirement?
23 A. No.
24 Most of them did; the majority did?
Q.
25 A. Some of them did.
25
lC I Q. When you became responsible for supervising welding 2 inspectors, did you have a working understanding of the 3 experience levels of the' people you were supervising?
4 A. As related to welding inspection?
5 Q. Yes.
6 A. Yes, sir.
7 Q. Did you understand which ones have previous welding a experience generally and which ones didn't?
9 A. I knew their inspection experience.
10 Q. Didn't know anythng a bout their other experience?
11 A. Well, I had come across it, but I never made a point 12 to look in and see what other inspection or what other 13 experience they had.
t Id O. So, you weren't familiar with their experience?
15 A. Not related to welding inspection. I was concerned 16 with their certification as welding inspector, and other 17 areas unless I was looking for someone to fill that type of 18 area, I wouldn't be looking at that type of record.
19 Q. So, at the point in tim e of the reclassification, a 20 written job description was approved for welding inspectors 21 that did not require previous welding experience?
22 A. Correct.
23 Q. What kind of experience, if any, did the reclassification 24 welding inspector job -- -
25 A. Quality control experience, QA experience, related constru :-
26
/
1 tion experience.
2 Q. slow down a minute. Quality control experience?
3 A. Right .
4 Q. That was mandatory?
5 A. Yes, sir.
6 Q. How would one establish quality control experience?
7 A. Could have b een in another inspection area. Could 8
have been mechanical receiving document, control, any one 9 cf a number of various --
10 Q. Did it require previous experience as an inspector?
11 A. No.
12 Q. Could it have been as a clerk, say, in another QC area?
13 A. Not normally, i
14 Q. Not a clerk, not an inspector? What else?
15 A. Could be a QA analyst, someone that reviews records.
16 Q. Any other type person acceptable?
17 A. Construction elated experience.
Is Q. That is second thing, right?
19 A. Right.
20 Q. That could be in place of QC experience?
21 A. Right.
22 Q. Ccnstruction-related experience?
'23 A. Rig ht .
24 0 . What would count as construction-related . experience?
25 A. Welding, pipe-fitting.
27
r 1
Q. Any kind of craf t work on a construction job?
2 A. Right.
3 Q. Any kind of construction job 7 4 A. Yes.
5 Q. Office work on a construction job?
6 A. No.
7 Q. Actual craf t work?
8 A. Craft'uork.
9 Q. What was the other type experience?
10 A. Related construction exp erience and that covers that 11 area.
12 Q. So, the new job description required quality control 13 experience or construction-related experience?
(.
14 A. Yes.
15 Q. Any other requirements?
16 A. No, that would be it.
37 Did the new welding inspector job description require any Q.
18 specific training or examination?
19 A. Yes. s ir .
- 20 In addition to the experience you have described?
Q.
21 A. Yes, sir, experience I just described was an entry level 22 one in order to be considered to be an inspector.
23 Q. In order to be eligible for training?
24 A. Right. -
r-25 Q. I want to understand , Mr. Allum, how the training and 28
I testing requirements for welding inspectors changed, if it 2 did, before and then after the reclassification?
3 A. It didn't.
d Not at all?
Q. .
5 A. No.
6 Q. Where would these former job qualifications for welding 7 inspectors be set out if it was anywhere, Mr. Allum?
a A. 1 The qualifications for welding inspector are contained within our QA program certification of inspectors J-1.
10 I'm sorry. QA-140, 11 That's a training and qualification policy?
Q.
12 A. That has all our procedures requirements for certifica-13 tion, training.
~
( 3d Q. Of all inspectors?
15 A. Right with the exception of NDE and radiography.
16 Where are the requirements for NDE and radiography?
Q.
II A. In the NDE program manual.
18 Q. That same QA-140 had the provisions for the qualification l'
of welding inspectors before the reclassification?
20
- A. No.
21 Q. Where would it have been before?
22 Well, I don't know that to be exact, I don ' t know what A.
23 the time frame of it were put in there, but there was no 24 change in that document relating to the reclassification.
25 I hope you understand, I'm trying to understand where I Q.
29
i l
I could fir.d the job description.
2 A. You won't find a job description in either place.
3 Q . Neither has a job description?
4 A. No.
5 Q. Is there any other place that does have a job description?
o A. The requirements for the certification of the job is 7 found in QA-140 or NDE-B, the NDE program manual. Job a descriptions in a personnel nature are in our personnel 9 depar tment .
10 Q. Where would I find that? What document would have the 11 job descriptions?
12 A. I don't know there is a document with them.
13 Q. Have you ever seen it?
IA A. Yes.
15 Q. Can you give me an idea of what it's called?
16 A. I have seen a binder with them in it. I have seen 17 position analysis for individual inspectors.
18 When did you see that?
Q.
19 A. Daily.
20 You do see it daily. Tell me where you look to find it, Q.
21 then.
22 A.. In my drawer.
23 I know you have one, then, righ t?
Q.
24 A. Yes.
1"-
25 It's just called a position analycis for welding inspector ?
Q.
30
[
-g - - -e we -- ~ g y.. -- - - n
e r
1 A. Right.
'2 Q. The document Oa-140 sets out certification procedures?
3 A. Right.
4 Q. As f ar as you know it was the same before and after the 5 reclassification?
6 A. Basically the same.
7 Does that cover retraining?
Q.
8 A.. Yes, sir.
' Do you know,Mr Allum, whether or not that QA-140 pro-Q.
10 cedure for. certifying welding inspectors has been approved 11 by the NRC?
12 A. I'm sure'it has. Well, I dois't know that for a fact, 13 but I believe it has.
( 14 Q. Has that document as it relates to the standards for 15 certifying welding inspectors changed at all since construc-16 tion began at Catawba?
17 A. I don't know.
18 You just don't know. You are not aware of any changes?
Q.
I' A. There's been revisions to the procedure, but the signifi-t 20 cant changes as f ar as welding inspectors go, the answer is no.
22 Q. Are you aware of any audits of the qualification of 23 welding inspectors?
l 24 Yes, s ir . - -
A.
25 Q. By whom?
31 6
y -- - +<- % ..r--.-- - , ,_._m ,. , ,. , . , _...,s., w,__ _,-r..,w ,., . - - - ' r - -
(
1 A. By the NRC, by our double two audit teams, by I don't 2 know who else.
3 Q. When was the most recent one?
4 A. I guess within the last six months.
5 Q. Are you aware of any findings by that audit?
6 A. There were no findings.
7 Q. Are you aware of any findings of the previous audits?
8 A.. I don't know of any finding that has been found in that 9 area.
10 That's as f ar back as you have been on Catawba site?
Q.
II A. As far back as I can remember.
12 Did the October,1982, self-initiated evaluation include Q.
13 a review of the certification be qualification of welding 14 inspectors?
15 A. I believe so. I don't know.
16 Q. Let m e understand. Why do you believe they did?
17 A. There was an all-encompassing type audit when they did 18 it.
19 Mr. Allum, what role, if any, does technical school' Q.
20 welding instruction have in the qualification or certifica-21 tion of welding inspectors?
22 A. I don't understand what you are saying.
23 Do the certification or qualification requirements give Q.
24 any credit for tech school welding training? A 25 A. No.
32 o
e .-
1 Q. What are the re-certification requirements for welding 2 inspectors?
3 A. Have to continue operating safisfactorily, and we give d a recertification exam at the end of every three-year period.
5 Q. How long has that requirement been in place as far as 6 you know?'
7 A. As long as I know.
8 Q. Anybody ever flunked their certification exam?
9 A. Not that I know of.
30 You are not aware of any welding inspector at Catawba Q.
11 that f ailed to pass their certification, is that correct?
12 A. '2 hat 's correct.
13 Are you aware lof any welding inspectors at Catawba that Q.
( id in the initial tried and didn't pass the certification t'est?
15 A. Not that I'm aware of.
16 Nbuld the recertification procedure allow them to be Q.
17 retested if they did?
18 A. Af ter a period of time and additional training.
19 If someone failed to pass a recertification exam, would Q.
20 there be any requirement that the inspection work that that 21 inspector had performed be reviewed?
22 A. I never had that situation come up. I believe that 23 would happen'.
24 You believe.there would be a requirement..to go back and Q.
25 look at that inspector 's work ?
33 i
I A. As far as I know. I don't know that has ever happened.
2 Q. Mr. Allum, generally do you understand that the recerti-3 fication -- I'm sorry. The reclassification of welding d inspectors resulted in reducing the pay grade of the welding 5 ' inspectors?
6 A. Yes, sir.
7 Q. In reducing the level of job requirements for the posi-8 tion of welding inspector?
9 A. Yes, sir.
10 Q . By reducing this sort of informal requirement of prior 11 welding experience, two year welding experience?
12 A. Right.
13 Q. Were there new persons qualified for welding inspector 3d after that reclassification who had not previously worked is as either welding inspectors or welders at Catawba?
16 A. No, sir.
17 Q.. No.
18 A. No.
19 How about, to break that down a little bit, were there Q.
20 ;crsons who came on as welding inspectors after the reclassi-21 fication that had not previously been welding inspectors?
22 A. No, sir.
23 Wnre there any persons who had been welding inspectors Q.
24
~
who would be terminated or transferred out ofs.the welding 25 . inspector position?
34
.- .. , . _ . _ . . . . - . -- , . = - . -
(
A.
1 I need more information. What are you saying?
2 Tell me what you don'g understand?
'Q. What am I not being 3 clear about?
d A. Are you saying have there been people that have quit 5 since that time or who were transferred to other divisions?
- A. First of all, I want to know who lef t the position of 7 we.Iding inspector. First of all, the people who quit.
8 A. Not that I know of. I don' t think so.
9 How about people who transferred to other positions?
Q.
30 A. Yes.
Il Q. How many?
12 A. Two.
13 0 What position did they transfer to?
( Id A. They went back to the welding craf t.
15 Q. Who were they, sir?
16 A. Vernon Godfrey and Gene Lawing. ,
17 Q. Are both of them still employed by Duke Power Company?
18 A. Yes, sir.
19 Q. Are they still both welders at Catawba?
20 j A. Yes sir.
21 Q. Were Mr. Godfrey and Mr. Lawing among the thirty-four
- 22 welding inspectors who held that position when you took 23 responsibility for supervising them?
24 A. That's right, they were. .
a..
25 Q. You now have forty-five approximately, is that right?
! 35 l
l G
O 4 l~
?
V 1 A. Yes.
2 Q. Where did the others come from?
3 A. They were rehires, prople who had ocen laid off at 4 Cherokee or one that had previously quit at Catawba and was 5 rehired.
6 Q. Help me understand if I'm following that right now.
7 You had thirty-four and two -- Mr. Godfrey and Mr. Lawing --
8 went back to welding craft. That takes you down to thirgy-9 two, and --
10 A. I said originally that thirty-four was approximately.
11 Q. Yes, sir, and I'm not going to hold you to all that, 12 but just generally. Thirty-four and you lost two. They 13 went back to the craf t and that's thirty-two, and you went to
( 14 forty-five, and that's thirteen more approximately. Now, 15 help me understand where the other thirteen more came from 16 approXimately?
17 A. One of them was a rehire, a welding inspector who had 18 quit and reapplied for a position.
19 Q. Who was that, sir?
20 A. 'Eddie Femster.
21 Does he still work there?
Q.
22 A. Yes, sir.
23 Q. When did Mr. Femster quit about? -
24 A. I don't know. .
25 Q. When was he rehired about?
e 36
_ _ _ _ _ _ _ _ - _ _ _ _ _ - . _ _ - _ _ _ _ _ 1
O D t
.'g a s -
'gs-9
'I il
[
. 1 A. October 5, '81. October something. ,
2 Q. Now, then the rest of them.
3 A. They were rehiies from people who were laid off at 4 Cherokee, and people:who were reclassified from NDE inspec-5 tors and_ trained and classified as division inspectors.
6 ~Q. ,
Let's break that down. How many approximately came 7 over from Cheroked? ~
8 A. Five, I guess.
9 Q. That five that came over from Cherokee, they had been 10 welding inspectors over therE?
J! A. Yes, sir.
12 Q. Had they been welding inspectors at Cherokee prior to 13 the reclassification?
( 14 A. Yes, sir.
. 15 Q. So , they, too , had the approximately two years prior 16 welding experience?
17 A. Yes, sir.
~ is Q. Is that: right?
19 A. I believe that' s r ight.
_ 2a Q. So', about how many were reclassified former NDE inspectors?
21 There's a bout seven is what my math is. A bout that?
22 A. I guess. That's right, I don't know.
23 Q. Let's talk a l'.ttle about them. Had you previously 24 superviced them when you supervised the NDs' inspectors?
25 A. Yes, sir.
37 l
l
O o Y'
i 1 Q. Those seven, can you remember their names and how many 2 can we list here?
3 A. Rick Moore, Tom Barnes, Max Reep, Gary Moss, Tom Costello, 4 David Zimmerman, Stan Strauss, Keith Davis, Don Jolly.
5 Q. That adds up to nine. Good r ecall, Mr. Allum. Of the 6 nine that you have just mentioned, had any of them previously 7 worked in the welding craft at Catawba?
8 A. In the welding craf t, no, sir.
9 Q. Describe the retraining and the recertification that 10 was performed for the former NDE inspectors?
11 A. We gave .them formal classroom training, on-the-job 12 training, general, specific and practical examination.
13 Q. That's three different tests?
14 A. Yes, sir.
15 Q. Was this a special recertification that was designed for 16 them?
17 A. We ll, this was not a recertification. This was an
~
is initial certification in all but one case.
19 I see, and which case was that?
Q.
20 A. Gary Moss had been previously certified as a welding 21 inspector.
22 Q. Then gone to NDE and then back again?
23 A. No, he was a welding inspector at Cherokee. HE was 24 rehired at Catawba as an NDE inspector.and' trja_nsferred over 25 to visual.
38 sr e * --*w --
% * * <'--w- -- - - =- - * --p
l- .- .
~
'f 1 Q. For the rest of them, was this a tailor-made program 2 to retrain them from MDE to welding inspector?
3 A. No, this was the same certification that all welding 4 inspectors took.
5 Q. Let's talk about this test a little bit. Break those 6 down for me again.
7 A. A general test.
8 Q. Describe that for me.
9 A. General test on welding, different testing related subjects .
10 Metallurgy, pipe configuration, joint design, welding processes ,
11 things of that nature.
12 Q. W a s that t.est previously required for welding inspectors?
13 A. Yes, sir.
( 14 Q. When they had prior welding experience?
15 A. Yes.
16 -Q. Help me understand this, Mr. Allum. It would just seem 17 common sense that someone who had worked for two years as 18 a welder would have a bit easier time passing a test on 19 welding and metallurgy and pipe configuration and welding 20 processes than someone who had never worked as a welder 21 unless that: person who never worked as a welder was given 22 some other substantive source of information to help pass 23 the test.
24 A. It's one hundred percent incorrect.
25 Q. How does the person who has never worked as a welder 39
r 1 learn the information needed to pass the test?
2 A. Training.
3 Q. The training program does change them?
4 A. No, the training program has always assumed that the 5 person coming in had no knowledge whatsoever. We do not 6 rely on previous knowledge or assumed knowledg e.
7 Q. So, the training didn't change at all?
8 A. No.
9 Q. Before and after the reclassification?
10 A. Right.
11 That's the general test.
Q.
12 A. Right.
13 Q. That's a written test, oral test?
( 14 A. Yes, sir, written test.
15 What kind of written test is it? True, false; multiple Q.
' 16 choice; essay?
17 A. All-types.
18 Fill in the blanks?
Q.
19 A. A combination.
! 20 Of what?
Q.
21 A. Multiple choice, completion and essay.
i 22 Who administers that test?
Q.
23 A. That is administered by our training staff out of the 24 general office. - -
25 That means here in Charlotte, corporate office?
Q.
. 40
?' ,
A. Yes.
2 Q. Do they also perform the training?
3 A. Yes , sir .
4 Q. How about the other test that are performed?
5 A. Specific test as to a test of dealing with the various 6 procedures that they are inspecting to.
7 Q. Does that vary from one inspector to ancther or from 8 one time to time?
9 A. No, it does not vary.
10 0., So, it is specific to the work of a welding inspector 11 at Catawba?
12 A. Right, a welding in spector period.
13 What subjects does it include?
Q.
i Id A. It covers various procedures; how -- what the different 15 things mean on procedure. How to do inspection by the pro- .
16 ced u re .
17 Q. All right, sir, does -- is that preceeded by training 18 on rhat subject?
19 Yes, sir.
A.
20 Q. Has that test or that training changed since the reclassi-21 fication?
22 A. No, sir.
23 It has not?
Q.
24 A. No. ..
25 Has it changed when the procedures have changed?
Q.
. 41
if' 1 A. Yes.
2 Q. So, it has changed?
3 A. Only to update the questions and procedures are basically 4 the same.
5 Q. Any significant changes at all since the reclassification 6 in the training?
7 A. In training?
a Q. On this subject?
V A. No.
10 Q. Who administers that test and who trains?
11 A. The same people.
12 Q. They train them on that subject as well?
13 A. Yes, sir.
Y '
id O. Any other testing?
15 A. Practical ex' amination.
16 Q. Tell me about that a little bit.
17 A. The inspectors are -- prospective inspectors are given 18 samples of welds and they are to go through the insoection 19 tecnique they would use to evaluate that weld along with 2c the procedures and evaluate it and present a report.
21 Q. Written report?
22 A. Yes, s ir , it's an inspection document.
23 Q. Essentially a facsimile of the document they would use 24 actually in the field? .
25 A. It's the inspection document they would use.
s 42
,y a- - - - - - - , -,-,%.-- w- -,
f . . - -
/
I Q. How is that examination evaluated?
2 g, rei s againct a known check sheet to see if all areas have 3
been covered and all of it, any or all indications have been d
noted in the weld or material to evaluate it.
5 Q. Is there a standard piece of work that is the su bj ect 1
6 of the practical exam?
7 A. Yes, sir, a
Q. The same for everybody?
9 A. Yes, sir, there is tests -- they may not take the exact 30 same test specimen. We have numerous test specimens that Il they test, but it's all the same type of test.
12 Q. This is random which one they get. They get one of a
'3 number of specimens?
A. Yes, they get several.
15 Q. They get several. Who evaluates that test?
16 A. The same people.
'7 '
Q. They train them on that subject?
18 A. Yes.
Q, Are there any other tests?
20 A. No.
21 Q. Is it possible to fail one part of the test and still be 22 certified?
23 A. No.
24 Q. What happenes if you do f ail one part of :the te st?
25 A. You have to be retrained.
43
4 8 f
1 Q. And, retested on that part?
2 A. Yes, sir.
3 Q. What are the requirements for retraining and retesting?
4 A. I'm not aware of anyone that has required it, but there 5 is a time frame that they have to be retained and have an 6 additional test, and what that time frame is, 1 don' t know.
7 Q. You know of nobody that has flunked the test?
8 A. No.
9 Q. As far as you know, no one has?
10 A. As f ar as I know, no one has.
11 Q. With respect to the practical part of the exam, practi-12 cal exam, are the candidates tested on procedure to be 13 followed when they find a problem?
14 Yes, sir.
A.
15 Q. Descri be that, how they are tested on that?
16 A. Well, they accept or reject the inspection that they 17 are doing, the piping or whatever the test sample might be.
18 They explain to the examiner, "I have rejected this and here's 19 why I rejected it."
20 Does the specimen that's used or specimens that are used Q.
21 in the specific test -- I'm sorry, the practical exam, test 22 them and under the circumstances in 5hich they would non-23 conform a weld?
24 A. No. ~
25 How about the circumstances in which they would write Q.
44
1 u, some other deficiency?
L 2 A. They would reject it. They have a reject or would just 3 not accept it, either one of the two.
d As a matter of process control?
Q.
5 A. Right.
6 Q. But, not as a matter of NCI?
7 A. The NCI situation requirements would not be met at this 8 time.
9 Q. How about the R-2 requirements?
10 A. What about them?
11 Q. Are they tested in circumstances that would test them 12 for identification of a weld that would call for employing 13 the R-2 procedure?
(' Id They are trained in Q-1 and R-2 on how to handle a situati .on A.
is and to use those' documents.
16 g, yem asking of tha testing now,.
17 A. Do they make out an R-2A or make out QA?
18 Yes.
Q.
19 As part of the practical exam.
A.
20 Q. Simply using process contr31 documents?
21 A. Right.
22 Did any of the other tests you have described include Q.
23 testing on recognition of deficiencies that should be pro-24 cessed under either procedure R-2 or Q-l?. ..
25 A. That's included in all training.
, 45 f
s f~ 1 Q. . How a bout testing?
2 A. A separate test on what that procedure covers is
'3 covered in the specific --
4 Q. That's what I want to understand. Help me understand which 5 tests include that and describe --
t 6 A. The specific examimnation. It deals with the procedures 7 that you are working to.
8 Q. Describe for me how the specific exam includes testing 9 on use of procedure Q-1 and R-2?
10 A. There are questions and situations involved in testing.
11 Question like how to use them, what they apply to, what they 12 are for.
13 Q. What are those questions?
{
14 A. I don't know.
15 Q. Have you ever seen those questions?
16 A. I have seen the examples.
17 Q. Have you seen the part of the exam that included questions 18 on how and when to employ procedure Q-1 and R-2?
19 A. I have seen those.
20 Q. Describe the best you can what -- how the subject is 21 covered on the test.
22 MR . M cG ARRY : I believe the witness said he didn't 23 know.
24 Q. Do you know at all?
I' 25 A. I have seen the exam. That 's all, and, you know, I have
'I 46
i 1 not read them for that type of information.
-2 Q. But, you recall that those two subjects were included?
3 A. I have seen the subjects included.
d You can't tell me anything about the way they are in-Q.
5 cluded?
6 A. No.
7 These tests are preceeded by formal classroom training Q.
e on the subjects on which they are then tested, is that right?
' They have a classroom examination or classroom training A.
10 on general and specific and factual.
11 Then, they are tested on he specifics?
Q.
12 A. Yes.
13 Q. You said in order to get certified, they also have on-Id the-job training?
15 A. Rig ht.
16 Describe what on-the-job training consists of.
Q.
37 That is working with a certified inspector going out and A.
18 witnessing inspections. At times doing inspections prior 19 to the other inspector going to and doing the inspection 20 for signature.
23
- Q. What is the specific OJT requirements?
22 A. Six months on-t he-job training.
23 Q. Prior to testing and certification?
24 Yes, sir. -
A. ti 25 What other duties would a candidate inspector perform Q.
47 T
I when he is undergoing on-the-job training?
2 A. That is the primary duty.
3 Q. What other duties though?
4 A. That is it. That is his duty.
5 Q. That is it period?
6 A. It's on-the-job training.
7 Q. Wbuld he serve as an assistant to a welding inspector a in the welding area?
9 A. That's how he gets his on-the-job training.
10 Q. As an assistant?
11 A. He is not authorized nor can he make an inspection. All 12 he does is go out and be with the inspector at the time he 13 places inspection, makes a separate inspection that he
(.
14 concurs or talks with the certified inspector about what he is found and see if he understands this program.
16 Q. He doesn't walk around with his hands empty. I mean, be 17 is expected to work at the time he is cetting on-the-job 18 training?
19 A. That is his assignment.
20 Q. What is that work. .
21 Q. Be with thac certified inspector and follow him around, 22 bird dog him.
23 Q. Does he perform any productive function other than learing?
24 A. No. -
25 Q. Nothing?
48 s
v .- < - - - - + - r --
t- '--w
1 A. No.
2 Q. Does that six month OJT requirement, has it been the 3 same before and af ter the reclassification?
d A. Yes.
5 O. No changes there?
6 A. As far as I know or can remember.
7 Q. Mr. Allum, you generally are f amiliar with the concerns a
that were raised by a number of welding inspectors at 9 '
Catawba in late 1981 or 82?
10 A. I'm familiar with the items that were generated, yes.
11 Q. And,t he work and reports of the Catawba Welding Task 12 Force that'resulted from those concerns?
13 A. I'm f amiliar with it.
( Id Q. And, the implementation of the-recommendations of the 15 Task Force?
16 A. Yes, sir.
17 Q. Describe, sir, the changes in use of non-conforming 18 items and procedure R-2 that occurred subsequent to the 19 concerns being expressed on the work by the Task Force?
20 A. Repeat that.
21 Q. I want to understand your description of how the use of 22 the procedure Q-1 for non-conforming items in R-2 for 23 construction. deficiencies in the welding area changed sub-24 sequent to the time when those welding . inspect. ors expressed 25 those concerns and the Welding Inspector Task Force did its
, 49
, ,, y ._n,g w w g-- -*- t '-
I work.
2 A. The basic change was in definition of what we was 3 classifying as non-performance item or R-2A.
4 Q. Describe that change.
5 A. The R-2A was something that was part of a pre-planned 6 inspection that would be considered an R-2A and Q-1 was 7 something that was found after the final inspection was 8 thrcugh or a procedure type violation.
9 Q. After the final inspection was through?
10 A. Righ t. .
11 Q. Or, I'm sorry. I missed that.
12 A. Something in the procedure that we needed to change 13 the procedure or had a question with procedure.
14 Or for a procedural question?
Q.
15 A. Uh huh.
16 Q. What was the policy with respect ce non-conforming items 17 with R-2A's before the change?
18 A. It was really the same, but just a better definition was 19 forthcoming that clarified any areas.
20 So, things were less clear before the change?
Q.
21 A. Yes.
22 Before the change, when things were less clear, how Q.
23 - were things done differently than af ter the definition?
24 g, g_1Ae s were written for items that-were found in inspec-25 tien that were readily correctible without additional input.
50
~ '
6 O h ,-
'l Q. What kind of items?
2 A. Some applying to surface on a weld, an undercut.
3 Q. Erregular surf ace, give me the second thing, d A. Undercut.
5 C Slag? What a bout salg?
6 A. That would be -
! 7 Q. Inclusion, is that what you said?
8 A. Inclusion. ,
9 Q. Others come to mind? .
30 A. Thats the general type of thing.
11 Spattering?
Q.
P 12 A. Wbld spatter would be th3re.
13 Q. Anything else that comes to mind typical?
(.. Id Those are typical examples of what was there.
A.
15 Q. How about o'c hers if they come to mine. I'm trying to 16 understand the type of thing.
37 A. That's basically the type.
18 How about markings?
Q.
19 A. We did heve markings that were on NCI's.
. 20 Q. Is that an example of something that would have been 21 found in the normal course of pre-planned inspection and 22 producing an NCI before but shouldn't now under the new 23 definition?
24 A. That's right. Now, you must clarify markings because 25 if there's an incorrect marking on there the same criteria
, 51
. e -
I would be involved. If there's a pencil mark or something 2 of that nature.
3 Q. Help me understand' the dif fer ance.
4 A. If there's a pencil mark on there or something that 5 would be readily repairable, that would not be an NCI situa-6 gion, 7 Either before or after?
Q.
8 A. Bu t , we had written them up as NCI's previously.
9 They had been written up?
Q.
10 A., Yes, sir.
11 But, a markings for control of materials?
Q.
12 A., Thatwould definitely be an NCI.
13 Before and af ter?
Q.
i 14 A. Yes, sir.
15 Q. How about cleanliness?
16 A. That was written up on NCI's previously.
I? Q. Not now?
18 A. No.
39 Q. R-2A now?
20 Possi bly.
A.
21 Q. Maybe not even that?
22 A. Possibly.
23 If not that then what?
Q.
24 Withholding his signature until it-meets .the cleanliness A.
25 requirement.
52
4 ..
- 4' 1 Q. Process control?
2 A. Yes.
3 Q. How about feilure to follow hold points?
d A. That's NCI .
5 Q. That's NCI before?
6 A. Yes, sir.
7 Q. After?
8 A, yes, 9 Q. How about misalignment?
10 A. That was NCI befor e .
11 Hov about af ter?
Q.
12 A. Tnat would not be. That would be process control.
I .',
13 Q. Would be resolved by process control?
- I.
14 A. Righ t.
l 15 Q. Does it require judgment on the part of the welding 16 inspector to get determine under the new procedure when 17- to do an NCI, when to do an R-2 or whnn to resolve the matter is through process control?
4 19 A. Everything requires judgment to a point.
.20 Q. I'm asking about those specifics; those require judgment?
21 Those decisions?
22 A. They know that they have an R-2A situation if it cannot 23 be readily corrected. If it's a pre-planned inspection, it 1.
24 is going to be an R-2A. If it's not, it 'would be an NCI.
25 Q. There have been fewer NCI's since the definitions have 53 i-
t V
4, 1 been changed?
2 A. Yes, sir.
3 Q. The welding area, Mr. Allum, give me an idea of what 4
the effect has Seen on the number of NCI's.
5 A. There has been a significant affect.
6 Q. A significant aff ect?
7 A. Yes.
8 Q. Meaning fewer NCI's?
9 A. Feker NCI's.
2 10 Q. Give me an idea of the numbers. How many fewer as bes t 11 you can.
12 A. We have or don't have a number readily available to 13 me where we stand, but I would say probably seventy percent.
L' 14 Q. Seventy?
15 A. Seventy percent reduction.
16 Q. In NCI's?
17 A. In NCI's.
18 Q. Give me a rough idea of numbers now. Any which way you 19 generally use them. You do a trend analysis of NCI's?
20 A. I don't.
21 Q., Someone does?
22 A. Someone does.
23 Q. Who does that?
24 A. That's done by our QA people. -
25 Q. Mr. Davison, his staff do a trend analysis?
, 54
$ 0 s is i 1 A. I don't know who actually performs it.
2 Q. But, it's done and it is done in the welding inspection 3 area?
4 A. Yes.
5 Q.. Do you see the trend analysis reports?
6 A.- No.
7 Q. Are you informed about the results of those reports 8 generally?
9 A. No.
10 Q. Is there some other source of information that you have 11 that would report the -- Does QC provide you the information 12 on how many NCI's there are or just generally few or more?
13- A. No.
14 Q. How do you get your information?
15 A. What information? ,
16 Q. The information on whether there are significant increases I:7 or decreases in NCI's.
18 A. When I was reviewing NCI's doing technical review I knew 19 at that time because they bhey come across my desk.
20 Q. That was at the time when you were supervising welding 21 inspectors?
22 A. Right.
23 Q. You would have to see the NCI when it was written?
24 A. Right. .
25 Q. Now, roughly then the point where you were supervising
, 55
t' I the welding inspectors, before the procedures were changed, 2 how many NCI's were you getting, say, in a month in welding?
3 A. That's hard to say.
4 Q. What is the highest you remember a week or month or 5 whatever period of time sticks in your mind?
6 A. I would say ten or twelve a day.
7 Q. How many were you getting when you last were responsible 1
8 for supervising welding?
9 A. Very few, less than one a day.
10 Q. If I were going to try to approximate the average number 11 of NCI's over a period of time but substantial welding work 12 was going on at Catawba, before the change, would it be 13 in the neighborhood of more than one a day?
(.
14 A. I don't know.
15 Q. What do you think?
16 A. I don't know.
17 Q.-Just don't know?
18- A. No.
19 Q. Let's talk about the R-2A's. Did you have R-2A's before 20 the procedure changes?
21 A. We did not use R-2A's in welding inspection at that time.
~
22 Q. What were they used for then?
23 A.. They were used in other inspection areas.
24 Q. Like what for instance? ,,
25 A. Mechanical, electrical.
56 4
4 a
( , , - _ . . . , , 3,... _ --..-w_ -,..w _ .
y,, .m_w,.- . , , _ + . 7r.,__._. m .,,,w_.,,- -
m,, , ..,q.,n.,.m._- .c.,~.._,
- 1 Q. All other craft areas besides welding?
2 A. Inspection areas.
3 Q. All other inspection areas besides welding?
4 A. Not all. No, I would not say all. I would say mechanical 5 and electrical and civil.
6 Q. Why weren't they use.1 in welding before?
7 A. Because we were procedure dictated where you would order 8 a Q-1A.
9 C. Non-conforming item?
10 A. Right.
11 After the procedure change and the definition change, Q.
12 R-2A's became used in welding inspection?
13 A. Right.
d .
14 Q. The welding inspectors used the R-2A?
15 A. Yes, sir.
16 Give me an idea of numbers by comparisen to the frequency Q.
17 with &&ich NCI's would be used?
18 A. I do not review R-2A's. I don't have that figure.
19 Q. Did you review R-2A's when you supervised welding inspec-20 tions?
21 A. No.
22 Why not?.
Q.
23 A. They ' wasn't part of my responsibility.
24 Who did it?
Q.
25 A. It was an issue reviewed by the technical supervisor and 57
i ,-
'- I went up to our organization to be reviewed.
2 Q.- You weren't a technical supervisor?
.3 A. Supervising technician, I'm sorry. First line supervisor 4 verified them and sent them up to our process or number 5 identification program to get a serial number on them and 6 get them logged in in the system.
7 It didn' t come through you?
Q.
8 A. No.
9 Q. Help me follow that again. Welding inspectors immediate 10 supervision -- first line supervision?
11 A. Right .
12 Q. What is the first line supervision for a welding inspec-13 tor?
T 14 A. A supervising technician.
15 Called sapervising technician?
Q.
16 A. Rig ht.
17 Who are the supervising technicians in welding inspection Q.
is at Catawba now?
19 A. Today?
20 Q. Yes.
21 A. Pat Sifford, Stanley Ledford, Bo b Harris, Beau Ross, 22 Bill Deaton.
23 Q. Was there the position of supervising technician at the 24 time prior to the time of the reclassification of the welding 25 inspectors?
, 58
'l 1 A. Yes, sir.
2 Q. Did all these gentlemen hold that position then?
3 A. Yes, sir.
4 Q. Any others?
5 A. No.
6 Q. Any changes at all in those people?
7 A. Pat Sifford is just new on that ane, Catawba.
8 Q. He has come on since then?
9 A. Yes.
10 Q. How long has Mr. Sifford been there in that position 11 approximately?
12 A. Days, 13 Q. Ju st came on?
( 14 A. Yes.
15 Q. Where did Mr. Sifford come from?
16 A. McGuir e .
17 Q. What job did he have over there?
18 A. Same job.
19 Q. So, the first line supervision, the supervising technicians, 20 reviewed the R-2A's and then where do they go?
21 A. They go up and get a number for certification number.
22 Q. Where do they get the number?
23 A. We have an organization that keeps logs of them, keeps 24 track of them. -
f, 25 Q. They work out of the QC office?
, 59
I A. No, in our construction management office.
2 What specific construction management office would you Q.
3 go to to get an R-2A number issued?
d A. Unit one process, unit one status coordinator's office.
5 Q. Who is the person by title and name who is responsible?
6 First of all Unit 2 is another place?
7 A. Yes, they are handling them all out of one office.
8 Both Unit 1 and 2 come out of Unit 1 status coordinator Q.
office?
U A. I believe that's correct.
11 Q. Who by name and title is responsible f'or issuing the 12 R-2A numbers?
13 I don't know the name A. There's a clerk in that office.
3d or title.
15 Is there a supervisory level person in that office who Q.
16 has to sign off before they issue that number?
37 A. No.
Is Q. It's a function that the clerk does?
19 A. The clerk puts a number on it and it goes through distri-20 bution.
l 21 l Q. And, logs it in?
22 A. Yes.
23 Does the~ supervising technician have to approve the Q.
24 :-
origination of the R-2A by the inspector?
25 A. He does not have to formally approve it, no. He looks at l
l 60
I 9
) i it to keep him advised of the status of the work.
2 Q. But, the welding inspector has to advise the supervising a technician before he originates an R-2A?
4 A. Not before. He shows it to him af ter he has written it, 5 and he shows it to the supervising technician to keep him 6 aware of the status and what is going on.
7 Q. So, he has originated the R-2A?
8 A. That 's right.
9 Q. He has written it up?
10 A. Right.
11 Q. And, then he has to show it to the supervising technician?
12 A. Right.
la Q. Bu t , before a number in issued?
14 A. There is no requirement either way. There is no procedure is requirement for him to show it to the supervising technician.
16 Q. There is no procedure requirement that he show --
17 A. No.
18 Q. But, that is the requirement?
19 A. That's they way we do business.
20 Q. T hat 's t he wa y we do it . I want to understand how you 21 do it. So, he shows it to the supervising technician and, 22 again, tell me how you do it. They show it to the supervising technician to advise them of what they are doing, but then
~
23 24 they go get the number issued? ~
~-
25 A. Uh huh.
61
1 1
Q. And, log it in?
2 A. It could be either way right now. There are no set ways 3 they have to do that, d Bu t, typically it would go to the supervising technician Q.
5 first and then to the construction manager's office to get 6 the number?
7 A. Right.
8 Q. Does the supervising technician have the authority to 9 instruct the welding inspector the technician supervist , to 30 resolve the deficiency by other than an R-2A?
11 A. Repeat that.
12 Sure, does the supervising technican have the authority Q.
13 to tell the welding inspector this ought to be resolved in 14 some other fashion than writing up an R-2A?
j 15 A. He can instruct them it needs to be a Q-1A. He can 16 reconmend to him it should be something that can be done 17 readily correctible and can be done by process control. He is can ask those questions, yes.
19 He can, as the supervisor of the welding inspector, he Q.
20 can direct that the welding inspector handle it in a way 21 other than an R-27 22 A. No, we do not do that.
23 Does he have the authority to do that?
Q.
2' A. No. -
r-25 Does not have the authoirty to do that?
Q.
I 62
U 1 A. No.
2 Q. Do you know of any instance when the supervising techni-3 cians or other supervision have exercised their supervisory 4 authority to the welding inspectors to direcb them to handle 5 it in a way other than R-2A?
6 MR. McG ARRY: I want to interject an objection.
7 I think that question assumes that the supervising technician 8 has the authority to direct, and I think the witness just 9 indicated that the supervising technician doesn't have 10 the authority to direct.
11 Q. Do you know of any instance where supervising technicians 12 have told welding inspectors not to issue an R-2A?
13 A. No.
14 Q. Do you know of any instance when welding inspectors 15 have complained that supervision has instructed them not to 16 i ssue an R-2A?
17 A. No.
18 Q. Do you know of any instances of, .Mr. Allum, where welding 39 inspector has originated an R-2A and written one up an? before 20 a number has been issued for that R-2A and before it's logged 21 in that that inspector has consulted their welding technician 22 and that the R-2A has been voided?
23 A. No.
24 Could that have happened? - ~
Q.
25 Anything could happen.
A. I say I don't know of it happening ,
, 63
- , , - , ,, - . - - , - - - . . , , e
'l 3- and I don't think it happened.
2 Q. How about instances -- do you know of any instances 3 where welding inspector has originated an R-2A and that R-2A d has been destroyed before a number has been issued or it has 5 been logged in?
6 A. No. ,
7 Do you know any complaints or allegations that that has Q.
8 occurred?
A. No.
10 Q. So, the R-2A then is originated, shown to the technician, 11 number gets issued, it gets logged in, you don't see it. Who 12 does?
13 A. It goes to the people who are responsible for resolving I,
14 it.
15 Who are they, sir ?
Q.
16 A. Technical support organization or quality assurance organ-17 ization.
18 Q. Or quality assurance?
19 Rig ht.
A.
20 When would it be technical support and when would it be Q.
21 quality assurance?
22 A. Procedure, it would be QA. If it was work problem, it 23 would be tech support.
24 Q. . So, a materials problem or construction pc.oblem, i s 25 that what you said?
s 64
- - - w -,-
g- e v yy. --nm--m r e- y
~
- 1 A. Right.
2 Q. Tech support reports to construction?
3 A. Yes.
4 Q. QA is quality assurance department?
5 A. Right.
6 Q. If it's procedure problem, it goes to QA and this involves 7 a weld, we are talkihg about welding at Catawba. Who would 8 be responsible for reviewing it?
9 A. Someone wi'_hin the QA tech support organization.
10 Q. First of all I'm talking about QA now.
11 A. Yes.
12 Q. Procedure problem, I had some people -- identify some 13 people to me by title and name if you know in welding.
14 Who would be assigned the responsibility for handling the 15 R-2A?
16 A. Joe Shopshire would have the final say on it.
17 What is Mr. Shopshire's job?
Q.
18 A. He is the QA Engineer.
19 Would somebody working under him review it first?
Q.
20 A, ye s, 21 Who would that be? Who works under him that would handle Q.
22 the stuff?
23 A. It would be Bill Gillespie, I think at this point in time.
24 What is Mr. Gillespie's job?
Q. -
.1 .
25 A. He is a QA Specialist.
, 65
.~ .
V 1 Q. Anybody hold that position or done that work before 2 Mr. Gillespie after this procedure changed?
3 A. Yes.
d Q. Who was that?
5 A. Rick' Rouse.
6 Q. Same job?
7 A. Yes.
8 Where is Mr. Rouse?
Q.
A. He is in our surveillance group.
10 Transferred?
Q.
II A. Yes.
12 Now, if it were materials or construction problem, it Q.
13 would go to tech support and construction?
Id A. Right.
15 Who would be responsible for its resolution there?
Q.
16 A. Whatever organization went to -- in there, whatever group 17 head is responsible.
18 We are talking Q. Help me understand how that would work.
19 about welding now. Let's say a welder did a bad welding 20 work and it was of such significance that it is written up 21 as an R-2A, who would that go to?
22 A. When you say poor welding work, you have to be more 23 specific.
24 Q. Maybe you can give me an example that- fits because I 25 don't know much a bout welding. I'm just trying to learn.
66
I Help me find -- use an example, if there is one, that is 2 appropriate that would fit the circumstances that you 3 described. An R-2A that gets written up and it involves d workmanship or construction and materials and therefore 5 would go to the construction people. What kind of problem 6 would fall in that category?
7 Any material type problem would go to that area.
A.
8 Give me an example of a workmanship type problem in Q.
9 welding that would follow that route if there is any?
10 Can you give an example?
" A. I don't know of one off hand.
12 How about excessive perosity?
Q.
13 That probably wouldn't be handled as an R-2A.
. A.
Id Q. How would that be handled?
15 In process control.
A.
16 And re-work?
Q.
17 l A. Yes.
18 Q. Sign off ag,ain?
l' Sign off period.
i A. No, not sign off again.
20 Q. Reject the first time around and accept the second time 21 around if it's done right?
l 22 A. Approximately.
23 Let's say the weld is a poor weld. Let's say that it is Q.
24 not -- it's not long enough according to the specifications 25 for that particular piece of work. W' o uld that be an R-2A?
- 67
O *
" I A. No.
2 Q. How would that be handled?
3 A. Correct it. Make it right, fix it.
d Thatwould be process control?
Q.
5 A. That is withholding signature from the process control.
6 Q. Let's say that it's two pieces of pipe that are not 7
aligned properly according to specification.
8 A. Fix it.
9 Q. Not R-2A?
H3 A. No.
11 Q. Not an NCI?
12 A. No.
13 How about just not enough weld material in the joint?
7 Q.
\
Id A. Fix it.
15 Same answer?
Q..
16 A. Yes.
17 Q. No documentation?
18 A. No.
19 Q.. Let's say they use the wrong welding rods.
20 A. NCI.
21 Q. Give me an example of the circumstances where the wrong 22 welding rods would produce an NCI?
23 A. You gave' me the example.
24
~
Q. I mean how would that occur? I'm not saying it has 25 occurred or would occur. Give me an example if it's plausible 68
" I example, give me an example of how wrong welding rods could 2 be used if you know?
3 A. It doesn't happen. I don't know of it happening off the d top. If that were a problem identified in the weld, it 5 would be written up as an NCI.
6 Let's say that different kinds of welding rods used for Q.
7 different kinds of welds, different kinds of material?
8 A. Yes.
4 Q. Let's say the wrong kind of welding rod issued for a 10 weld that needs to be performed. It's an error. That could 11 I'm not asking you to say it has or happen, couldn't it.
12 will or likely or unlikely will. I'm sayin as an example 13 that could happen, couldn't it?
.( Id A. The wrong rod was issued for that weld?
15 Yes, sir, for the type material. f or the type weld.
Q.
16 A. Okay.
37 Not according to specification. There are different Q.
18 kinds of welding rods used in dif ferent kinds of jobs, right?
19 A. Righ t.
20 Someone mixed them up. The welder welded with it.
Q.
21 A. NCI.
22 Q. It becomes an NCI, not an R-2A?
23 g, go, 24 Q. Why not an R-2A? -
.25 A. Because that's something that has been completed.
69
~ - .
.[
' 1 You violated the material requirements. We are going to 2 go back and fix it. We are going to cut out the weld.
'3 Q. Let's say that the inspector finds that while it's in
~
d progress. The we1d hasn't been done yet, but walks up and 5 the welder is working on it and the welding inspector notes 6 that the wrong kind of welding rod is being used. What 7 happens then?
8 A. If it's in process inspection, it's going to be an R-2A.
9 Q. It would be an R-2A? -
10 A. If it's an in process inspection.
11 Q. If that's an example, a welding inspector writes it up 12 as an R-2A. Does work stop?
- 13 A. Yes.
14 Q. Checks with his tech supervisor, a number gets issued for 15 the R-2A and logged in and then who reviews that example 16 for resolution?
17 A. The welding tech support.
18 Q. Who would that be?
19 A. Tom Robinson's group.
20 What is his job?
Q..
21 A. He is civil welding construction engineer.
22 Q. Is there anybody that works under Mr. Robinson who would 23 be responsibie for handling an R-2A that came up that way?
24 A. Several people.
25 Their names?
Q.
70
1 A. Bill Sams would be one of them. Jim Kinnard, Terry 2 Huffstetler. I think that's the primary ones.
3 Q. What are their jobs?
4 A. They are on the staff of welding tech support.
5 Q. In the welding area?
6 A, yes, 7
Q. They have been in that position since the time this pro-8 cedure changed?
9 A. I don't know.
30 Q. You j u st don' t know?
11 A. No.
12 Q. How about Mr. Robinson. He has been there?
13 A. Right.
T' Id Q. Mr. Allum, are you f amiliar with the requirements of 15 10CFR Part 50 Appendix B?
16 A. Yes.
17 Q. Quality Assurance Criteria?
18 A. Yes.
I' O. Your lawyer has a copy of it for you. Look at page 457 20 of my version of the Bible here. I direct your attention to 21 Criterion 16, corrective action. Wbuld you take a look at I
22 that and refresh your recollection i 23 MR. McGARRY: L>st the record reflect that we are 24 looking at dif ferent editions here. You perhaps have the 25
'83 edition.
e 71
'b' 1 Q. The fir st time that I have a more up-to-date copy of 2 anything the company does. I think the text is identical.
3 It's probably on a different page, but why don't you check 4 it. The corrective action criteria.
5 SHORT RECESS (4:00 p.m.)
o CONTINUING EXM4INATION: (By Mr. Guild) (4 :10 p.m. )
7- Q. Mr. Allum, are you f amiliar with the provisions of t hat l
8 criteria with respect to that corrective action?
9 A. Yes, sir.
10 Q. I want to understand in the circumstances where af ter 11 the procedures have changed we have talked about here, 12 the circumstances where construction deficiencies are 13 handled not through procedure issuing an R-2A and not
,3 Id through Q-1 issuance of NCI, but through means of process is controll. Tell me in the welding area at Catawba how 36 effective corrective action is taken and the causes of those 17 deficiencies, the route causes of those deficiencies identi-18 fled.
l' A. I'm not sure I understand your question.
20 Q. Help me. Tell me what you do not understand.
21 MR'. McG ARRY: Are you interested in now exploring
. 22 process control?
23 g, yem interested in trying to have the witness answer that 24 question. ,,
25 MR . M cG ARRY : I'm confused by that question, and
- 72
{
't 1 I think the witness is. If you could just repeat the 2 question.
3 Q. You told me that a number of things that formerly were in 4 the welding area that used to result in NCI's now are handled 5 through means of process control, is that true?
6 A. This is true.
7 Where welding inspector would initiate an NCI in the
. Q.
8 past, he now is authorized under procedure to have the craf t 9 rework the weld, one example, and reinspect and accept, if 10 acceptable, as a matter of process control?
11 A. Yes. sir.
12 Q. I want to understand how items construction deficiencies 13 that are handled through the process control devise that
(_ 14 you have described or how the root cause of those deficiencies 15 are identified and how effective corrective action is taken 16 in compliance with that quality assurance critera, that 17 being 16, corrective action.
18 A. Criterion 16 is items are identified on an NCI and there-19 fore are taken care of in the non-conformance situation and 20 in that process.
21 That only relates to NCI's in your opinion?
Q.
22 A. Rig ht.
23 Does not relate to R-2A's?
Q.
24 A. No. :.
25 Or to deficiencies that are identified and resolved Q.
73 f
I 1 through process control?
2 A. Right.
3 Q. Where do you get that understanding, Mr. Allum? Is 4 that Duke policy at Catawha as you understand it?
5 A. I have never seen a policy that says reading corrective 6 action in criterion 16. 10CFR 50 implies that to me.
7 Q. It does?
8 A. Yes.
9 Q. Were you trained in that policy by Duke Power Company?
10 A. Yes, sir.
11 Q. That is consistent with your training as you understand 12 it?
13 A. Yes, s ir .
14 Q. Let me ask you as an example, Mr. Allum, 'if significant 15 construction deficiencies occurred in welding and, let's 16 say, the root ccuse of those construction deficiencies in 17 welding is due to a lack of training of welders doing bad is welds because they weren't trained right. All of the welds 19
! that were done bad were noted by welding inspectors and i 20 corrected through process control. That's possible, isn't 21 j it. I'm goi~ng to ask you to accept all the rest of that --
22 A. I'm not sure I follow your train of --
23 g, we lding inspectors note bad welds, and they see that the 24 welds are corrected through process control'. .~.
25 A. Right.
, 74
.. .s k 1 Q. They don't write up an R02A or NCI.
2 A. They do occasionally if it f alls in the proper category.
3 Q. I'm asking you to take the situation where I understood 4 you to say that the weld isn't done right -- it's too short.
5 A. Yes.
6 Q. Not enough fill?
7 A. Right.
8 Q. So, those two examples, it's corrected in process.
9 A. Right.
10 Q. Accepted after it's inspected and found acceptable.
11 A. Right.
12 Q. But, die problem did occur the first time the welding 13 inspector looked at the work, right?
'/
14 A. True.
15 Q. I'm asking you to accept hypothetically that the route 16 cause of that problem was a lack of training of the welders.
17 They just didn't put enough fill or running the welds long 18 enough according to specifications, and what I want to 19 understand, Mr. Allum, is how the pattern of recurring problems 20 whose cause was as I just described would be documented and 21 therefore identified .and therefore allow appropriate correc-22 tive action to be taken in the circumstance where no NCI or
- 23 R-2A's were written up.
24 A. Appropriate corrective action is taken with-an acceptable 25 weld.
, 75
$ 1 Q. I want to show you a document. This is a list which 2 includes a number of documents that was provided to me by 1
- 3 the company in discovery, Mr. Allum, and the list is 4 entitled, " Handwritten notes from QC and QA Inspectors,"
I 5 which set forth their specific problems and concerns, and 6 it's a list of names, and I want to ask you to identify 7 these people. I believe they are welding inspectors at a Cataw ba . Take a look at the list first and then, if you 9 hand it back to me, I will go through the list and ask you to some questions about those people.
11 A. I know them all.
12 Q. You know them all?
13 A. Yes, sir.
14 0 . These gentlemen are welding inspector s you have been 15 responsible for supervising at Catawba?
16 A. Yes.
17 Q. Do you know Dean Bentley?
18 A. Yes.
19 Q. Is he a welding inspector at Catawba?
20 A. Yes, sir.
1 21 Q. He has been for some time?
22 A. Yes, sir.
23 Q. What is ' your opinion of Mr. Bentley's work?
24 A. Good inspector. n 25 Q. How ha s Mr . Bentley been evaluated?
76
, - ,-----n-.- , ,-..,-m, , , - , , - - . -- , ,- ,
t 1
A. Evaluated how?
2 Q. I mean has he been evaluated as competent?
3 A. Yes, sir.
4 Q. Better than- competent?
5 A. We don't have a competent, better than competent evalua-6 tion system.
7 Q. You have a rating of competent?
8 A. We have.
9 Help me understand what the rating is?
Q.
10 A. We have satisfactory or unsatisfactory evaluation.
11 Q. Has Mr. Bentley been rated satisfactory?
12 A. Yes.
13 Never unsatisfactory?
Q.
Id A. Not that I know of.
15 Are you aware of any criticism of Mr. Bentley?
Q.
16 A. What kind of criticism?
17 Any criticism.
Q.
18 A. Of what?
19 Mr. Bentley?
Q.
20 A. No.
21 Are you aware of any adverse action against Mr. Bentley?
Q.
22 A. No.
23 Do you know T. A. Gardner?
Q.
I4 A. Yes, sir. - ~
25 Is Mr. Gardner a welding inspector?
Q.
77
, e 1
A. Ye s , s ir .
2 Q. He has been there for some time?
3 A. Yes, sir.
4 What is your opinion of Mr. Gardner's work?
Q.
5 A. A good inspector.
6 Q. Mr. Gardner's rating evaluation?
7 A. Satisfactory.
8 Ever less than satisfactory?
Q.
9 A. Not that I know of.
10 Q. You aware of any criticism of Mr. Gardner?
11 A. I have a problem when you say criticism. Your definition; 12 where is the criticism coming from?
13 I want to understand. I want to ask the question, and Q.
Id if I can, Mr. Allum, in a way that you can tell me what you 15 understand as criticism if there is any. If you know of 16 any, tell me.
37 I don't know of any criticism.
A.
18 Are you aware of any adverse action against that gentle-Q.
19 man?
20 No.
A.
21 Q. Mr. William H. Burr.
22 A. Yes, sir.
23 Mr. Burr 'a welding inspector?
Q.
24 ~-
A.
~
Yes.
25 Q. Been there for a while?
78
T. 1 A. Yes, sir.
2 Q. What is your opinion of Mr. Burr ?
3 A. He is a good inspector.
4 Q. Ho w ta s Mr. Burr been rated, evaluated?
5 A. Satisfactory.
6 Q. Ever heard of any criticism of Mr. Bu rr ?
7 A. No.
8 Q. Mr. Boyce Kaufman.
9 A. Yes.
10 Q. An inspector at Catawba?
11 A. Yes.
12 Q. Been there for some time?
13 A. Yes, sir.
[ 14 Your opinion of his work?
Q.
15 A. He is a good inspector, lo Evaluation?
Q.
17 A. Good, satisfactory.
18 You are not aware of any criticism of Mr. Kaufman?
Q.
19 A. No.
20 Q. Any adverse action against him, are you aware of any?
21 A. No.
22 Q. C. D. Cr isp .
23 A. Yes, 24 Inspector at Catawba?
j Q. -
25 A, yes,
, 79 l
l
l Q. Been there for some tine?
2 A. Yes.
3 Q .' Your opinion of his work?
d A. Good.
5 Q. His evaluation?
6 A. Good, satisfactory.
7 You aware of any criticism of Mr. Crisp?
Q.
8 A. No.
9 Any adverse action against him?
Q.
10 A. No.
11 Q. B. Deaton?
12 g, ye s, 13 He has been an inspector for some time there?
Q.
14 A. He is a supervisor.
15 He is a supervisor?
Q.
16 A. Yes.
17 Q. Has he been a supervisor for some time?
18 A. Yes, sir.
19 Q. What is Mr. Deaton's position?
20 He is a welding inspector " supervisor or supervising tech-A.
21 nician.
22 Has he served as a welding inspector befor e?
Q.
23 A. Yes.
24 I'm sorry, the position is -- - "
Q.
25
.A. Supervising technician.
80 4
9
1 Q. When did he become a supervising technician?
2 A. I don't know.
3 Q. Was he a welding inspector when you came -- when you 4 took over the rerponsibility of supervising welding inspec-5 tors?
6 A. No , he was a supervisor.
7 Q. Your opinion of Mr. Deaton's work.
8 A. Good.
9 Q. His evaluation?
10 A. Satisfactory.
11 Q. Any criticism you know of Mr. Deaton?
12 A. No.
13 Q. Any adverse action against him?
14 A. No.
15 Q. Harold Eubanks.
16 A. Yes.
17 Q. Been an inspector for a while?
18 A. Yes.
19 Q. Your opinion of his work.
20 A. Good.
21 Q. Evaluation?
22 A. Satisfactory.
23 Q. Any criticism you are aware of?
24 A. No. ..
25 Q. Any adverse action against him?
, 81
! 1 A. No.
2 Q. Mr. A. S. Ghant?
3 A. Yes.
4 Q. Has been an inspector for a while?
5 A. Yes.
6 Q. Your opinion of his work?
7 A. Very good.
8 Q. Better than good?
9 A. Good.
10 Q . Same as the rest of the gentlemen you mentioned?
11 A. Yes.
12 His evaluation.
Q.
13 A. Good, satisfactory.
.(- Id Q. Any criticism of that gentleman?
15 A. No.
16 A. Any adverse action you are aware of?
17 A. No. ,
la How about B. C. Godfrey?
Q.
19 A. I know him.
20 Q. Has he been an inspector for some time?
21 A, yes, 22 Your opinion of Mr. Godfrey's work?
Q.
23 A. He is not currently an inspector.
24 What does Mr. Gcdfrey do now?
Q. - -
25 A. He is in welding craf t.
, 82
U 1
Q. He transferred back to welding craft?
2 A. Yes.
3 Q. When did Mr. Godfrey transfer back?
4 A. January,1981, February,1981, somewhere around there.
5 Q. Are you aware of Mr. Godfrey's work?
6 A. No.
7 Q. As a welder?
8 A. Yes.
9 Q. What is your opinion of his work as a welder?
10 A. Strictly opinion, it is good.
11 Q. You are not aware of his work as a welding inspector?
12 A. I had no interface with him as a welding inspector.
13 Q. So, you have no opinion of his work as a welding inspec-i 14 tor?
15 A. No.
16 Q. Do you know what evaluation Mr. Godfrey had as either 17 a welder or welding inspector?
18 A. Satisfactory as a welding inspector. I don't know about 19 his welding.
20 Q. Are you aware of any criticism of Mr. Godfrey as a 21 welder or-welding inspector?
22 A. No.
23 Q. Any adverse action against Mr. Godfrey?
24 A. No. -
25 Q. How about Larry Jackson?
83
Ib 1 A. Yes.
2 Q. Is he a welding inspector?
3 A. Yes.
4 Been there for a while?
Q.
5 A. Yes.
6 Q. Your opinion of Mr. Jackson's work?
7 A. Good.
8 Q. His evaluation?
9 A. Satisfactory.
10 Any criticism you are aware of Mr. Jackson?
Q.
11 A. No.
12 Any adverse action against him?
Q.
13 A. No.
14 Q. Richard Jones.
15 A. Yes.
16 He has been an inspector for a while?
Q.
17 A. Yes.
18 Your opinion of his work?
Q.
19 Good.
A.
20 Any evaluation of him?
Q.
21 A. Satisfactory.
22 Any criticism you are aware of?
Q.
23 A. No.
24 Any adverse action against him?
Q. .
f.
25 A. No.
, 84 w-- , - -- , . . - . ,._y - , - -- ,.e= w. -e-
[ 1 Q. Kenneth Carriker?
2 A. Yes.
3 Q. . He has been a welding inspector for some time?
4 A. Yes.
5 Q. Your opinion of his work?
6 A. I haven't had a lot of interf ace with him, but as far as 7 I know it's good.
8 Q. Why not Mr. Carriker?
9 A. He was not in my organization long and transferred to 10 another crew and at a later time and I had him for about 11 eight months, I guess. His performance was good at that 12 time.
13 Q. Were did Mr. Carriker transfer to?
i 14 A. He is still in welding inspection, but he is in another 15 area.
16 Q. Why not under your supervision?
17 A. Because I no longer had Bill Deaton as a supervisor under 18 me.
19 Q. So, this crew were people under you and under Deaton.
20 A. Rig ht , every one mentioned so f ar has been in Beau Ross' 21 group except Carriker.
22 Q. Mr. Carriker was not under Beau Ross' crew?
23 A. No.
24 Q. During the time you did supnrvise and you knew of his ,
i 25 work, your opinion was good?
g 85 i
- - - - . - - - - - , - , - - - - - - - - . - - - - ~ - - .
t O %
t 1 A. Yes.
2 Q. Mr. Carriker's evaluation?
3 A. Satisfactory.
4 Any criticism of Mr. Carriker you know of?
Q.
5 A. No.
6 Any adverse action against him?
Q.
7 A. No.
8 Q. Ronald Kirkland?
9 A. Good.
10 He has been a welding inspector for some time?
Q.
11 A. Yes.
12 Satisfactory evaluation?
Q.
13 A. Yes.
\ id Q. Any criticism?
15 A. No.
16 Any adverse action you know of?
Q.
37 A. No.
la Q. John McCoy?
39 A. Yes.
20 He has been around as an inspector for a while?
Q.
21 A. Yes.
22 What is your opinion of him?
Q.
23 Good.
A.
24 Q. His evaluation? -
25 Satisfactory.
A.
, 86
. o N 1 Q. Any criticism?
2 A. No.
3 Q. Any adverse action you know of?
d A. No.
5 Q. John Rockholt.
6 A. Yes.
7 Q. Been an inspector for some time?
8 A. Yes.
9 Your opinion of his work?
Q.
10 A. Satisfactory.
11 His evaluation?
Q.
12 A. Satisfactory.
13 Q. Would you evaluate his work as good?
(
14 A. Yes.
15 You hesitate. Do you weigh Mr. Rockholt's work any Q.
16 less satisfactory than the others?
17 A. No.
18 His evaluation?
Q.
19 Good, satisfactory.
A.
20 Consistently satisfactory as far as you know?
Q.
21 A. Yes.
22 Any criticism you are aware of Mr. Rockholt?
Q.
23 A. No.
24 Q. Any adverse action against Mr. Rockholt? .H.'
25 A. No.
87
6[ < '
- 1 A. No.
2 Ransom Sims?
Q.
3 A, yes, d Been an inspector for a while?
Q.
5 A. Yes.
6 Your opinion of his work?
Q.
7 A. Good.
8 Q. His evaluation?
9 A. Satisfactory.
ic Q. Any criticism you know of?
11 A. No.
12 Q. Any adverse action against Mr. Sims?
13 A. No.
~I
'- Id Mickey Standridge?
Q.
15 A. Yes.
16 Q. Been an inspector for a while?
17 A. Yes.
is Q. Your opinion of his work.
19 A. Good.
20 Q. His evaluation?
21 A. Good satisfactory.
22 Q. Any criticism?
23 g, 30, 24 Q. Any adverse action? .,
25 A. No.
, 88
-.. e i
1 Q. Lindsey Hovis?
2 A. Lindsey Harris?
3 Q. It says Hovis. Would that be Harris?
4 A. Yes.
5 Q. How about Mr. Harris, has he been an inspector?
6 A. Yes.
7 Q. Your opinion as to his work.
8 A. Good.
9 Q. His evaluation?
10 .A. Satisfactory.
11 Q. Any criticism of Mr. Harris?
12 A. No.
13 Q. Any adverse action against him you are aware of?
14 A. No.
, 15 Q. Beau Ross.
16 A. Y)es .
17 Mr. Ross been a supervisor for some time?
Q.
18 A. Yes.
19 Q. Your opinion of Mr. Ross' work?'
20 A. Marginal.
21 Marginal?
Q.
22 A. Yes.
23 Less than good?
Q.
24 g, yes, -
f.,
25 What is the basis for your opinion of Mr. Ross' work as Q.
. 89
. . - = . -- . . .
~
t -.
I t
7'
- 1 less than good?
2 A. Failure to communicate with his people.
3 Q. Tell me what you mean by t hat. By his people, do you i d mean the people who he supervises or on the list down here?
5 A. Yes.
6 Q. .What do you mean by failure to communicate with those 7 people?
a A. He wasn't carrying the information he gave chem on what 9 was told to him.
10 Q. He didn't communicate from his supervision effectively 11 to them?
12 A. Rig ht.
13 Q. By that you mean from you to them?
( 1d A. -In some cases, yes.
15 You were his supervisor?
Q.
16 A. Yes.
17 What cases do you mean he failed to do that?
Q.
18 A. Various interpretation changes when we would request a 19 change where we were doing business organization-wise and do 20 it this way, that way, the other way. It was not affectively 21 communicated to his people.
22 Can you be specific about what you mean?
Q.
23 A. I don't believe that some of the personnel policies 24 were affectively communicated to his people so;;that they had l 25 the understanding of what they should have had.
, 90
( .
1 Q. What parsonnel policies do you mean?
2 A. Transfer policies, things of that nature.
3 Q. I'm asking if you would be as specific as you can. What 4 are you talking about transfer policies?
5 A. e W'll, what the basis are for approving transfers and what 6 the criteria are and things of that nature.
7 Q. Speaking of transfers of welding inspection to the craf t?
8 A. Not particular welding inspection. Inspection to site 9 representative.
10 0 What does that reference mean? What specific factual 11 setting are you talking about? What does Mr. Ross do that 12 you think is wrong?
13 A. His people felt the transfer policy was not communicated 14 to them properly as it applied. They had many questions 15 on it. That he either evidentally couldn't answer or couldn't 16 support, didn't feel comfortable with.
17 Q. Transfer as applied to who?
18 A. His people.
19 They wanted some kind of -- they wanted a transfer. They Q.
20 were interested in a transfer?
l 21 A. They would like to go to operations area of QA or basicall: r 22 that's where they wanted to go, different sites.
23 Q. When did this failure on Mr. Ross' part in your opinion 24 occur? -
25 A. I guess the last time we had a transfer policy change or 91 f
__c . _
' ~
a . .
I the last six months, I guess.
2 Q. Within the last six months?
3 A. Yes.
4 Q. Do you have any basis, do you have an opinion as to Mr.
5 Ross' work in the period of time from before this recent 6 experience, before the last six months, earlier than that?
7 If so, what is it? What was his work -- what's your opinion a of Mr. . Ross' work before this instance?
9 A. He is a supervisor and does a good job of supervising 10 people, getting them to the right place at the right time, 11 and getting the work done. He is affective in that area.
12 Q. It's good?
13 A. .Yes.
k 14 This is the instance in which you think it's less than Q. ,
15 good?
16 A. Yes..
17 It has to do with transfer from construction QC to Q.
la operational .QC within the last six months?
19 A. Yes.
l 20 Q. Anything else?
21 A. Organization changes.. Putting NDE out of the people 22 that do the welding inspection crews having NDE people in 23 those crews.
24 .Q. What about that?
~
r-25 A. H e didn't like the idea and didn' t support it, I don't 92 l
- ~
3 .
y.
' I believe.
2 Q. That's the business about the new welding inspectors 3
you have drawn from retraining the NDE people, is that
- rig ht?
5 A. Yes.
6 Q. He didn't support retraining the NDE people as visual 7 inspectors?
8
- A. Right.
9 Q. Anything else?
10 A. That is the main ones.
11 Q. Those are the main ones?
12 A. Yes.
13 Q. Are you aware of any other criticism of Mr. Ross?
( 14 A. No.
15 Q. So, are you aware of any adverse action against Mr. Ross?
16 A. No.
17 Q. Are you ware of any criticism of Mr. Ross by Larry 18 Davison?
19 A. No.
20 Have you ever criticized Mr. Ross?
Q.
21 A. I have told him things we needed to improve on. Yes, I 22 have done that.
23 Q. On matters other than the two areas you just tole me about?
24 A, Iem sure there have been. . .-
25 Q. Anything of significance that you know of?
, 93
i: 1 t^ . -~.
1 A. I couldn't give you specifics.
j 2 'Q. In general areas, if it's significant.
'3 A. Personnel matters primarily.
d Q. What sort?
5 MR. McGARRY: I'm going to interpose an objection 6 if it has to do with personnel matters as opposed to quality 7 control and quality assurance at Catawba. I think that's a f air game, but to get into personne.1 matters, I interpose -
9 an objection.
10 Q. I would like Mr. Allum to answer the question. I'm really 11 l not interested primarily of matters of personnel or a person-
- 12 nel nature, but to the extent they ceflect an adverse opinion 13 by Mr. Allum on Mr. Ross' work or Mr. Ross' credibility is id an issue or may be an issue, I would like your witness to answer j 15 the question so I can have as complete a picture as possible.
16 MR. McGARRY:
- To the extent they go to his work, 17 that is a fair question.
18 Q. You can, Mr. Allum, tell me anything else that is a basis l
l' for your opinion you have expressed about Mr. Ross.
20 A. I thought I told him one time I thought he was too 21 critical on his people as f ar as how they get to the gate on 22 time and things of that nature.
23 Q. Pushes them too hard?
24 A. Yes. "-
25 Too particular about small details?
Q.
94 l
- - ,-,.. -.,,- , . , , , , ,-n,.,,-_ . , - , n., , - , , , , , , . - - - , - , , - - , , - - - , , , , , - , , - - - , - . - . . , . . - - - - - . . - - - - , . . .
. o 1
1 A. No.
2 What is your understanding of the opinion of those welding Q.
3 inspectors that M'r. Ross does and has supervised of Mr.
d Ross and his work?
5 g,. Would you repeat that?
6 Q. What do you understand Mr. Ross' people to think about 7
him in his work?
8 I will object to that. I think it's MR. McGARRY:
9 One step I won't about two steps removed from hearsay.
'O object to, but we are getting pretty far-fetched.
Il Q. Wauld you have any reason, Mr. Allum, to disagree with 12 the characterization that the people whom Mr. Ross supervises 13 think highly of him?
Id A. I need you to ask the question again.
15 Q. Sure. Do you know anything to the contrary or do you 16 know any ba sis for thinking otherwise that the welding inspec-17 tors that Mr. Ross supervises think highly of him?
'8 A. Are you asking me do I know that people do not think highly of him?
20 Q. Yes.
21 A. Yes.
22 g, g3g7 23 A. Several on that list.
24 "'
Q. Tell me if you know, please?
25 A. I would say Rick Jones, Rick Moore, Richard Mills, Carl 95
Soussa.
1 2 Q. I don't believe I'm f amiliar with Mr soussa's name.
3 A. You are not.
4 Q. Is he one of the welding inspectors of Mr. Ross?
5 A. Yes.
m o Q. Is he a recent welding inspector to come under Mr. Ross?
7 Recent by comparison to the list of names I have read you 8 so f ar, the last six months.
9 A. Yes.
10 Q. The rest of those people you mentioned as well?
11 A. They worked for him a long time.
12 Q. Mr. Soussa is one of the former NDE in spectors?
13 A. Yes.
14 Any others?
Q.
15 A. John Jolly, Scott GHant, Lindsey Harris. I guess that's 16 about the best I can come up with off the top of my head.
37 Q. What is the basis for your belief that they don't think is hig hly of M r . Ross?
l' i
A. My communications with them.
20 How do you understand that they have that opinion of him?
Q.
21 Have they told you that or have you seen it in writing or 22 just give me an idea of what your source of information is.
23 A. They told me that.
24 Q. Have they ever put that in a written evalu'ation?
25 A. No.
96
1 Q. Ever solicited or are you aware of any written evaluation 2 of Mr. Ross by his people?
3 A. No.
4 Q. Have you ever communicated those opinions to any of your 5 supervision?
6 A. I don't know.
7 You just don't remember?
Q.
8 A. Right.
9 You told Mr. Henry here?
Q.
10 A. No.
11 Q. You ever discuss Mr. Ross with him?
12 A. No.
13 Q. I have one more name on this list and that's J. R. Br yan t.
14 A. Yes.
15 Do you know Mr. Bryant?
Q. -
16 A. Yes.
17 Q. Has h6 been a welding inspector for some time?
18 A. Yes.
19 Q. What is your opinion of his work?
20 A. Good.
21 Q. Mr. Bryant's evaluation?
22 A. Satisfactory.
23 Q. Are you aware of any criticism of him?
A. No.
- 25 Q. Any adverse action against him?
97
T 1 A. No.
2 Q. I'm going to show you a document of several pages in a length and ask if you can identify it. Let's see if we can 4 mark it first. I will identify this as Exhibit Twelve, and 5 we don't need to take too much time with it. Tell me, if 6 you can identify that? Have you ever seen that before. I 7 don't believe there'm. any name attached to it.
8 Q. Mr. Allum, you have had a chance to look at that document?
9 A. Yes.
10 Q. Do you recognize it?
11 A. Have I seen it before?
12 Q. Yes, have you seen it before?
13 A. Yes.
14 Q. Have you -- do you recognize the handwriting?
15 A. Yes.
16 Q. Whose handwriting is that?
17 A. John Bryant.
18 Q. Mr. Bryant one of the velding inspectors?
19 A. Yes, sir.
20 Q. Fir st of all, what is an M-4?
21 A. That's a procedure we deal with.
22 Q. What is it?
23 A. ASME code material, welding material.
24 Q. That specifies how you perform weld.s on AS(IE code?
e
, 25 A. Yes.
'. 98 L . p
L i 1 Q. Are there any other procedures which describe how you 2 do welding on code welding?
3 A. Not on that particular su bject, no.
d O. Are there any others though?
5 A. We have procedures for most anything you want.
6 Q. What is M-4?
7 A. That's ASME code material.
8 Q. Code welding?
9 A. Yes.
10 Q. I guess my question I was trying to understand was are 11 there any other procedures that describe how you to ASME 12 code weldir.g?
13 A. No.
( 14 That 's it, M-4?
Q.
15 A. There's modifiers, but that's it.
16 Sub-yTocedures or related procedures?
Q.
17 A. There's things that work in conjunction with M-4.
18 Mr. Bryant writes some questions and these are question Q.
19 in Mr. Bryant's handwriting and see if you know the answers 20 to any of these. What impact did Mr. Lee have on the wage 21 evaluation? Do you have any understanding or information on 22 that?
23 A, go, 24 Whs his, same question, same paragraph, was his source Q.
25 of information compiled by Jim Wells (QC non-support) ? Do
, 99
p' -.
1 you know?
2 A. No.
3 Q. Larry Davison, same parenthetical (QC non-support) .
4 A. No.
5 Q.. Nas there anyone to offer Mr. Lee the full scope of 6 responsibilities who is QC oriented?
7 A. No.
a Q. Are you aware of the concerns that are reflected in this 9 question?
10 A. Yes.
11 Q. Have you heard those expressed by Mr. Bryant and others 12 before?
13 A. Yes, sir.
k Id Q. Do you know whether those concerns have been -- whether is corrective -- whether those concerns have been addressed 16 and corrective action has been taken?
17 A. What corrective action?
18 Q. Any, if you know of any. Do you know of any?
19 A. I'm not sure I know what the question is. What corrective 20 action?
21 Well, do you know whether those concerns have been l
i Q.
22 addressed ?
23 A. I can' t answer that. I don't understand the question.
24 Q. Well, what about it don't you understand. :-I can rephrase 25 it try again. What I want to know if you have heard those
. 100 l
i 1 - concerns expressed. My question is do you know of any --
2 whether those concerns have been addressed?
3 A. The answer to the question one is I don't know that Bill 4 Lee was addressed with this problem.
5 Q. Say again.
6 A. I don't know that Bill Lee was part of the answer to 7 this question, r.nd number two, if I don't know that, then 8 I don't know the answer to the other ones.
9 Q. You don't know whether those concerns have been addressed 10 or not?
11 A. No.
12 Q. Why was Charles Baldwin removed as 00 W' e lding Supervisor?
13 Is Art Allum, you, qualified to effectively oversee the QC 14 Section program? Why was Beau Ross overlooked for this job 15 position? Should not Larry Davison and Jim Wells also be 16 removed from their positions? That's another little box of 17 que mions. Are you aware of those questions before being 18 asked and those concerns being expressed by Mr. Bryant and 19 others?
20 A. No.
21 Q. Let's take them one at a time. Why was Charles Baldwin 22 removed as QC Welding Supervisor?
23 A. I don't think he was.
24 Q. He wa sn ' t? .
f.,
25 A. He was rotated. We were rotated.
, 101
t*
1 Q. How as his position changed if it wasn't -- if h e 2 wasn ' t r emoved , was it changed?
3 A. We s wapped j obs.
d Q. Yo u and he did?
5 A. Yes.
6 Q. What did Mr. Baldwin do?
7 A. He took over radiography and NDE and receiving inspection, 8 document control.
9 Q. He no longer fulfilled the position of QC Welding Supervisor?
10 A. Right .
11 Q. You did in his place?
12 A. Yes.
13 Q. Do you know the answer to the question of why?
14 A. No. We normally rotate or do rotate.
15 Q. Is art Allum qualified to affective oversee the QC inspec-16 tion program? Your opinion?
17 A. Hell, yes.
18 Q. You aware of that concern being expressed by Mr. Bryant 19 and others?
20 A. No.
21 Q. Your qualification to do that.
22 A. Do they know my qualification?
23 Q. No, are you aware of that concern being expressed before?
24 A. No. _
25 Q. This is the first time you have heard that being expressed?
g 102
~
f 1 A. Yes.
2 Q. Why was Beau Ross overlooked for this job position?
3 A. I don't know.
4 Q. Was Mr. Ross in a position where it would have been the 5 next step in progression for him to have taken the position 6 that you occupy?
7 A. If we were going to promote someone, ha ~ "1d be one of a many choices.
9 Q. I mean he would have been -- the position you hold is lo the position next above the position that he held at the 11 time you came into that job?
12 A. Yes. .
13 Q. .You supervise him directly now?
14 A. I do not.
15 Q. You did until you changed your job?
16 A. Yes.
17 Q. So, do you know why he -- he is one of a few people whose 18 progression would have next taken him into a position you hold?
19 MR. McGARRY,: I believe the witness said no, he was 20 one of several people.
21 Q. Several. Not many, several, is that right?
22 A. Yes, sir.
23 Q. T hen , the question is, why wasn't Mr. Ross promoted into 24 that position? ,
25 A. It was not a promotion made, it was a lateral transfer.
103 l
l l
l
3
.(~ 1 Q. For you?
2 A. Yes.
3 Q. Do you know whether or not Mr.. Ross was considered for 4 that position?
5 A. I don't believe a promotion was being made. No promotion 6 was made.
7 Q. You just don't know whether he was considered or not?
8 Can you say affirmatively he was not considered?
No.
9 A.
10 Q. You just don't know? ,
11 A. It wasn't my job.
12 Q. Are you aware of anyone ever expressing the question or 13 concern why Mr. Ross wasn't put in that position?
(
14 A. No.
15 Q. That's the first time you have heard it expressed in 16 this question?
17 A. Yes, sir.
18 Q. What about the last point. Should not Larry Davison and 19 Jim Wells also be removed from their position?
20 A. I think we have said -- I don't believe that Charles 21 was removed from his position to start with nor do I believe 22 that Larry Davison or Jim Wells should be removed.
23 Q. Are you-aware of anyone expressing that question or those 24 concerns why Mr. Davison and Mr. Wells _ shoulda;not be removed?
25 A. No.
104
- ~ -
i( i Q. Never heard that phrase till now?
2 A. No.
3 Q. Do you know whether or not the concerns expressed in 4 that group of questions there have been addressed?
5 A. No.
6 , Q. Next one is why is construction involved in resolving 7 the QC inspectors concerns and construction caused many of a the concerns? Are you aware of that concern being expressed, 9 that question being expressed?
l in A. No.
ij Q. Never heard that before?
12 A. No.
i3 Q. Do you have an opinion of that question and answer to
!. ja that question?
15 A. I believe that the Task Force was made up of the most 16 qualified people from all areas to do the Work.
17 Q. They included construction people?
is A. Yes, sir.
19 Q. Do you know whether or not that concern has been addressed ?
20 A. No.
21 Q. Why do we have QA procedures in design drawing requir ement;s 22 if construction in QA upper management feel they can verbally 23 override them? Are you aware of that concern being expressed 24 by Mr. Bryant or others?
25 A. No.
105 e
i
6 +
1 Q. Never heard anybody raise the question about verbal over-2 rides of QA procedure?
3 A. No.
d Q. Do construction -- does construction still have the 5 authority to verbally override QA procedures?
6 A. No , never d id .
7 Q. Never did?
8 A. No.
9 Q. How about GA upper management. Do they still have the 10 authority to verbally override QA procedures?
11 A. No.
12 Did they ever?
Q.
13 A. No.
i Id Q. Do ycu know whether or not that concern has been addressed?
15 A. No.
16 Q. What is the significance of a QC welding inspector 's 17 job with Duke Power? Have you ever heard anybody raise 18 that concern by Mr. Bryant or others?
19 A. No. I don' t understand the question, but I never heard 20 it.
21 Nev er heard it?
Q.
22 A. As stated.
23 Q. You don't know whether anyone has ever addressed that 24 concern or whether that concern has been addrNssed?
25 A. I don't know that it is a concern.
106
. ~
l It's my understand and what I read that to say Mr. Allum Q.
2 is -- you know, when we talked about the reclassification of 3 the welding inspector jobs and I have seen documents that rais e d questions concerning whether or not that represented, shall 5 we say, devaluation of the welding inspector function with 6 Duke Power. In that light, do you understand the question?
7 A. No.
8 You never heard anybody raise that concern? These are Q.
9 stated the way this question is posed?
10 I haven't heard that question.
A.
11 Q. Why is it that welding and mechanical technicians are
'2 found to have more responsibility and their services more 13 valuable to Duke than the welding inspectors?
Id I don't know that is true, A.
is Q. You disagree with that?
16 A. What am I agreeing to or disagreeing to?
17 Is that an accurate statement that this raises a ques-Q.
is I mean is there a factual error in the question that tion?
you know of?
20 I don't know that there is any f actual -- anything f actual A.
21 to it. I don't know whether there is a difference or not.
22 Q. Are you aware of that question or concern being raised 23 by Mr. Bryant or othdrs?
24 A. No. .
4 25 Q. Are,you aware of that concern being addressed by Duke
< 107
, Power?
2 A. No.
3 Q. Upper supervision wants QC inspector to perform their 4
jobs in trust for them and disregard the QA procedures and 5 specific design requirements. Are you aware of that concern 6 or question being asked by Mr. Bryant or others?
7 A. No.
8 Q. Aware of that concern being addressed?
9 A. No.
10 Q. I'm going to show you another document which I'm marking 11 as Exhibit Thirteen, and ask if you can identify that.
12 A. Yes, sir.
13 Q. What is that?
14 A. It's a note that I found on my desk one morning from 15 M r . Ro ss . .
16 Q. Has a notation, this is a copy of a note. You got the 17 original, Mr. Allum?
18 A. I don't think so.
19 Q. You got this -- this appears to be the note you got?
l 20 A. Yes.
21 Q. At the bottom is circled, it says, "no reply." The note 22 asks," Art, please. see if you can get me a copy of federal 23 regulations concerning harrassment or intimidation of 24 inspection personnel. I would like to have a . copy of federal 25 regulations concerning treatment of employees who have expressed
, 108
4 b' I concerns about nuclear fabrication. I would like to have 2 a copy of Duke Power's policy conerning above. I would like 3 for you to find out what recourses are available if an employe.e 4 Joes not agree with his evaluation and thinks the evaluation 5 is retaliatory in nature." It has no reply written at the 6 bottom. Did you reply to Mr. Ross?
7 A. Yes.
8 Q. How did you reply to him?
9 A. I verbally replied to him.
10 Q. What did you tell him?
11 A. I told him we did not have a set procedure at that time 12 for addressing appraisals that people felt were unjust or 13 unfair or whatever.
14 Do you have one now?
Q.
15 A. Yes.
16 What is that?
Q.
17 A.. We have a harrassment procedure.
18 Harrassment procedure?
Q.
39
'A. Recourse procedure.
l j 20 Recourse procedure?
Q.
21 A. Yes.
1 22 That recourse procedure was not in existence on June 2, Q.
2: 1982, when this note was written?
24 A. I don't believe so. -
25 Q. You don't know of it, if it was? You told him you didn't
} 109
, w I
i 1 know of one?
2 A. Righ t.
3 Q. What about his request with regard to federal regula-d tions regarding harrassment or intimidation of inspection 5 personnel?
6 A. I brought him that information.
7 You provided him that information?
Q.
8 A. Yes.
9 Q. What did you provide him?
10 A. I told him we had 10 CFR 51. We had the regional charts 11 that show what various regions are in our jurisdiction, 12 aid there's a statement on there concerning harrassment 13 or retaliation.
14 Q. Is that Form Four?
15 A. I think it is.
16 Is it posted on the bulletin board or some place?
Q.
17 A. Yes, sir.
is Q. Where is that?
I 19- A. In all of the inspection areas throughout the job, 20 several areas.
21 Several?
Q.
22 A. Uh huh.
23 On a bulletin board?
Q.
24 A. Yes. -
. r.
l 25 Q. That's what you told him to look at the poster?
110 t
o ~-
P I
A. That and another docdment that was a letter that was 2
written by Mr. Bob Dick saying that what the construction 3
policy was with regard to people who had concerns about qualit:7 d
Q. Did you give him a copy of that letter?
5 A. Yes, sir. I showed it to him. I didn't give him a copy.
6 It was on the bulletin board.
7 Q. It 's posted as well?
8 A. Yes, sir.
Q. That's about persons that have concerns about work?
IO A. Yes, sir.
Il Q. Safety on the nuclear job?
12 A. Yes, sir.
'3 Q. Couns41, maybe you can help. Has that been identified and produced in discovery, do you know?
15 MR. McGARRY: I don't know.
Q. Do you have a copy of that letter with you, Mr. Allum?
A. No, sir.
18 Q. Counsel, we request that a copy of that letter be made available.
20 MR. McGARRY: I don't have a copy of it now.
21 Q. Perhaps'your people could help make it available.
22 MR. McGARRY: We don't have that. Our recollection 23 is that you did not request such information in discovery and 24 the information that we have just reviewed ~is . discovery infor-25 mation.
i 111
~
.< w
! A 1 Q. My recollection, counsel, is that I asked for policies 2 that would cover any such -- I mean what I understood the 3 witness' description of the letter to be, and that is recourse 4 for complaints about safety in construction. Be that as it s
5 may, we ask that you make that available. I don' t want to 6 prolong Mr. Allum's deposition. I certainly would like to I 7 be a ble to ask Mr. Dick about it and perhaps between now and 8 then, it could be produced. I would appreciate it. Mr. Allum, 9 has there been any further notice from either Duke Power 10 Company or the Nuclear Regulatory Commission concerning the 11 protections available under federal regulations for persons 12 complaining about possible safety concerns at Catawba?
13 A. At Catawba, no.
14 Q. You are not aware of any new notice or letters from Duke 15 Power that have been posted?
16 A. No.
17 Q. Nbuld you know if such a notice had been posted recently 18 at Catawba?
l 19 A. I would pro ba bly get a copy of it. Most likely, I.would.
20 Q. You haven't gotten a copy of any such thing?
21 A. Not that I can recall.
- 22 Q. Mr. Allum, thank you very much. I asspreciate you being 23 present and that's all the questions I have for you, sir.
24 25 A. E. ALLUM 112 h
y- . ,,r, c,-- w, an-,- .,.nr v. . - , - + ,- - , , , . n,- ,, .,.,,me---,, - - - . ,,,-,.we,,, -.--,-m,, -e . - , ,
~
1 STATE OF NORTH CAROLINA )
) CERTIFICATE 7 COUNTY OF MECKLENBURG )
3 4
5 I, the undersigned Commissioner and Notary Public, 6
in and for the State of North Carolina, do hereby certify 7
that A. E. Allum was duly sworn prior to the taking of a
his deposition.
9 I do further certify that the foregoing one hundred and 10 twelve pages constitute a true and a,ccurate transcript of M the evidence given by the said kitness as taken down and 12 transcribed by me.
13 This theeleventh day of July,1983.
14 15 BARBARA V. HAAS 16 Commissioner and Notary Public 7
My Commission Expires:
8 April 23, 1987 l
l l 20 j 21 i
i 22 l
23 24 '.
j_ 25 l
l 113 l
t
,A O
, ~ .
I' 1 INDEX 2
3 Exhibit Twelve Page 98; Line 4 4 Exhibit Thirteen Page 108; Line 11 5
6 DIRECT EXAMINATION 7 By Mr. Guild Page 2; Line 2 8
9 10 11 12 1
13 15 16 17 18 i
19 20 21 ,
22 23 24 :-
25 114
=_