ML20078L748
| ML20078L748 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 06/29/1983 |
| From: | Baldwin C DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20078L617 | List: |
| References | |
| FOIA-83-434 NUDOCS 8310240057 | |
| Download: ML20078L748 (191) | |
Text
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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)
)
e, m ",/7 I, Barbara V. Haas, Commissioner and Notary Public, proceeded to take the deposition of C.
R.
Baldwin on the twenty-ninth day of June, 1983, beginning at 4:40 o' clock a
P.M. in the offices of Duke Power Company, South Church Street, Charlotte, North Carolina.
DEPOSITION OF C.
R.
BALDWIN Associetec 4401CO!Wickkd p o s. m..,
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1 C. R. BALDWIN,.being first duly sworn, testified as follows:
2 EXAMINATION:
(By Mr. Guild) 3 Q. ' Mr. Baldwin, would you state your full' name and your work d
address for the record, please?
5 A.
Charles Raymond Baldwin, Post Office Box 223, Clover 6
7 Q.
You work for Duke Power Company, Mr. Baldwin?
8 A. Yes, I do.
~9 O'.
You are assigned to the Catawba Nuclear Station?
10 A,
- yes, 11 Q.
Mr. Baldwin, my name is Robert Guild, and I'm counsel 12 for Palmetto Alliance, intervenor in the Catawba operating 13 license case.
Are you generally aware-that we have raised Id a question concerning quality assurance in construction at 15 Catawba?
16 A.
Yes.
17 Q.
EWfore we proceed, perhaps we can ask the record to 18 identify other people present.
To my left is Billy Garde, l'
Government Accountability Project who is working with us on 20 the case.
To my right, Michael Lowe, director of Palmetto 21 Alliance and Philip Jos of Palmetto Alliance.
22 MR. JOHNSON:
I'm George Johnson.
I'm counsel for 23 the staff of the Nuclear Regulatory Commission.
24 MS. CODDINGHAM:
Anne Coddingham for Duke Power 25 Company.
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2
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1 MR. HENRY:
Wayne Henry, Quality Assurance Depart-2 ment, Duke Power Company, 3
MR. MCGARRY:
Michael McGarry, counsel for. appli-d cant.
5 Q. Mr. Laldwin, I want to show you a document that quotes o
contention Six that Palmetto Alliance filed in the licensing 7
case, and ask you to take a moment and review that, sir, 8
so I can ask you some questions on that subject.
It's a 9
December 31, 1982, response by Duke to Palmetto Alliance lo questions and discovery.
Beginning at the bottom of page 11 three and on to page 4, there is an indented text, and if 12 you will take a few. moments to review that.
Have you had 13 a change to look at that?
i 14 A.
Yes.
15 Q. Have you seen that before?
16 A.
No, I haven't.
17 Q.
Mr. Baldwin, I'm going to be asking you a series of 18 questions and pro bably not get much further this afternoon 19 since we are going to break at five, but it's going to be on 20 the subject of that contention that relates to quality assur-21 ance at Catawba and particularly with reference to work in 22 the welding area.
As I ask you these questions, if I confuse 23 you in my question or you don't understand the way I have 24 asked it or a term I may juse, please stop me and ask me to 25 be clearer or rephrase the question, and.I will try to do 3
t
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1 that.
I'm trying to obtain some information in discovery 2
to prepare our case on this subject, and I would like your 3
answers to be as complete and accurate as I can.
If you 4
don't stop me and ask for clarification, the transcript that 5
will later be prepared will simply reflect the question as 6
asked and your answer and I will just presume you were answer-7 ing, understanding the question.
What job do you hold right 8
now at Cataw ba, sir?
9 A.
I'm the technical supervisor.
10 Q.
In what department, sir?
11 A.
In welding inspection and non-destructive testing.
12 Q.
How long have you held that position?
13 A.
Approximately five years.
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14 Q.
Also had that title?
15 A.
No, I was supervising technician prior to that.
16 0.
In what department?
17 A.
In the QC/QA Department.
la Q.
When did you hold that position?
l 19 A.
I think from '75 until I was promoted to technical 20 supervisor.
I don' t r emember the specific dates.
Approximately 21 four years, I think.
l 22 Q.
Until about a year ago, you held that earlier position?
l l
23 A.
No, I have been technical supervisor for about five years.
24 Q.
I see.
When did you start the previous position, and 25 when did you get promoted the best you recall?
i 4
j a
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{
1 A.
I was promoted to supervisor, I think, in '75.
No, 2
excuse me.
I'm not sure about the date.
I was supervisor, 3
first line supervisor which is classified -- the title is d
supervising technician for about three years, and I have been 5
technical supervisor for a bout five or six years.
I'm really 6
not sure.
7 Q.
When did you first go to work at the Catawba site?
8 A.
1975.
9 Q.
Have you been there essentially since they began construc-10 tion?
11 A.
Essentially.
12 Q. The first position you were in was the supervising techni-13 cian position?
14 A.
Yes, for a short period of time at the beginning of the 15 job.
16 Q. Then what?
17 A.
Then I was promoted to technical supervisor.
18 Q. The job you hold now?
19 A.
Yes.
20 Q.
To whom do you report now, Mr. Baldwin?
Who is your boss 21 now?
22 A.
I have to think.
I have had so many bosses.
I'm now 23 wor king for Jerry Goodman.
I will be at the beginning or 24 the fir st of the month.
25 Q.
Let's understand this.
As of the first of July?
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5 i
b l-1
l 1
A.
Yes.
Presently, I'm working for Joe Willis.
'2 Q.
This is not changing in jobs for you, but a change in 3
jobs for one of them, I take it?
4 A.
Yes.
5 Q.
What i s Mr. Willis ' title now?
6 A.
I'm not sure.
He was promoted to the operations QA 7
Department section.
8 Q.
He was switched over?
9 A.
His title'now?
10 g,
- yes, 11 A.
He is the inspection superintendent at the Catawba site.
12 Q.
Is that the job title Mr. Goodman is going to have as of 13 the first of July?
\\
Id A.
Yes.
15 O.
You work directly under the Inspection Department?
16 A,
- yeg, 17 Q.
When you held the position before that, the supervising 18 technician, who did you work for then?
I-19 l
A.
I worked for Larry Davison.
20 Q.
What was Mr. Davison's position then?
21 A.
Then, he was a Senior QC Engineer, Senior Quality Control l
22 Engineer.
23 Q.
Now, where is Mr. Davison in relation to you, sir?
What 24 is his relationship to you in your work if any?
l 25 A.
He is the Senior QA Engineer, I believe is his title now.
l 6
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l l
l l
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i Q.
How about QA Manager Projects?
2 A.
That sounds rig ht.
3 Q.
Do you see Mr. Davison in your work or how do you relate to him in your work now if at all?
4 A.
I don't relate directly to him, through the Inspection 5
6 Superintendent.
7 Q.
Who reports to you now, Mr. Baldwin?
e A.
I have three supervisors reporting directly to me.
9 Q.
Who are they?
What are their titles?
10 A.
They are called Supervising Technicians.
ii Q.
Who are they, sir?
12 A.
Dennis Cabe.
13 Q.
Spell that last name?
I 14 A.
C -A - B-E.
15 Q.
All right, sir.
16 A.
Stanley Ledford and Bill Deaton.
1.7 Q.
Do they in turn of employees who report to them?
18 A.
Yes, they do.
pp Q. Khat is the job title of the persons that report to them?
20 A.
They are inspectors.
21 Q.
Welding inspectors?
22 A.
Welding inspectors, radiographers, NDE inspectors.
23 Q.
What is your position relative to that of Mr. Art Allum?
24 A.
Well, at this point in time, he is --
25 Q.
He has made a recent job change?
7
(
1 A.
Yes, but prior to that, he and I were on equal levels.
2 Q.
And, now?
3 A.
Still equal levels, but another area.
Before, he was 4
responsible for part of the welding inspection group, and 5
I also had part of that responsibility.
6 Q.
Both of you reported to the Superintendent?
7 A.
Yes.
8 Q.
How is your area of responsibility changed since the quality control inspection function was reorganized in Fe bru-9 10 ary of '82?
11 A.
I don't remember the reorganization in February.
Will 12 you please explain that?
13 Q. Are you aware that quality control inspectors formerly 1
14 reported to construction for administrative pucposes?
15 A.
Yes, sir, you are talking about the change in responsi-16 bility of the QA Department on their reporting?
17 Q.
Yes.
18 A.
It really hasn't changed as a result of that as far as 19 no change that I'm aware of.
20 MR. McGARRY:
Just to clarify the record, I believe 21 you said ' 82, and it s hould be '81.
22 Q.
I'm sorry, ' 81, i s what I mean t.
Are you aware of the re-23 classification of the position of welding inspector in July 24 of '82, I believe that's the right date?
25 A.
Reclassification of the position of welding inspector?
(
I 1
Q.
Yes.
2 Q.
Would you please explain what you mean by that?
3 A.
Do you understand that there was a re-evaluation of the job description of inspectors including welding inspectors?
4 5
A.
Yes.
6 Q.
And, that there was a reclassification for at least pay 7
purposes and also a change in the qualification requirements 8
for welding inspector in about July of '82?
9 A.
I'm aware of a reevaluation of welding inspector's pay.
10 Q.
Are you aware of the change in the qualification require-11 ments for the position of welding inspector?
12 A.
Yes, there was a procedural change.
I wasn't sure it 13 ahppened at the same time the pay issue came out as far as s
the qualification requirement.
14 is Q.
Yes, are you aware of a change in the qualification requirc 16 ment to expressly remove the customary qualification of 17 requiring two years welding experience for a welding inspector 2 18 A.
The procedure was revised so that' welding experience was 19 no longer a requirement for a welding inspector.
20 Q.
You agree that in practice two years welding experience 21 had been required for welding inspectors?
22 A.
It was required by procedure to have two years of welding, 23 yes.
2d Q.
After that change, it was no longer required that you have 25 welding experience?
9 8
I I
A.
That's true.
2 Q.
That happened about July of 1982?
~
3 A.
I'm not sure of what the date was.
Probably.
I'm not 4
sure exactly when that change was made.
5 Q..
Are you aware of the transfer and certification of a o
number of persons who previously held the position of NDE 7
inspector to the post of welding inspector af ter that date?
8 A.
NDE inspector were put in the welding inspection crews 9
for the purpose of training as welding inspectors, yes, s
10 Q.
Did your responsibilities as technical supervisor change 11 in light of the change in qualification requirement for the 12 position of welding inspector?
13 A.
No.
Id Q.
You previously supervised the QC welding inspection, is visual welding inspection?
16 A.
Yes.
17 Q.
As well as the NDE welding testing?
n 18 A.
Yes.
19 Q.
You did that af ter that reclassification as well and you 20 continued to do that?
21 A.
Yes.
22 Q.
Mr. Baldwin, briefly describe your background and training 23 prior to your coming to work in the two positions that you have 24 just told me about at Catawba?
What did you do before that?
25 A.
I worked with Letourneau-W stinghouse.
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10
I Q.
What did you do there?
2 A.
I worked on the assembly line assembling earth moving 3
equipment and several other functions in that company, d
Q.
What other functions were those?
5 A.
I worked in the electrical department connecting electri-6 cal motors and statters.
I also worked as a painter.
7 Q.
Any other jobs?
8 A.
Yes, I worked with a Gulf Oil Distributor as a bookkeeper.
9 Q.
Have you ever done any welding work?
10 A.
No.
I haven't been employed as a welder.
11 Q.
What kind of welding work have you done?
12 A.
I h'ad a vocational training in high school and also 13 industrial arts training in college, had welding and metallurg:r.
i Id O.
Vocational training in high school in welding?
5 A.
Yes.
16 Q.
You said -- I'm sorry.
17 A.
I had welding and metallurgy training in college.
18 Q.
Where was that, sir?
19 A.
Tha t wa s at Berry College in Rome, Georgia.
I also have 20 had classes in basic metallurgy at Tri-County Tech in, I 21 believe, the address is Anderson, South Carolina.
22 Q.
The course at welding metallurgy was that a classroom 23 course?
24 A.
Yes.
Also incorporated the practical aspects of the 25 classroom plus practical aspects.
_(
11
L 1
Q.
You learned to weld?
2 A.
'Yes.
3 Q.
And, have you evdr wor ked as a welding inspector?
d A.
No, I haven't.
5 Q.
Any other construction experience prior to coming to 6
work for DukefPower Company in the position you have 7
identif ied?
8 A.
No.
9 Q. I believe this is a convenient stopping point, and if 10 we can resume tommorrow at eight.
11 EVENING RECESS 12 CONTINUING EXAMINATION:
(By Mr. Guild) (8 : 20 a.m., 6/30/83) 13 t
Baldwin, how are you sir?
Q.
Good morning, Mr.
34 A.
Good morning, sir.
15 Q.
Are you aware generally first of a nwnber of technical 16 and nontechnical concerns that were expressed by welding 17 inspectors at Catawba-during the period of approximately late 18
'81, early '827 19 A.
Yes, sir; but before I answer that, I would like to clear 20 the record of yesterday.
I think I misunderstood your question l
21 as far as my experience and background.
22 Q.
Sure.
23 A.
I came to work for Duke July 25, 1967, in the Quality 24 Control Department of the Construction Department at that time, 25 So, I have been employed with Duke in the inspection area since 12
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July 25, 1967.
In addition to that, most of the time prior to 2
being promoted as a supervisor, I was a radiographer, which the 3
job required me to make and interpret the results of radiographs.
s 4
Q.
All right, sir.
5 A.
That's all.
6 Q.
Help me with that then.
I think I picked you up at-- we 7
got you through working, college, and tech school, and working a
at Westinghouse.
9 A.
Yes, this is prior to being employed with Duke in '67.
10 Q.
Prior to Duke employment?
11 A.
Yes.
12 Q.
How about Gulf Oil bookkeeping job?
13 A.
That was prior to Duke.
(
Id Q.
Leading up to
'67, and you joined Duke Power Company?
What 15 was your position then, sir?
16 A.
At Duke Power Company?
17 Q.
Yes.
l l
18 A.
I was employed as an inspector in the civil inspection 19 area for approximately a year before I went to the welding 20 inspection area.
21 Q.
Slow down one second.
I want to take it one step at a time, 22 You were an inspector in the civil area?
23 A.
Yes.
l 24 Q.
What was your job title, if you remember?
25 A.
Civil inspector.
g 13 l
l 1
Q.
Where was that?
2 A.
That was at Oconee.
3 Q.
What was the nature of the inspection work you did?
4 A.
That was inspection of concrete reinforcing steel, the 5
inspection of aggregate that went into the concrete.
6 Q.
That was for approximately a year?
7 A.
Approximately a year, yes.
8 Q.
Then what was the next position you held with Duke?
9 A.
That was a radiographer.
10 Q.
That was an inspector also?
11 A.
Yes, inspector.
I was trained at B & W Erection Department, 12 Babcock & Wilcox, that was where I was trained.
That's where 13 my welding inspection training with Duke Power began in 1968 L
14 at the Erection Department in Barkton, Ohio.
15 Q.
B& W was the vendor for Oconee?
16 A.
They were the supplier of the reactor system for the 17 Oconee Plant.
18 Q.
They trained you in radiography?
i 19 A.
Radiography, magnetic particle and liquid penetrant inspec-20 tions.
21 Q.
Did you receive any welding training from them?
22 A.
Yes, radiography, I was trained on the interpretation of 23 radiographs which could be considered welding inspection train-l 24
- ing, l
i 25 Q.
For radiographing welds?
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1 A.
For the interpretation of the radiographing of welds.
That 2
was part of the training.
I was also trained to radiograph 3
the welds, d
Q.
To run a machine to take the radiograph?
5 A.
Yes, to use an x-ray machine or isotopes.
6 Q.
How long did that training last?
7 A.
That was for a month.
a Q.
Then that trained you to be certified as a radiographer?
9 A.
Yes, as a Level 1 radiographer, which allowed me to make 10 the radiograph.
After I became licensed with the State of 11 South Carolina.
12 Q.
Licensed in what capacity?
13 A.
Had to be licensed as a radiographer, which means you have
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14 to be trained in radiation safety and demonstrate your ability is before being licensed with the State of South Carolina on the 16 radioactive material license.
17 Q.
Is that the Health Department license, do you know?
l 18 A.
Yes.
l l'
O.
Then, did you take a test and get certified as a radiographer?
20 A.
Yes, I was certified as a radiographer shortly after the l
21 training.
I'm not sure what the required training period was, 22 the experience period was; but I became certified and was also i
23 tested and licensed as a radiographer shortly after.
l 24 Q.
By the State?
25 A.
I was licensed by the State and tested by our Physics 15 i
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[
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Department, Lionel Lewis.
2 Q.
Then you held the position of radiographer?
3 A.
Yes.
4 Q.
What period of time did you hold that job?
5 A.
From approximately '68 till
'72, I think.
o O.
At Oconee?
7 A.
Yes.
8 Q.
Then what was the next position you held?-
9 A.
The next position, I think, was approximately '73 when I 10 was promoted to Supervising Technician.
11 Q.
At Oconee?
12 A.
At Oconee.
13 Q.
What was your area of responsibility there?
I 34 A.
Area of responsibility there was to do nondestructive 15 testing.
At that time, I had inspectors doing ultrasonic 16 liquid ~ penetrant magnetic particle inspection.
But those types 17 of inspections--
18 Q.
Radiography?
19 A.
I don't recall at that time.
I was also serving as a 20 Level 3 radiographer which meant I was developing procedures 21 and techniques to be used in radiography.
22 Q.
Did you supervise welding inspectors?
23 A.
Not at Oconee.
Not inspectors classified as welding inspec-24 tors.
I supervised inspectors that were inspecting welds with 25 nondestructive testing.
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Q.
But not welding inspectors who did visual welding 2
inspection?
3 A.
Nondestructive testing inspectors had responsibilities to 4
inspect welds to make sure they were satisfactory to do the 5
tests, but they were not classified as visual inspectors.
6 Q.
There was a separate class of welding inspectors that 7
were--
8 A.
Yes.
9 Q.
You didn't supervise those?
10 A.
No, not that I recall.
11 Q.
Then the next position with Duke?
12 A.
Then I was transferred to Catawba, I think November 15, 13 1975, as a Supervising Technician; and I held that job for one t
14 or two years.
I'm not sure; and while I was at Catawba, I is was supervising welding inspectors, nondestructive inspections, 16 receiving inspectors, mechanical inspectors, a number of other 17 inspectors possibly.
I don't recall all the inspectors I was i
18 responsible for at the different periods of time.
19 Q.
If you have done some thinking about or refresh your 20 recollection, let's track back through and see if we can get 21 a little more precise about the dates and the specifics of 22 the job at Catawba than yesterday, Mr. Baldwin.
You first came 23 on November 15, 1975, Supervising Technician, and yesterday my 1
24 notes had you saying you supervised welding inspectors in 25 nondestructive testing, is that right?
17 i
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1 A.
Yes, at Catawba.
2 Q.
By welding inspection, then you do mean visual inspections 3
as well?
4 A.
Visual inspection, yes.
5 Q.
How long did you hold that position?
Wait a minute now.
6 I have got Supervising Technician was the first job title you 7
had at Catawba.
8 A.
Yes.
9 Q.
And how long did you hold that position, if you remember?
10 A.
At Catawba?
11 Q.
Yes.
12 A.
I think I was in that position a year or so after I came 13 to Catawba.
I 14 Q.
A year or so?
15 A.
Yes.
16 Q.
Then what position?
17 A.
Then was promoted to Technical Supervisor, which was the 18 second level supervision.
19 Q.
I'm a little confused.
Supervising Technician is a first 20 level.
21 A.
First level.
22 Q.
Technical Supervisor is second level?
i 23 A.
Yes.
l 24 Q.
What was your area of responsibility as Technical 25 Supervisor?
18
1 A.
At welding inspection or visual inspectors.
I had people 2 performing radiography, I had people performing nondestructive 3 testing, which included ultrasonic liquid penetrant and o
4 magnetic particle.
Pa'rt of that period of time was also-- I 5 had document control inspectors working directly for me.
I 6 was actually serving in the first line supervisory capacity 7
also.
At one period of time, I had receiv!.ng inspectors reporte a
ing directly to me.
So it was actually serving as a first line 9
supervisor and second line supervisor in another area at the 10 same time.
11 Q.
Why was that, sir?
12 A.
Because we had not promoted anyone to Supervising 13 Technician position to cover that area.
They were relatively t
Id small areas.
15 Q.
Give me an idea of the period of time when you would have 16 been doing both the second level and first level supervisor 17 job?
18 A.
I don't recall that specifically.
I think approximately 19 three years I did that, and I think that was from about '79 or 20
'78 to '82.
21 Q.
For the period of time that is material to the complaints 22 that were expressed by the Catawba welding inspectors late 23,81 through-- let's say late '81 to '82, it was during that 24 period of time you held both second level and first level 25 supervising positions approximately?
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19
t 1
A.
Yes, I think I did hold the position of first level and 2
second level during part of that period of time.
3 Q.
Is that the current position you hold with Duke Power?
4 A.
Current position I hold is Technical Supervisor of Welding 5
and Nondestructive Testing.
6 Q.
It's the same position that you held a.f ter you were promoted.
7 from Supervising Technician?
8 A.
Yes.
9 Q.
Do you have a better recollection of the date when you 10 were promoted to your present position, you said November 15, 11
'75, you came to Catawba Station a year or so--
12 A.
'76 or '77, I really don't recall specifically.
13 Q.
Your job has remained essentially the same with the 14 additional obligation or responsibilities that you have talked 15 about when you held that first line supervisor position at the 16 same time?
17 A.
Yes, essentially the same.
I no longer have inspectors 18 reporting directly to me at this time.
19 Q.
Who is between you and the inspectors now?
20 A.
I have three superintendents:
Stanley Ledford, who is the 21 Welding Inspector Supervisor; Bill Deaton, who is a Welding 22 Inspection Supervisor; and Dennis Cabe, he supervises radiography 23 at the site.
24 Q.
When was this additional level-- when was the level between 25 you and the Welding Inspectors inserted?
20
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A.
The level between me and the Welding Inspectors was inserted 2
when I was promoted to Technical Supervisor, approximately '76 3
or '77.
4 Q.
During the present time, you held your present job, there 5
has been a Level 1 supervisor between you and the Welding 6
Inspectors?
7 A.
Yes.
8 Q.
Now, sir, I think-- well, is there anything else that you 9
can tell me that you recall now that would help me understand 10 better your experience and qualifications, first and 11 specifically, the welding craft area, and second, in the 12 welding inspection area?
13 A.
I had a number of related seminars, and I have completed i
14 all of the Duke Power Company welding inspection and non-15 destructive training courses that relate to this.
I have 16 served as the Welding Inspection Examiner for a period of 17 time at Catawba, which means that I did training and certifying 18 the Welding Inspectors in accordance with the QA Program.
19 Q.
When did you do that, that Examiner position?
20 A.
I had that position for approximately two years.
I think 21
'79 and
'80.
I'm not sure about that.
Maybe later.
22 Q.
You did the Examiner job as well as the first and second 23 level supervisor job you talked about, that would have been 24 at the same time?
25 A.
I don't recall that.
I don't' recall if that was the same 21
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I period of time.
2 Q.
The best you remember, and I'm trying to get a sense of 3
this and not trying to hold you to recall you don't have, so tell me, if you don't remember; but I think you said '78 through 4
5
'82 or somewhere in that time frame, you thought you remembered 6
doing the first line supervisor at the same time you were 7 doing the Technical Supervisor, the second level position,and a
the best of your recollection, would the Welding Inspector 9
Examiner position have fallen in that same time, too?
10 A.
Yes, it would have.
11 Q.
I guess the question I started with, I ended the question--
12 anything else that has occurred-to you now that_would help 13 me understand your experience and qualifications in welding t
14 and welding inspection?
15 A.
Not that I can recall now.
16 Q.
I started this morning.
I direct your attention to a 4
17 subject I want to pursue in some detail, and you do recall the i
18 complaints by a number of QA Welding Inspectors, technical and 19 nontechnical matters, that were brought to the attention of 20 management in late '81, early '82?
21 A.
Yes.
22 Q.
And the work of the welding-- Catawba Welding Inspectors r
23 Task Force, their final report recommendation and implementatior.
24 of those?
25 A,
Iem aware of it, yes.
t 22
I 1
Q.
A number of procedural changes that affect the welding 2
inspection at Catawba have been adopted as a result of the 3
work of that Welding Inspector Task Force, is that right?
4 A.
I'm sure some procedures have been changed as a result 5
of that, but procedure change is an ongoing thing.
6 Q.
You're aware of a number of procedural changes that have 7
been adopted since the Task Force issued its report?
8 A.
I'm not aware of any changes in procedures in this time, 9
directly as a result of that; but I do know a number of pro-10 cedures have been changed.
11 Q.
Let me ask that question.
I think I understand your 12 answer, but are you aware of any changes that-- procedural 13 changes that affected welding inspection that resulted from
\\
14 the report and recommendations of the Welding Inspector Task 15 Force?
16 A.
Would you please state that question again?
17 Q.
Sure.
I just want to understand what you know and it's 18 not a trick question, but I want to know, do you know whether 19 or not there are any procedural changes that affect the 20 welding inspection work at Catawba that resulted from the 21 report of the Welding Inspector Task Force?
22 A.
I'm trying to understand what you mean, how would it l.
23 affect or what effect are you referring to on welding?
24 Q.
I guess I want you to tell me the answer to. hat question, 25 if the answer to the first question is yes.
If you do recall i
23 I
o I
-1 any, if you do know of any.
Help me understand what you 2
recall.
'3 A.
I'm not aware of any changes that affected the inspection 4
criteria as a result of the Task Force.
I'm aware of some 5
changes that might have affected the administrative part of 6
the procedure.
7 Q.
Fine, let's direct your attention to that.
8 A.
Not specifically.
That's the way I recall the changes 9
are more administrative than they are criteria or the 10 acceptance criteria.
11 Q.
Fair enough.
Do you remember the administrative changes?
12 Help me understand what administrative _ changes you understand 13 resulted from the Task Force recommendations.
(
14 A.
I really don't recall any specific changes, administrative 15 or otherwise, as a result of that.
16 Q.
Was the procedure that governs the identification and 17 processing of nonconforming items as they relate to inspection la of welding work at Catawba?
19 A.
That would be QA procedure, 0-1.
20 Q.
Procedure Q-1 has been in effect before and after the 21 work of the Welding Inspector Task Force?
22 A.
Yes.
23 Q.
Are you aware of changes in procedure 0-1 that resulted 24 from the work of the Task Force?
25 A.
Yes.. I do recall that since you brought that up.
24
I 1
O.
How about describing for me your understanding of the 2
changes in procedure Q-1, 3
A.
In what respect?
4 Q.
Any respect that you understand or you know of, si'r.
5 A.
Q-1 is really being used to identify at the beginning this 6
job minor discrepancies.
Any minor discrepancy, as I recall,
/
was reported on the Q-3A, which is nonconforming item report, e
and this was a tremendous burden on the system in trying to 9
handle this.
So after the Task Force review, the procedure to was revised to handle minor discrepancies by other means 11 to allow Procedure Q-1 to be more effective in handling prob-12 lems that needed more attention.
13 Q.
What do you understand the minor discrepancies to i
14 represent,as,you use that term, Mr. Baldwin, in the welding 15 area, using welding as an example if you would.
16 A.
I was referring to discrepancies that were identified 17 by the welding inspectors during their normal preplanned 18 inspection and the procedures made provisions for them to 19 handle them without writing out a QA or nonconforming item 20 report.
21 Q.
The procedures after the change?
22 A.
The procedures were more-- they were revised to more 23 clearly define how to handle those, I think.
I think I could 24 say that.
25 Q.
Then the procedures weren't changed, the procedures for 25
,----.n----,
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I 1
identifying those minor discrepancies during a preplanned 2
inspection existed before the change?
3 A.
The procedures existed before the change.
4 Q.
They weren't changed?
5 A.
But 0-1 was changed to more clearly identify how to handle 6
those problems and more specifically handle-- I'm calling 7
discrepancies problems.
a Q.
You don't identify--
3 9
A.
Let me say discrepancies instead of problems.
10 Q.
Problems that then sounded more serious than they are in 11 your judgment?
12 A.
It might be interpreted that way.
13 Q.
Now then, focus on the welding area and help me understand i
14 what you mean by minor discrepancies.
15 A.
If a welding inspector was doing an inspection, and he 16 found a minor arc strike or something, that's a minor discrep-17 ancy which the procedure does make provisions to correct that 18 without writing a nonconforming report.
19 Q.
Arc strike would be,in your judgment, in the nature of a i
l 20 cosmetic or blemish on the work surface?
21 A.
In most situations.
In some situations, it could be con-l 22 sidered more serious.
23 Q.
When would it be more serious?
24 A.
Depending on the area that the are strike was in and the j
piece of equipment or piping it happened to be on, depending on 25 l
26 i
i
'I 1
the surface intended for that equipment.
2 Q.
Give me an example of that situation, not saying that has 3
occurred or would' occur, but give me an example of a situation 4
that you described where an arc strike could be other than a 5
minor discrepancy.
6 A.
On the face of the flange or something where you had a 7
mechanical connection.
8 Q.
Where the trueness of the surface was required by the 9
inspector?
10 A.
Yes.
11 Q.
Would that be a bow surf ace for example?
Give me an 12 example.
13 A.
A flange, a fitting, a flange for making a mechanical i
14 joint on a packing system.
15 Q.
Give me another example of how you're using the term 16 minor discrepancy in this context.
17 A.
If a Welding Inspector has a responsibility of assuring 18 that the fit-up inspection of the joint is proper so if a 19 craftsman calls for a fit-up inspection and the fit-up inspec-20 tion doesn't meet the criteria, that could be considered a 1
21 minor discrepancy.
22 Q.
Pipes not aligned properly?
23 A.
Yes.
24 Q.
Are there circumstances, Mr. Baldwin, where proper fit-up
.25 in this instance, for example, pipe misalignment, would be i
g 27 i
I
6 1
other than a minor discrepancy?
2 A.
I can't think of any specific, but I'm sure there are 3
situations where it could be something other than a minor 4
discrepancy, yes.
5 Q.
Have you ever seen craft try to use a come-along or some 6
other kind of device to force pipes to line up close enough 7
to be able to perform a weld on them contrary to construction a
procedure?
9 A.
I haven't seen that, but I have approved nonconforming 10 item reports that were written by Welding Inspectors.
11 Q.
That kind of thing has happened before?
12 A.
Yes, and it was identified by Welding Inspection and 13 corrected.
14 Q.
That would be a circumstance where misalignment or the 15 incorrect fit-up would be other than a minor discrepancy in 16 your judgment?
17 A.
That would not directly affect the fit-up of the joint la other than the face they are putting unnecessary or more force
(
19 on the pack than would be allowed to make that fit-up.
A 20 certain amount of force is permitted in certain situations, 21 and certain situations, it's improper to use that force to 22 make the fit-up.
23 Q.
Well, let's take a situation where it's improper contrary 24 to specifications, and I want to understand in that situation 25 would it be other than a minor discrepancy in your judgment?
28 i
i 1
l
(
i A.
Yes, to use undue force would be something other than a 2 minor discrepancy.
4 3 Q.
Is that something then that you would expect that should 4 be handled under Q-1 both before and after the procedural 5
changes?
6 A.
Yes, because that will require the design engineering 7
evaluation of the situation.
8 Q.
Any other examples occur to you of situations where 9
improper fit-up, either pipe alignment or some other improper 10 fit-up, would be other than a minor discrepancy, Mr. Baldwin?
11 A.
I'm sure there are numerous other situations that would be 12 something other than a minor disrepancy, but I can't recall 4
13 any.
p 14 Q.
None occur to you now?
15 A.
None occur to me at this time.
16 Q.
Well,' talking then about arc strikes, improper ~ fit-ups 17 what other kind-- what other examples would represent in your 18 mind minor disrepancies that should be handled the way we 19 described under the new procedures?
20 A.
Undercuts, it could be handled as a minor discrepancy; 21 excessive reinforcement on the weld.
L 22 Q.
Undercut, let's talk about that.
Define that for me, 23 please.
24 A.
In the process of welding,the welder melts and consumes
'. 5 part of the base material adjacent to the weld and doesn't fill I.
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-that area up with welding material, and it leaves a groove 2
adjacent to the weld.
3 Q.
That's a minor discrepancy?
4 A.
Generally it is.
5 Q.
Tell me any circumstances in which you would understand 6
that an undercut would represent other than a minor discrepancy 7
A.
Let me answer your question in this way.
If an inspector 8
had inspected the weld and signed for that weld and later it 9
was identified that he had obviously overlooked a rejectable 10 undercut, that would be considered something other than a 11 minor discrepancy because he had already passed the inspection 12 and had bypassed the intended means to catch that sort of 13 thing.
'd Q.
I understand.
That same point would apply to the other 15 two examples of minor discrepancies?
16 A.
Yes.
Any time anything is overlooked that fails to meet 17 the acceptance criteria.
la Q.
Then it would be other than minor?
19 A.
Yes, because it's evaluated to the extent.
20 Q.
That would be a failure-- That would be a discrepancy in 21 quality assurance procedure?
22 A.
Yes.
But in the inspection.
23 Q.
The significance of the deficiency would be that the 24 Welding Inspector didn't do the job he was supposed to do 25 in short, right?
i 30
1 A.
Yes, that is what is looked at.
That is why it's con-2 sidered to be a nonconforming item to determine if it's wide-3 spread.
If the inspector is qualified or did he just make an error in judgment or overlook something, a human error'.
Each 4
5 one of those situations is evaluated.
6 Q.
. If it were determined that an inspector overlooked a 7
rejectable undercut, that deficiency should be treated under 8
Q-1 as a nonconforming item?
9 A.
Yes, and I don't know of any situation where it would not 10 be treated.
11 Q.
That's both before and after the change in procedure that 12 you have referenced to?
13 A.
Yes.
t 14 Q.
But the rejectable undercut, it would still be in your 15 judgment a minor deficiency, the problem here would be the 16 inspector failed to reject it?
17 A.
. It could have been handled as a minor discrepancy or 18 as he-was making his inspection because the procedure identi-19 fies a means for him to correct that situation.
j 20 Q.
How about other examples?
I think you started to tell 21 me about the excessive reinforcement.
You mentioned that?
22 A.
Yes, excessive reinforcement is another deficiency.
23 Q.
What does that mean?
What is excessive reinforcement?
24 A.
Excessive reinforcement is excessive weld on the joint.
25 Q.
Are there circumstances where excessive reinforcement, in i
31 f
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your judgment, would not represent a minor discrepancy?
2 A.
Yes, it's possible.
3 Q.
Tell me about that.
4 A.
Well, if the inspector overlooked, in his judgment, or 4
5 failed to catch or identify excessive reinforcement at hi's 6
inspection and it was later determined to not meet the criteria, 7
that would be handled as something other than a minor dis-a crepancy.
9 Q.
I understand generally if the inspector doesn't catch it, to that is the problem with the inspection; but focusing on the 11 workmanship itself here, there are situations where excessive 12 reinforcement itself would not be a minor discrepancy?
13 A.,
I'm classifying.
Let me make sure we understand what I'm
('
14 classifying in my discrepancy.
I'm classifying those as l
15 discrepancies that can be corrected within the QA Program.
16 without further engineering evaluation.
Usually in an 17 inspector's judgment, he can get this corrected without either la signing the acceptance of that inspection or writing Q-1A on 19 it.
The procedure identifies the means for him to do that.
20 Q.
What procedure do you have reference to there?
21 A.
M-4.
22 Q.
What is procedure M-4?
23 A.
It's a procedure for the inspection of ASME.
It's basic 24 procedure.
There's other procedures that are referred to, 25 M-4.
32
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Q.
What's the procedure H-47 f..
'2 A.
I believe H-4 is identification and control of piping 3
material.
4 Q.'
Including ASME piping, piping used in ASME welding?
5 A.
Primarily piping used in.ASME welding.
- g,
P] ;'
J
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6 Q.
What in M-4-establishes the procedure that would permit 7
the inspector to resolve minor discrapancies in the way you 8
have talked about?
9 A.
The procedure as a form, which is the M-4A, which has 10 accept and reject marks on it at this time, and I'm not sure 11 exactly or specifically what the procedure says, but at this 12 time, because it has been revised a number of times, and i
13 it's very difficult to keep up with the wording and revisions 14 even.though I'm trained in each revision.
The procedure l
15 does, if I recall correctly, give directions to the inspector
'r
/
16 if he identifies a minor discrepancy to reject that inspection
[
17 and identify the discrepancy on the M-4A.
la Q.
Describe for me how he describes the document, the dis-19 repancy on-the M-4A.
20 A.
He rejects it, he has a rejection block on the M-4A, and
,d o
21 he has an area on the form to describe the discrepancy and 4
22 the extent of it which is the record of defects, I believe 23 is what it's called on the form.
24 Q.
Counsel, has procedure M-4 been.made available in discov-8,
25 ery?-
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MR. McGARRY:
I don't know.
I will attempt to find 2-out.
3 Q.
Will you consult the records wagon?
4 MR. McGARRY:
I still don't know the answer, 5
Mr. Guild.
I don't believe that the M-4 procedure was 6
specifically referenced in Interrogatories inasmuch as the 7
M-4 procedure wasn't affected by the Welding Task Force 8
Report, but the welding procedure is indeed included in 9
the Duke Quality Assurance Manual, which is available, 10 and I believe has been made available to you.
11 Q.
Can we get that procedure then so the witness can refer 12 to it?
13 MR. McGARRY:
Yes.
Can we take a break?
(
14 SHORT RECESS (9 :05 a.m.)
15 CONTINUING EXAMINATION:
(By Mr. Guild) (9 :20 a.m.)
16 Q.
Mr. Baldwin, I have a copy of Procedure M-4 in front of 17 me.
You have had a chance to see it over the break?
l 18 A.
Yes, sir.
19 Q.
Do you know whether or not this is the latest revision to 20 Procedure M-47 l
21 A.
I think it is.
22 Q.
Is the date that appears on that cover sheet-- how about 23 Mr. Henry's cover-- apprcved when?
24 A.
3-15-83.
25 Q.
Construction approval?
34 6
I i
A.
That was 3-20-83.
2 Q.
Whose signature is on that construction?
3 A.
I believe that's Mr. R. L. Dick.
4 Q.
Mr. Dick's signature?
5 A.
Yes.
6 Q.
This is revision number what?
7 A.
Revision number thirteen.
8 Q.
Attached to Procedure M-4 is the form M-4A that you have 9
referenced?
to A.
Yes, sir.
11 Q.
What is the title of that form?
12 A.
Welding Process control Sheet.
13 Q.
Does that, the Process Control Sheet, that would be used
(
14 for a weld that was performed and inspected under ASME Code 15 requirements?
16 A.
Yes.
17 Q.
You have made a reference just before we took the break, 18 and you were saying that if one of these minor discrepancies 19 was identified by an inspector in a process of his preplanned 20 inspection, he would use this form to note that and to get 21 it corrected and how about just directing my attention or 22 at least run me through an example of using this form, how an 23 inspector would do that.
Let's take the example of the under-24 cut.
25 A.
Okay.
There's really two means that the inspector can 35
I handle an undercut by using the form and still being in com-2 pliance with the procedure.
If the craftsman calls for inspec-3 tion, and the inspector discovers that the undercut is in 4
violation of the criteria, we have given the inspector the 5
option of getting that corrected and previous situations, if 6
it's very minor and can be repaired very quickly and the 7
craftsman is there to take care of it, he can get it corrected a
it and accept the weld, something very minor, before he accepts 9
the inspection; and the inspector also has the option, this 10 was prior to this previous revision of the form, the form Il now has a reject blocked on final.
Before, we didn't have 12 the reject blocked on the form, the previous revision of the 13 form.
t Id Q.
Help me figure out what you're referring to.
Where is the 15 reject block?
16 A.
Step 7, Final Visual Inspection.
You see the A and the 17 R in the next column?
1a Q.
Yes.
19 A.
That's for accept and reject.
20 Q.
Formerly, there was no accept / reject block?
21 A.
Yes, for a period of time, there was no accept or reject 22 block.
There was wording in the procedure that gave the 23 inspector directions not to sign off the form until the work 24 was acceptable.
He just withheld his signature.
25 Q.
Then after the work-- after the deficiency was corrected--
(
36
I 1
A.
He reinspected the work and signed the form, if it was 2
acceptable.
3 Q.
Now when does that change with adding the accept / reject d
block so that he has the option?
5 A.
I really think this was changed two or three revisions 6
ago, probably a year or so ago.
I 'm not sure.
7 Q.
Would that change have been made since the recommendations 8
of the Welding Inspector Task Force?
9 A.
I believe the change was made prior to the Welding 10 Inspector Task Force.
11 Q.
So lead me through it as it stands now on this current 12 version of the procedure, and then tell me after you have done 13 that, how things were done before.
t 14 A.
Let's use the form as a guideline, and let's assume that 15 this inspection that was rejected, the amount of discrepancy 16 was discovered at final revision.
You see Step 7, that would 17 have been rejected by the Welding Inspector or Visual l
18 Inspection.
l 19 Q.
He would do what?
l 20 A.
He would mark the R block and put a check in the R block.
l 21 Q.
On Line 7?
22 A.
Yes, and you come to the bottom of the form under Records 23 of Surface Defects, that's by MT, PT, or VT.
MT for magnetic l
24 particle, PT for liquid penetrant, and VT for visual inspec-l l
25 tion.
He would indicate the type of defect and when the 37 l
[
l_
1 1
defect was removed, and re-examined, he would initial with 2
his level of certification and the date.
3 Q.
On the example we're using undercut, excessive undercut, 4
what would he do?
5 A.
He would write undercut instead of linear indication.
He would reject the inspection, record the type of deficiency, 6
7 undercut, and return the Process Control Form back to the a
craftsman for repairing of the work.
9 Q.
Then what would happen?
10 A.
The craftsman would make the repair and call for another 11 inspection and the inspector would go through the same 12 process.
He would determine if the weld was acceptable and 13 sign the acceptance off under B, defects removed, surface t
14 re-examined.
The records of surface defect.
He would initial 15 the form and put his level of certification and the date it 16 was accepted.
17 Q.
The certification level is the box that says level on 18 there?
19 A.
Yes, level of certification.
I 20 Q.
That's the certification of the welder?
21 A.
The certification of the Welding Inspector or NDE Inspector 22 or whatever it may be.
23 Q.
Then what would happen?
24 A.
It would go to the next step on the Process Control Form.
25 If the NDE was required after the weld was repaired, he also t
38 l
~
I 1
has to make a determination prior to accepting that if the 2
weld is acceptable and in this particular situation, the 3
Welding Inspector signed on this form that the weld was d
acceptable with that weld repair, so some minor grinding 5
apparently was done to correct the minor discrepancy.
6 Q.
In the one that's used in this example?
7 A.
In the one that's used in this example, yes.
8 Q.
In the case of an undercut, that would have to be rewelded 9
or repaired or patched, or how would the defect be removed 10 in the example of an undercut?
11 A.
Generally, that's done by welding.
Call it cosmetic 12 welding.
13 Q.
Fill the undercut with welding material?
Id A.
Yes, generally.
15 Q.
How would the form be filled out in the example of an 16 undercut?
17 A.
Well, if welding was done, the welder would have to enter 18 the repair number.
19 Q.
Where would that be?
20 A.
That would be under Weld Information.
He would have to 21 enter all of his information, his initials.
22 Q.
Back up at the top of the form under repair?
23 A.
That's under Weld Information Record near the bottom, just 24 above the Record of Surface Defect.
He gives the repair 25 number, his initials, his welder stencil number, all the
(
39 t-
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information required by that form and he makes the repair 2
and calls for another inspection and the inspector signs it 3
off.
4 Q.
All right.
5 A.
That's the Visual Inspector.
If the Visual Inspector 6
accepts a weld and NDE is required on the weld, it goes to 7
the next step which would be under A4.8.
a Q.
All right, sir.
Now you were leading me through some 9
examples here.
We had the undercut as the minor discrepancy 10 and the situation, and you were saying that he faced-- he had 11 a couple of choices.
And the first choice that you identified 12 was to correct it before he completed-- before he inspected 13 it.
That would have been in the previous version of this 14 procedure, the earlier version of this procedure, is that is right?
16 A.
It's still not incorrect.
Generally, it's not done that 17 way, but in some situations, the inspector does allow the 18 discrepancy to be corrected, in some situations.
19 Q.
Let's take the case of an undercut.
How would that be 20 handled if it were one of those situations where it was 21 corrected before inspected?
22 A.
If the weld was acceptable and met the criteria that the 23 inspector was inspecting to, he would sign the weld off as 24 visually acceptable.
25 Q.
How about if there had been correction done, minor in 40 g
1
I 1
nature in your opinion?
2 A.
Prior to the inspector signing off?
3 Q.
Yes.
d A.
I'm not sure what point you're making.
5 Q.
I guess I'm not trying to make any point particularly, 6
I'm trying to understand what you said.
In some situations, 7
I thought you told me if it.was minor in the craftsman and a
the craftsman was there and the inspector noted the deficiency, 9
he could get the deficiency corrected before he did anything 30 on this form.
11 A.
Essentially what he can do is tell the craftsman he is not 12 ready for inspection.
It's not good enough.
You correct it, 13 and I'll reinspect it when it's~ acceptable.
Id Q.
How would that work?
If the undercut is an example of a 15 situation where you could do that, tell me how you would do 16 that in a situation of an undercut.
17 A.
That would be the inspector's responsibility to tell the 18 craftsman that you have got an undercut that's not acceptable, 19 and it's up to you to get it corrected.
When you get it 20 corrected, call me again, and I will inspect the weld.
21 Q.
How would the inspector use this form in that situation?
22 A.
In this particular situation, the situation that I was 23 describing was prior to this revision of the form that did 24 have an accept and reject block on it.
Generally, it's now 25 used if any discrepancy is discovered, it's documented on the a
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form.
2 Q.
Generally?
3 A.
Generally.
I can't say that's true in all situations.
' Generally that's true.
5 Q.
And it would be noted in the way you describe using the 6
earlier example?
7 A.
- Yes, a
Q.
A previous revision of the form before there was the accept /
9 reject block there, how would it be handled, sir, in that 10 example?
11 A.
The inspector wouldn't sign the inspection until the work 12 was acceptable.
I3 Q.
How would the form have been used in that situation?
Was
'd the form essentially the same except for the change in the 15 A and R, accept and reject blocks?
16 A.
Yes.
17 Q.
Before they had the reject block there, how would the la inspector have handled it according to procedure before the 19 revision?
2c A.
Before the revision, he would not sign for the inspection 21 until the weld was acceptable.
22 Q.
Tell the craftsman to go back and do it?
23 A.
He would tell the craftsman what was wrong, why it wasn't 24 acceptable so the craftsman could correct the discrepancy.
25 Q.
Then call me when you're ready for inspection?
42
l' 1
A.
Yes.
2 Q.
Would there he any record made of that identification of 3
a discrepar.:y under the previous procedure?
~4 A.
Those minor discrepancies that were identified and to 5 place to reject on the form, is that what you're saying?
6 Q.
Yes.
7 A.
No.
Let me clarify that.
Not for visual inspection.
This 8
block Record of Surface Defects was there prior to that revisier t we're referring to, and this block was used for NDE, so the 10 record of defects was documented for NDE inspection and not 11 for visual inspection.
12 Q.
So we have got the previous choice of doing as you just 13 described, which didn't generate the use of this form till the 14 work wrs corrected, and the actual second inspection got done.
15 You say that while generally after this revision, adding the 16 accept / reject block, the initial rejection would be noted, 17 there may be situations where--
i 18 A.
Very minor.
19 Q.
It was done.
Where the former procedure was still followed 20 without rejecting on this form?
21 A.
Yes, there is possibly a situation.
l 22 Q.
So that's sort of the choice 1 for minor discrepancies 23 using this form, which is basically to get it fixed and then 24 do the inspection and cceept it, it's acceptable.
What are i
25 the other choices that the inspector would have and lead me 43
(
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through those.
2 A.
We have a minor discrepancy report, which is known as the 3 R-2Awhich would be used when neither of the other two situations would apply, such as a random inspection where the inspector 4
5 would not have process control to document his inspection 6
and he identified a discrepancy.
7 Q.
What kind of discrepancy wculd come under that procedure, 8
sir?
9 A.
If he was doing a random inspection and discovered there 10 was a gap or something that occurred in the piping as a result 11 of construction work, he would identify that.
He could identify 12 that using the R-2A form which would be reviewed and could be 13 upgraded to an NCI.
\\
14 Q.
Is the importance of the use of this second alternative 15 that the discrepancy in situation was identified in other than 16 preplanned inspections?
Do you follow me?
The R-2A is used 17 for preplanned inspection?
It's for a preplanned inspection?
18 A.
Yes.
19 Q.
I understood if you said random inspection.
20 A.
The procedure does require random inspection.
j 21 Q.
Random?
22 A.
Random would be considered a preplanned inspection.
23 Q.
I follow you.
Then, is the distinction, in my understandine',
24 that the distinction is it's not something that's discovered 25 and governed by the normal process control?
(
[
44 l
t
(
i 1
A.
Yes, that's true.
When you don't have the process control.
2 When there's no other process control available to document 3
the inspection or discrepancy covered in that inspection, the 4
R-2A is generally used.
5 Q.
The M-4A is used as you describe or the alternative of o
getting the work fixed, which was the first choice.
That's 7
used when the inspector finds it's in a preplanned inspection, 8
that is following procedure M-4 normally a process control?
9 A.
Yes, generally.
10 Q.
Generally.
The same kind of discrepancies, though, would 11 be noted?
Is there any distinction in the kind of discrepancies 12 that are appropriately noted using the R-2 procedure?
13 A.
May be the same type discrepancies that are noted on the
\\
Id M-4A that you would note on the R-2A.
The inspection may not, 15 maybe the M-4A doesn't apply to that inspecticn, the same type 16 of discrepancy.
17 Q.
Because it's not during normal process control?
18 A.
That's right.
19 Q.
Is it a fair understanding, Mr. Baldwin, that the dis-20 tinction is not in the type of discrepancy, it's in the 21 circumstances under which the discrepancy is noted, is that the 22 important distinction?
23 A.
It's determined by-- yes, on whether or not process control 24 is available.
It's normal in process insp;ction.
25 Q.
So we have got using process control and the way you des-45
I i
cribe, and we have got then using your minor discrepancy report, 2
the R-2A, what other choices, if any, does an inspector have 3
when he finds a discrepancy?
4 A.
The Q-1A, which is Nonconforming Item Report.
5 Q.
When would it be appropriate to use that?
6 A.
It would be appropriate when none of the other means 7
I have described would be appropriate.
s Q.
When would that be, sir, give me a concrete example, in 9
welding, if you can.
I 10 A.
The situation that comes to mind would be if he was doing 11 a reinspection as a result of something, something that had 12 already been accepted and signed off by a previous inspector, 13 even by himself.
It would normally be nonconformed.
(
14 Q.
When would such a reinspection typically occur?
15 A.
On an M-18 inspection.
L
.16 Q.
What is that?
17 A.
That is an inspection on structural steel.
l.
18 Q.
Describe some more about that so I can understand what it l
19 is.
20 A.
It would be a portion of work, such as a platform,that had j
21 been constructed over a period of time and as inspectors, 22 or as the work was being done, the inspector or number of 23 inspectors, might have inspected the work as the craftsmen 24 had completed that, but then the final sign-off of that work l
25 an inspector is required to verify that everything on that 46 p
l l
I
i i
platform, whatever the structure, has been inspected and 2
accepted,and he is required to reinspect.
3 Q.
Give me an example of how that would come up.
4 A.
I thought I had just given you an example.
-5 Q.
You did, and I think I understand you, but let's take a 6
Procedure Q-1 then, and I think I have a copy.
This is 7
Procedure Q-1, and it's been identified as an exhibit to 8
another deposition we have taken.
Can you tell me whether 9
that's the latest revision?
10 A.
I believe it is.
It's Revision 18.
ii Q.
Take Q-1, and I have that came one in front of me here, 12 and run me through how that would be handled in the exhibit 13 which you have just identified.
I want to clarify that we
('
14 bave the current version.
Is this the current version?
15 MR. McGARRY:
That's the current version.
16 A.
The example I gave you may not be a good example.
That's 17 a preplanned inspection.
I can't think of a situation that la would be nonconformed, even though the inspector signed it 19 off because it's preplanned inspection, so that's really not 20 a good example.
21 Q.
So in this situation, you're talking about the M-18, some-22 body is coming back to look at a structure that has been built, 23 lots of welds in it, lots of inspectors involved; but it's a 24 routine inspection since it's called for by M-18, and, there-25 fore handled by process control or the R-2A.
47
i 1
1 A.
Yes.
2 Q.
It would be handled through process control?
3 A.
Yes, it has M-18, a form that the inspector signed off 4
after he has verified the work is acceptable for that portion 5
of the work.
6 Q.
That would not be a circumstance where the Q-1 nonconform-7 ing item--
8 A.
I can't relate to one.
I'm sure there is a situation where 9
a Q-1 would be appropriate in that situation, but I can't 10 recall one.
11 Q.
Let's take another example.
Give me an example of a 12 situation where the Q-1 procedure under current procedure would 13 be used in welding.
(
14 A.
Anything that's discovered that's not in process inspection, 15 a preplanned in-process inspection.
16 Q.
I understand the definition now, but give me an example 17 of a situation that in your judgment would be appropriately 18 handled by use of Q-1A as it stands now.
l 19 A.
If the inspector discovered something that was clearly in l
20 l
violation of the acceptance criteria on a vendor supplied item 21 or he had discovered a hole in the piping system on something 22 other than a preplanned inspection, that would be nonconforming.
23
(
Q.
How about something in welding?
l 24 A.
If he had discovered a deficient weld on something other i
i.
25 than a preplanned inspection, that would be nonconforming.
48 g
I 1
Q.
How would an inspector discover a deficient weld in other 2
than a preplanned inspection?
3 A.
Just by observation.
d Q.
By just chance?
5 A.
Just chance, yes.
6 Q.
You walk through the plant and you see a bad weld just 7
generally?
I'm not trying to be facetious.
I want to under-8 stand.
9 A.
Yes.
That's generally the way.
That's one way he could 10 discover something that's defective.
Just by walking through 11 the plant, or he may be doing an inspection adjacent to just 12 as observation while doing a preplanned inspection.
The pro-13 cedure does specify areas that at random inspections are t
3d required.
15 Q.
But those are preplanned?
16 A.
Yes.
17 Q.
Those you would use a process control procedure for those 18 random inspections?
19 A.
Yes, if you didn't have process control available, and 20 if you found a discrepancy, it would either be handled with 21 a minor discrepancy report or in some situations, it could be 22 handled with a Q-1A.
23 Q.
If it was a random inspection and,therefore, preplanned, by 24 definition you wouldn't use Q-1, you would use an R-2A?
25 A.
Unless the inspector knew that it would require seeing
(
49
1 design engineering evaluation.
But even if he had written 2
an R-2A on it, the R-2A would probably be elevated to a Q-1A.
3 Q.
Let's talk about that last point.
Who is responsible d
for-- Describe how, including who is responsible for elevating 5
an R-2 deficiency to a Q-1?
6 A.
It would be the Technical Support Group or Engineering 7
Department or even QA Department could do that.
8 Q.
Technical Support, Design Engineering, or QA?
That covers 9
a lot of people, doesn't it?
10 A.
Most anyone can elevate to a 0-1A if they felt it to be 11 appropriate.
12 Q.
How about you?
13 A.
Yes.
i.
'd Q.
Tell me how you fit into this, Mr. Baldwin.
Give me an 15 example of a situation that might occur where it would be your 16 responsibility to review an R-2A and elevate it to an NCI?
37 A.
Normally I don't review R-2A's.
18 Q.
Tell me a situation where you would, if you would.
A.
I don't have responsibility of reviewing it and to correct-20 ing discrepancies or putting resolutions on them or correcting 21 discrepancies.
22 Q.
So you wouldn't then?
23 A.
I would not, no.
I can't think of a situation.
I could 24 if I deemed it necessary, but that's not my normal responsi-25 bility.
[
50
(
1 Q.
You have the authority but not normally the responsibility 2
for doing that, is that fair?
3 A.
It's my responsibility to inspect and report the result 4
or get that done in my area.
5 Q.
To see the inspection gets done?
6 A.
To see the inspection gets done and report the results of 7
that innpection.
8 Q.
But you don't do the inspection?
9 A.
I don't do the inspection.
10 Q.
Tell me what the process for reviewing the R-2A to deter-11 mind whether it should be upgraded to an NCI, how does that 12 work?
13 A.
I really can't speak firsthand on that.
I'm not sure if 9
Id they give it with the review of the appropriate people.
15 Q.
The appropriate people?
Let's talk about that.
Of the 16 Tech Support Design Engineering, you're in the QA area?
17 A.
Yes.
Now Design Engineering normally doesn't evaluate 18 R-2A's.
I think you misunderstood.
I was referring to the f
39 Tech Support Group.
That is the Engineering Department at 20 the site.
Normally, Design doesn't review R-2A's.
It can 21 happen, but I'm sure in some situations it does happen where 22 they are involved in the review of it.
23 Q.
It means it can go to QA for review or to Tech Support 24 with engineering expertise?
25 A.'
Yes.
t 51 4
g.
, ~.,
w
I 1
Q.
Tell me how that would happen.
How does an R-2A get 2
reviewed by either of those two organizations as you understand 1 3
A.
The discrepancy-- I'm not even sure who that is that has d
responsibility of writing those to the appropriate people for
[
5 that resolution, and that person is assigned the responsibility 6
of the resolution and has to make a determination is this an 7
appropriate means of handling this discrepancy.
8 Q.
In the QA area, how is it done, if you know?
9 A.
QA would review-R-2A's.
10 Q.
Who, do you know?
11 A.
I don't know specifically.
I know the area.
12 Q.
Tell me what you know, tell me the area.
13 A.
That'would be Joe Shopshire's area.
Id Q.
What is Mr. Shopshire's job?
15 A.
I believe his title is QA Engineer Mechanical and Welding.
16 rem not sure specifically.
He is over the mechanical and 17 welding QA tech support.
18 Q.
It wouldn't go through you normally?
19 A.
Normally I don't see R-2A's unless thera is some action.
20 Q.
If the corrective action requires reinspection, would you 21 know about it?
22 A.
Not necessarily.
It may be routed directly to the super-23 visor.
24 Q.
Can it go the other way according to procedure, Mr. Baldwin?
25 Can an NCI, under the current Q-1 Procedure, be downgraded to
(
52
~.
1 R-2A?
2 A.
I believe you could consider that to be possible, yes.
3 Q.
Does it happen in practice?
d A.
Not generally.
5 Q..
Are you aware of it ever having happened?
6 A.
I'm not aware of any specific situation, no.
7 Q.
Since the new procedure has been adopted,and I'm not talking 8
specifically about the latest revision of either of these, 9
but generally the procedure changes you identified that go 10 back some time that provided for using other than the noncon-il forming item, the Q-1, to identify and document welding 12 deficiencies.
Since those procedures have changed, have the 13 number of nonconforming items in welding been reduced?
i Id A.
Yes.
15 Q.
Significantly?
16 A.
Yes.
17 Q.
Give me an idea of the numbers before and after the 18 procedure changes generally, the best of your understanding.
t 19 A.
Probably twenty-five a week wer<e written in the welding 20 inspection area prior to procedure revisions.
21 Q.
And now?
l A.
Probably two a week.
The reason for that change as I see 22 23 it, is the welding inspection area never utilized the use of 24 R-2A's and most of the minor discrepancies are now, or a lot 25 of minor discrepancies, are being handled by the R-2 procedure.
i 53 i
i I
l 1
Q.
So before the procedure change, there were no R-2A's in 2
the welding area, is that fair?
3 A.
I wouldn't say there are no R-2A's, but generally the Q-1 1
4 was used where the R-2 procedures are now being used.
5 Q.
If not none, there were very few, is that fair?
6 A.
Yes, very few.
7 Q.
So help me by comparing.
Before there was very few or 8
none R-2's?
9 A.
I don't even recall any, but I wouldn't say there were 10 none.
11 Q.
And now give me an idea in the welding area of how 12 frequently you would see R-2A's.
13 A.
As I say, they aren't routed through me, and I don't have a s-14 good feel for that, but I feel there are several R-2A's 15 written each week.
16 Q.
Who would know more particularly, Mr. Baldwin, in terms 17 of numbers of R-2A's in the welding area?
18 A,
Ism sure the Inspection Superintendent or the Project QA 19 Manager.
20 Q.
Mr. Davison?
21 A.
Yes.
22 Q.
Does the Project QA Manager now review all of the R-2A's?
23 A.
I don't really know.
He doesn't have a signature block on 24 the R-2A, I don't believe.
25 Q.
Mr. Shopshire, would he review the R-2A's in the welding 54 g
I area?
2 A.
I feel sure that either he or some of his employees would 3
have that responsibility, d
Q.
In the welding inspection area, Mr. Baldwin, are yo'u aware 5
of reports which trend R-2A's?
6 A.
Yes.
7 Q.
Do you see those reports?
8 A.
Occasionally.
9 Q.
I mean did you see those as a part of your job and the 10 trend analysis routed through you or do you initiate them or 11 see them in any way, shape, or form?
12 A.
No,I really don't have any responsibility.
It's just 13 information if I see any reports.
t 14 Q.
How about trend analysis for NCI's?
15 A.
I don't normally see those.
Maybe for information, they 16 may be routsd through me.
17 Q.
Would there be a trend analysis for NCI's specifically in 18 the welding area that you would be informed of by chance if 19 it related to the inspection function?
20 A.
Possibly.
21 Q.
How about trend analysis of deficiencies noted in the 22 M-4 procedure, say, on the M-4A?
23 - A.
Not necessarily.
If it was inspection deficiencies, I 24 l
probably would.
I'm sure I would be made aware of those.
l 25 Q.
Are you aware of any trend analysis that is performed on 55
n I
1 deficiencies that are identif..ed in the M-4 procedure?
2 A.
No.
I don't recall any specific trend analysis.
3 Q.
Is there any other, with the same reference to procedure M-4, is there any other documentation of deficiencies that d
5 are noted in the course of process control, say, on an M-4?
6 A.
There's numerous other procedures that are used in process 7
control.
8 Q.
Taking M-4's is what I'm focusing my attention on.
An M-4, 9 you have identified, could be-- the M-4 process and M-4A form 10 could be the process and the documentation for noting a 11 deficiency in welding, correct?
12 A.
On ASME.
13 Q.
As you've just described on ASME weld?
t-14 A.
Yes.
15 Q.
What I want to know, are there any other documents that 16 would reflect the deficiencies that have been noted through 17 the M-4 process?
18 A.
Well, the inspector has the option of using the work-19 stoppage report if it's significant to the point, you know, 20 where the inspector feels he needs to stop the work in that 21 particular area.
He can use the workstoppage report'.
22 Q.
What is that, sir?
23 A.
I believe that's R-3A form.
I'm not sure ab0ut that.
R-3.
24 Q.
What is procedure R-3?
25 A.
I'm not sure of the correct procedure on that.
It's not a 56 g
J-
~
x.
I 1
daily thing we use workstoppage.
Usually the R-2 or Q-1 takes 2
care of the process.
3 Q.
Counsel, do we have that available, is there an R-3 proce-4 dure?
5 MR. McGARRY:
I believe the records will reflect it's 6
an R-1.
7 Q.
Does that sound right?
8 A.
Yes, that sounds right.
9 MR. McGARRY:
Would you like a copy of that?
10 Q.
Yes.
11 SHORT RECESS (10:05 a.m.)
12 CONTINUING EXAMINATION:
(By Mr. Guild) (10:25 a.m.)
13 Q.
Mr. Baldwin, you were telling me about situations where i
14 a deficiency might produce the workstoppage form, and I think 15 you identified procedure R-1, right, sir?
16 A.
Yes.
17 Q.
Tell me the circumstances under which that procedure would la be appropriate and workstoppage form initiated.
19 A.
It's easier for me to use an example of procedure.
In 20 this situation, the welding inspector supervisor discovers 21 the welding on the primary system.
Apparently this welding 22 wasn't covered by process control.
It was being done in an 23 uncontrolled manner, so he felt it necessary to write a 24 workstoppage to stop this work to make sure it was corrected.
25 Q.
You're talking about the example that was attached to the 57 g
r 1
form?
2 A.
Yes, the exhibit that was attached to this.
3 Q.
What was the deficiency that is reflected in that exhibit 4
they use there?
5 A.
I'm sure that the Q-1A or nonconforming report is not 6
attached, but that also goes with che workstoppage notification, 7
more clearly describes that deficiency.
This just lists an a
example of the serial number of Q-1A.
9 Q.
It doesn't describe the deficiency on that form?
10 A.
It just describes what was actually happening, welding 11 on the co-leg pipe to the steam generator, 1-Bl.
There's a 12 lot more information that you really need to know in order--
13 This really doesn't completely describe it, so I would assume 14 that it's not identified on process control.
15 Q.
In that form calls for description of the workstoppage, 16 that's what that says?
17 A.
Yes, just the description of what was stopped.
They 18 stopped the welding and scme problem with the welding.
19 Q.
That's not where you described the deficiency?
20 A.
No, that would be described on the Nonconforming Item 21 Report.
I 22 Q.
Tell me an example of and describe the deficiency that 23 would generate the use of procedure R-1 and the use of this 24 workstoppage notification.
When would that be appropriate?
25 A.
If it was determined that there was a generic problem with
(
58
1 procedures or the method in which the work was being performed.
2 Q.
Generic problem?
What do you mean?
3 A.
Widespread.
4 Q.
So an individual instance of a deficiency in welding 5 would not be the basis for using the workstoppage procedure?
6 A.
It could be.
~
7 Q.
When would it be?
8 A.
If the inspector discovered work that was being done that 9
he had no other means, it would be written a 0-1A or 2A, and 10 that did not stop the work.
It would be the obligation of the 11 inspector at this point to write the workstoppage notification 12 report.
13 Q.
Describe for me an example, a concrete example of when s
14 that would occur and, therefore, the procedure R-1 would be 15 followed.
16 A.
If the Welding Inspector had discovered that a welder wasn't 17 qualified for making a weld, and he had written a Nonconforming 18 Item Report, and the weider continued to make that weld, it 19 would be the responsibility of the Inspector at that time to 20 write a workstoppage notification report.
21 Q.
Well, sir, I'm trying to understand now.
In the normal 22 course of a planned inspection, an Inspector notes that the 23 weld is being welded by an unqualified welder, right?
24 A.
Right.
25 Q.
He writes an NCI at this point?
59 s
1
(
1 A.
Now let me use the example of a pipefitter making a weld 2
other than a welder.
3 Q.
So he's not even supposed to be on the weld?
4 A.
Yes, that would more clearly describe the point I'm trying 5
to make.
6 Q.
So help me with that exan gle now.
That's pretty outrageous 7
example.
That doesn't happen, does it; do you know of any a
situation?
9 A.
It could possibly happen.
I don't know of any situation 10 it has happened.
It could happen.
11 Q.
You have a pipefitter, and he's welding on the code weld.
12 A.
Yes.
13 Q.
He's not supposed to?
(
La A.
No.
15 Q.
And the inspector discovers this in-the course of a normal 16 preplanned inspection, right?
17 A.
Yes.
18 Q.
That situation you would write an NCI?
19 A.
Yes, usually.
20 Q.
Would that be according to procedure?
21 A.
Yes, it would be in accordance with procedure.
22 Q.
So he writes the NCI, but to write an NCI, the man is 23 actually-- the pipefitter is working on a weld on the pipe, 24 a code weld, and the inspector is doing normal process control, 25 and he comes over to look at it, and he says, " Hey, you're a 60
(
I I
pipetitter."
2 A.
That wouldn't be a normal inspection.
That would not be 3
normal.
If he discovered a pipefitter making a weld outside 4
of his inspection hold points.
5 Q.
So it's not to be outside of the normal preplanned 6
inspection?
7 A.
Yes.
a Q.
So, like walking through the plant, he sees somebody he 9
knows is a pipefitter and discovers--
10 A.
And he knows that man is not qualified.
11 Q.
Then what does he do?
12 A.
He would write up, normally he would write a Nonconforming 13 Item Report.
Id Q.
But the welding is going on right then?
15 A.
Yes.
16 Q.
So what does the inspector do?
'7 A.
First of all, he notifies the supervisor, his supervisor, l
'8 and the welding foreman.
I' Q.
Does he tell the pipefitter to stop welding?
20 A.
Yes.
That would be the first step,to tell the pipefitter 21 to stop welding.
He's not qualified to make a weld, and he 22 would report it to his supervisor.
l 23 Q.
What does the pipefitter do under that situation?
24 A.
He is supposed to stop.
25 Q.
Is that the job of the inspector to tell the craftsman he
(
61 l
i
'i 1
is not doing right, or he is not qualified?
2 A.
It may not be cAearly described in procedures that is his responsibility, but that is what they are normally trained.
3 If they see someone doing something that is not acceptable, 4
5 that would be appropriate to make them aware it's not acceptable, and to take correction,necessary correction and 6
action as far as necessary documentation to make sure that's 7
8 corrected.
9 Q.
Does the inspector have the authority to direct the 10 craftsmen to cease the work?
11 A.
To direct the craftsmen to cease the work?
12 Q.
Yes.
The workstoppage procedure gives him that authority, and 13 A.
/
Q-1 procedures give authority if work is not being done 14 15 correctly.
16 Q.
Let's take a concrete, specific-- the torch is on and the weld is being welded, and it's not being done by someone 17 who is permitted by procedure to do it, a pipefitter working la on a code weld, and you say the first thing the inspector 19 20 should do is he should instruct the pipefitter to stop that 21 work, correct?
22 A.
Yes.
What I want to understand, does the inspector have the 23 Q.
authority to tell the craftsman not to do the work?
24 I think that would be appropriate to say yes to that.
25 A.
62 i
~,
I 1
Q.
Where is that procedure set forth, if it is, Mr. Baldwin?
2 A.
I don't know where those specific words are mentioned.
3 I'm sure the inspectors are trained.
4 Q.
Is it fair to say there is no written procedure that 5
says that, sir, to your kncwledge?
6 A.
That may be covered in G-1 or R-1.
I can't remember the 7
specific.
8 Q.
Take a look at it, and see if you can help me find it.
I'n.
9 interested in it, if it's there.
Do you have Q-l?
10 A.
Yes.
11 Q.
All right, sir.
12 A.
Yes, that's covered in procedure R-1 in the responsibility.
13 Q.
What does that say there?
l 14 A.
This is referring to section R-1 of ASME.
Stated in 15 Section R-1, all project quality assurance staff personnel 16 or Construction engineering personnel have t ae authority to 17 stop any work being performed which is causing a condition 18 adverse to quality.
The individual who detects this work is 19 responsible for initiating Form R-1A Workstoppage Notification 20 Sheet and Form Q-1A Nonconforming Item Report Sheet, so he 21 is directed by procedure R-1 to stop the work if it's 22 adverse to quality.
23 Q.
How does he do that?
24 A.
He can do that by talking to the person and telling them 25 to stop; and in addition to that, he has to initiate an appro-
.I 63
(
I 1
priate process control and it normally would either be Q-1A 2
or R-1, excuse me.
3 Q.
What I want to understand is, is it clear to you, sir, that the inspector has the authority to verbally direct e
5 craftsmen to stop the work under the circumstances that we 6
have just described?
7 A.
Yes, if it's adverse to quality.
8 Q.
And the craftsperson is supposed to follow that instruc-9 tion?
10 A.
Yes.
11 Q.
Then he goes and gets an NCI issued, and then he goes and 12 gets a stop work order, stop work notification completed?
13 A.
Generally he puts a red tag on it, even prior to b
14 initiating the report to make sure the work doesn't continue.
15 Q.
Tell me what the red tag is then.
16 A.
The red tag, I believe, is the Q-1B tag.
It's the 17 identification of the part er material.
It's Q-1B tag, just la to flag the work that's in noncompliance.
19 Q.
With his signature on it?
l 20 A.
Yes.
l 21 Q.
What is the significance of putting that red tag on in l
22 this instance, the weld?
23 A.
That usually will stop the work so the work doesn't con-(
24 tinue.
25 Q.
What do you mean by--
64 g
l t
,_,-,m
I 1
A.
And also to identify the location.
2 Q.
It identifies it and usually stops work.
What do you 3
mean by usually?
d A.
I'm saying normally.
I don't know of any situation it 5
1hasn't stopped, but I'm saying if it doesn't, they have 6
procedure R-1 that will definitely stop the work.
7 Q.
So I mean there may be situations where the craft would 8
ignore the red tag?
9 A.
If you had an irate craftsman, but I don't know of a 10 situation.
I'm using the extreme case for an example.
11 Q.
That happened, hasn't it?
That has happened at Catawba?
12 A.
I don't know that there is any situation where the 13 inspector identified any work that was adverse to quality 14 and notified a craftsman that the work wasn'u stopped at that 15 time.
I don't know of any such thing.
16 Q.
Counsel, if we can, let's mark Procedure M-4 as the next 17 exhibit, Exhibit 1.
This is Procedure M-4 Revision 13, and l
if we can identify Exhibit 2 as Procedure R-1 Revision 9.
18 l
39 Mr. Baldwin, with respect to this specific documentation of 20 deficiencies that you have outlined, the R-2A's Nonconforming 21 Items, the Process Control forms, and the Stop W rk Notificaticn, o
22 is the Nuclear Regulatory Commission made aware of those docu-23 ments?
24 A.
I think the Nuclear Regulatory Commission is routed a copy 25 of all Nonconforming Item Reports and any Workstoppages to the
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k.
I 1
best of my ability.
2 Q.
You're responsible in part for routing those to them?
3 A.
No.
4 Q.
Do you know that to the best of your knowledge?
5 A.
Yes.
o Q.
And to whom are they routed, sir?
7 A.
That would be the site representative of the Nuclear 8
Regulatory Commission.
9 Q.
Mr. Van Doorn?
10 A.
Yes.
That's my understanding.
That's not my responsibility.
11 I'm just aware of it.
I think that's what the procedure is.
12 Q.
Does the Nuclear Regulatory Commission, Mr. Van Doorn, 13 or anyone else get a routed copy of an R-2A?
14 A.
I don't know the answer to that.
15 Q.
How about the Process Control Form?
16 A.
I don't think so.
I'm almost sure he doesn't get a copy 17 of the Process Control Form.
It's made accessible to him.
18 Q.
Do you now or did you have a responsibility or a role, 19 Mr. Baldwin, in reviewing the decision to initiate either 20 a Nonconforming Item of Workstoppage or an R-2A by a Welding 21 Inspector?
22 A.
For a period of time, it was my responsibility to do the 23 technical review uf the Nonconforming Item Report.
24 Q.
When was that, sir?
25 A.
I think that was during '81 and
'82, some period of time 66
(
1 there.
2 Q.
Describe how you performed that responsibility or what you i
3 did.
What was your job at that point in time, your task?
4 A.
It was to review the reports to make sure that the' 5
deficiency was described correctly, and it was to correct 6
means or appropriate means to handle that deficiency and if i
7 it was truly a deficiency.
8 Q.
Describe for me how you did that.
What was the process, 9
Mr. Baldwin?
10 A.
I reviewed the report to determine what portion of the 11 QA Program was violated; and if it was, was it proper or the 12 deficiency described properly with the location of it 13 adequately described.
14 Q.
By report, you mean the Nonconforming Item Report?
15 A.
Yes.
16 Q.
Did you have any role or responsibility prior to the 17 origination of the Nonconforming Item Report?
18 A.
In a sense, I guess you could say that I did have some 19 responsibility to the origination of the Nonconforming 20 Item Report.
21 Q.
Describe that for me, if you would.
22 A.
Because I had people that worked under a supervisor or 23 under me that was responsible for describing deficiencies, 24 and I was responsible for giving directions or answering any 25 questions that came up, 67 g
I 1
Q.
So during the time frame then when you were doing that 2
review, was your role or responsibility set forth in a written 3
procedure?
4 A.
Yes.
5 Q.
What procedure was that?
6 A.
Q-1.
7 Q.
Let's look at Q-1, and this is Revision 18 in front of us 8
here.
Direct my attention to the portion.of the procedure 9
that describes your responsibility at the time.
10 A.
The procedure has been revised since it was my responsi-11 bility.
12 Q.
Has that portion been changed?
13 A.
Yes.
Directly from the originator to the QA reviewer now.
(
14 So the technical review doesn't appear on the form anymore.
15 Q.
So now--
16 A.
As such, let me check the form.
No, I was correct.
The 17 form is signed by the originator and goes directly to QA review, la Q.
The originator is the Welding Inspector?
19 A.
It could be anyone that discovers a discrepancy.
20 Q.
In the case where you were involved, it would be a Welding 21 Inspector typically?
22 A.
Yes.
23 Q.
So the originator in that instance, a Welding Inspector, 24 under the current revision, the code, NCI, goes from the 25 originator to whom?
68
1 1
A.
To the QA Department.
There is individuals who have been 2
appointed the responsibility of reviewing, doing the QA review.
3 Q.
Help me find where that part of this current procedure is, d
if we can.
5 A.
That's on paragraph 5.1.8, I believe.
6 Q.
How about 5.1.6?
Go back a little further.
7 A.
5.1.6 only tells the originator he is to get a number 8
and forward that to the individual designate by QA manager.
9 Q.
Is that what you mean?
Is that the reviewer you're 10 referring to?
11 A.
Yes, and 5.1.8 gives the responsibility of the QA reviewer, 12 but that's not the same review I was doing.
13 Q.
I understand that.
(
Id A.
That has been deleted.
15 Q.
Let's take what we've got with the current revision and 16 then I want you to contrast that, but first to understand 17 what is your current procedure?
It goes from the originator is in this example, I want to follow, the Welding Inspector, to l'
the individual designated by Project QA Manager as set forth 20 in 5.1.6, correct, isn't that right?
21 A.
I was reading that.
22 Q.
It goes from the originator, and the originator forwards 23 the report to the individual designated by Project QA Manager 24 under 5.1.6?
25 A.
Yes.
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69 i-
_, - -... ~
1 Q.
Who is that individual now by title and name, if you know?
2 A.
There is five people at the site that have been designated.
3 I'm not sure I can recall all their names at this time because d
that's a recent change.
That would be Joe Willie, who is 5
Inspection Superintendent.
6 Q.
He's currently or going to be the first of July.
7 A.
He was.
He will be replaced by Jerry Goodman the first of a
July.
9 Q.
Okay.
10 A.
I believe Jerry is now appointed as one of those individuals.
31 Jerry Goodman will be the Inspection Superintendent effective 12 the first of July.
13 Q.
And Mr. Goodman is now what?
'd A.
He is now presently QC Engineer Mechanical, I believe is 15 the title.
16 Q.
And.just before you go further, are these individuals
'7 responsible for review in their areas of work?
Mr. Goodman, 18 say, in mechanical, is that the way it breaks down?
l' A.
That's normally the way it's handled, but they are and 20 can approve any of the QA review on any.NCI's that are written.
21 Q.
It's not limited to their area?
22 A.
No.
i 23 Q.
Mr. Willis?
Mr. Goodman, who else can you think of2 24 A.
R. A. Morgan.
25 Q.
Who is Mr. Morgan?
I 70
,.--i.,.
-r_
-,.,,y
.. -..m.
I 1
A.
Mr. Morgan is a QA Engineer.
2 Q.
What area?
3 A.
He is over all the QA, I believe Senior QA Engineer.
4 Q.
Okay.
5 A.
I don't recall at this time who the other people are.
6 Q.
Two others though?
7 A.
I think.
8 Q.
Any of those people have specific responsibility for the 9
welding area that you know of?
10 A.
I don't know of anyone that has specific responsibility, Il no.
12 Q.
How about specific training in the welding craft, specific 13 expertise in welding?
i 14 A.
Are you talking about all the people that are assigned 15 responsibility of doing the QA review, would you please clarify 16 your question?
17 Q.
Sure, I'm trying to understand who are the people who are 18 the individuals designated by the project QA Manager as set 19 forth 5.1.6, and you said five people were currently.
20 A.
I'm sure all of these people have had training and are 21 aware of procedures in the welding area.
22 Q.
Nobody specifically more than any other one has welding?
23 A.
I really can't speak to that.
f 24 Q.
That's how it's done now.
NCI goes from the originator to 25 one of these five gentlemen?
71 i
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I i
/
I 1
A.
Yes.
2 Q.
How recently has that procedure been adopted, if you know 3
approximately?
4 A.
Since the implementation date, and it was approved 3-11-83; 5
but I believe we have thirty days to implementation, so it 6 was this year, either March, probably in March of this year.
7 Q.
Before that, how was it done?
8 A.
The originator originated the Nonconforming Item Report and 9 forwarded that to a person that had been appointed or desig-10 nated to do the technical review; from the technical review, it 11 was forwarded to the QA Department for a QA review; and at that 12 point, it was determined who the appropriate group,usually 13 it was mechanical in Design Engineering, either mechanical
(=
14 or civil or electrical area, and it was forwarded to the Design 15 Engineering usually.
Some situations the Engineering Department 16 at the site had the responsibility of resolving NCI's also.
17 Q.
It would be the construction engineering?
18 A.
Yes.
19 Q.
QA review would make that determination?
I 20 A.
Yes.
QA also in some situations had the responsibility of f
21 NCI's.
l L
22 Q.
The procedure set forth clearly who did what when?
23 A.
Yes.
l 24 Q.
That's the previous revision to Q-l?
25 A.
As I understand.
That really wasn't my responsibility to 72 l
I i
1 know who had the responsibility to give the resolution and 2
the disposition of it.
3 Q.
I have got a Revision 17 of Q-1.
Take a look at that, and d
see if that sets forth the procedure you have just referred me 5
to.
Mr. Baldwin, is that the procedure?
6 A.
Yes, I believe that paragraph describes and answers your 7
question.
Paragraph 5.1.4 of Revision 17 of Procedure Q-1.
e Q.
That's before you go on.
Let's mark that one Number 3, 9
I'm marking it as Exhibit 3.
All right, sir, was that pro-10 vision-- how does that provision detail what your role was at 11 the time?
12 A.
Maybe I misunderstood your question, but this procedure 13 details what the QA engineer's responsibility was.
That's
(
14 what I thought you were asking.
15 Q.
Is there a description of what your responsibility was to previously in that document?
17 A.
Yes, this is paragraph 5.1.2.
18 Q.
What does that provide there?
19 A.
Review the information reported for clarity, completeness, 20 and validity.
Have needed corrections or additions made by i
21 the originator and sign and date for technical review.
22 Q.
Who is to be doing that?
What's the description in that 23 procedure of whose performing that?
24 A.
It says the originator shall sign and date to attest to l
25 accuracy of information and forward report to appropriate I
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~. _ _
1 individual in construction or QA or Project QA, excuse me.
2 Q.
Let me see that, please.
There's 5.1.lM that you just 3
read from, correct?
4 A.
Yes.
5 Q.
It's your testimony that you were the appropriate individual 6
with respect--
7 A.
Yes.
8 Q.
At the time with respect to welding?
9 A.
Yes.
Let me set the record straight.
I'm not sure that 10 this procedure describes in detail the same responsibilities 11 as the procedure that was in effect at the time that I was 12 doing that.
It was an earlier revision that I was doing the 13 review under.
\\
14 Q.
I want to be as accurate as possible.
This procedure, is this revision, this last revision was approved by QA.
16 Mr. Henry's signature appears there 6-8-82, right?
17 A.
Yes.
la Q.
Mr. Dick's 6-16-827 19 A.
Yes.
20 Q.
And the changes are indicated by that revision in the 21 right margin, correct,' by a solid line?
Is that right?
22 A.
Yes, apparently so.
23 Q.
I want to understand,that clearly.
If that wasn't pro-24 cedure that governed the way you did it when you did it, let's 25 understand which provision we should be looking at and see if 74 t
I 1 we can get it.
Let me ask you this.
First of all, look as 2 it is set forth there and tell me whether you know of any dif-3 ference between that revision one, you have now, which is 17, and the procedure in force at the time that describes the way 4
5 you perform that function?
6 A.
I would like to speak to my attorney before I answer that 7 question.
8 Q.
Sure.
9 MR. McGARRY:
The difficulty we are having and the 10 witness is having is being able to construct whether this 11 5.1.2 of Reference 17 is indeed the procedure that is germane 12 to your line of questioning.
The witness indicated he doesn't 13 think so.
I believe the question then said precisely what is 14 the proper procedure.
I think absent the witness going back and is looking at the prior revisions, we can't really go much further 16 in this.
That would take some time.
We can do it.
I leave 17 that to you.
j is Q.
Let's see if we can do this.
Move ferward.
I want to have 19 the record clear and complete, and it's probably a lot more 20 effective if the witness has the actual procedure in front of 21 him.
I really want it clear.
Perhaps I can ask some of the 22 other questions I have, and maybe we could try to find that 23 revision in the meantime.
24 OFF THE RECORD DISCUSSION 25 Q.
I don't know whether any of the questions come outside of 4
75
I i
this procedure, but it seems to me that Q-1 has changed during 2
the period this material to Mr. Baldwin's involvement in 3
reviewing welding work,particularly the late '81 on when I 4
presume most of the changes are taking place, might be con-5 venient to have as revisions available and then there won't be 6
any problems that develop about which specific one at this 7
point in time.
There are going to be specific pieces of work a
which I may want to talk to Mr. Baldwin about that may vary 9
over that period of time and for which there may be a different to revision in place at that point in time so perhaps if those 11 revisions could be found, we could have them all available and 12 wouldn't have to interrupt the questioning.
13 A.
I really feel like I have the feeling that I know the type 14 of question he's going to answer, and I really need to know 15 what the procedure says for that period of time before I can to answer the question appropriately.
17 MR. McGARRY:
We'll get those procedures.
Why don't is you continue your line of questioning and another line of 19 questioning, and we'll pick up with that.
20 Q.
Mr. Baldwin, describe for me, sir, as best you recall, and 21 what a Welding Inspector would typically do before the 22 procedure change when you had this review responsibility?
Let's 23 take an example of a situation where a Welding Inspector 24 determined that the weld is too short on a code weld according 25 to specifications, and the Welding Ins'pector determines that 76
f' I
it's appropriate to write up a Nonconforming Item Report.
When 2
would you typically find out that the Welding Inspector had 3
made that determination and how would you be involved, sir?
4 A.
Generally that would happen after the Inspector had already 5
made that determination and presented that report to me for 6
technical review.
7 Q.
The Inspector is in the plant, and he's down the hole 8
looking at a pipe and reaches a point in process control where 9
he's supposed to perform an inspection, and he sees the weld 10 is too short according to his judgment.
What does he do then 11 if he has discern that an NCI is appropriate under the error?
12 A.
As stated earlier under the Procedure R-2, it wasn't used 13 very frequently by the Welding Inspectors, so Q-1 was used in i
14 a lot of cases to handle minor discrepancies; and it was in 15 the Inspector's judgment when to write NCI's as directed by 16 the procedure, but there's a lot of room for judgment in that 17
- area, 18 Q.
So I'm asking you to presume that the Inspector exercises 19 that judgment, and he determined on the basis of his experience 20 and training and judgment that this particular weld was too 21 short, then what?
22 A.
In some cases, the Nonconforming Item Report was written 23 and forwarded to me for retlew.
24 Q.
How does he go about writing an NCI at that time?
25 A.
He states his location and on the work, describes the work, 77 g
4
,,e_.._...
,,y_
I 1
and describes what is nonconforming.
2 Q.. Does he have a piece of paper there physically with him 3
when he is down in the hole looking at the weld?
4 A.
Yes, usually he has access to it at his work location.
5 Q.
Which would be close, in close proximity to the inspection 6
site?
7 A.
Yes.
8 Q.
He goes and gets an NCI form, Q-1A?
9 A.
Yes.
10 Q.
And completes it at his work location?
11 A.
Yes, usually.
12 Q.
Then what does he do with it?
13 A.
He puts a red tag on the item that he is writing-the 14 Nonconforming Report on.
15 Q.
Tags the pipe?
16 A.
Or piece of work he has determined to be nonconforming.
17 Q.
Then what does he do?
18 A.
Then he forwards that report to me at the time.
Q.
All right.
20 A.
For technical review.
21 Q.
Where were you physically located?
22 A.
I was physically located in the main construction office.
23 Q.
So the Welding Inspector gave the paper to someone else, 24 and it came up out of the hole?
25 A.
No, in most situations, the first line supervisor was made
(
78
1 aware,the Inspector would make aware,his immediate supervisor 2
of the situation, and then the Inspector would bring the report 3
to me for review, so we could discuss any-- to make sure that 4
it was clearly understood.
5 Q.
Now, the first line supervisor, where was he located?
6 A.
He was located at one point in time in the same office in 7
another location in that same office building.
a Q.
The same as you?
9 A.
Yes.
10 Q.
In the main construction office?
11 A.
Yes, at one period of time.
12 Q.
Where are the other periods of time?
13 A.
He was located in a trailer just outside of the main office 14 area.
15 Q.
When in one and when in the other, if you can recall?
16 A.
During the period of time that I was doing the technical 17 review, I don't recall the dates, but for some period of time, 18 he was in.the main office area, and then he was relocated out-19 side that office area into a trailer, mobile home.
20 Q.
Would that have been when there was a reorganization of 21 the QA Department into QA?
22 A.
I don't think the reorganization had anything to do with 23 it.
24 Q.
But in any event, the immediate supervisor or inspector 25 wasn't in the hole or near the work location, is that right i
79
I i
typically?
2 A.
Typically he wasn't because he had inspectors covering a a
large area, so he wasn't always in direct communication with 4
that inspector.
5 Q.
The inspector physically-- he has red tagged the piece of 6
work, he has completed the QA, Q-1A form, Nonconforming Item 7
Report, and he brings it up off the job out of the hole to 8
the maintenance office, correct?
9 A.
Yes.
10 Q.
And brings it to you?
11 A.
Yes, he brought it to me.
12 Q.
He brings it to you and then you see that the NCI number la is issued, and the NCI is logged?
l 14 A.
No, that was his responsibility to get that done.
Someone 15 else had that responsibility of controlling and keeping up with 16 nonconforming numbers.
17 Q.
Who was that?
18 A.
That was someone in the Construction Department at that 19 time.
I think they called them Document Controllers was the 20 title.
I don't remember who the individual was.
21 Q.
Where were they located?
22 A.
Located in the main construction office, the same office I 23 was in.
24 Q.
They would come see you and then you would review and then 25 they would go-- the Inspector would take it to Document Control 80 i
i
I 1
and get the number issued in the log?
2 A.
Yes.
Let me make a point clear that generally it was also 3
in order to keep the first line supervisor aware of what was 4
going on, and I had requested that he also initial that form 5
so I would know he concurred with the Inspector.
That didn't 6
happen in all situations because he wasn't available.
7 Q.
So at that time, the Inspector would take the NCI to his 8
first line supervisor who would review it and initial it to 9
show his concurrence?
10 A.
Yes, and sometimes he would just talk with him on the 11 telephone and make him aware of what was going on.
12 Q.
And not initial it if he weren't available?
13 A.
No, he wouldn't initial if he weren't available.
Id Q.
Then the Inspector would take it to you, and you would 15 review it, correct?
16 A.
Yes.
17 Q.
And then it would go to Document Control or to be logged 18 and numbered?
19 A.
Yes.
20 Q.
Then where would it go from there?
21 A.
It would go to QA review, to QA Department for review.
22 Q.
As part of your review, Mr. Baldwin, would you look at just 23 the paper work that had been presented to you by these Welding 24 Inspectors?
25 A.
Usually that was sufficient to determine if it was a valid
(
81
1 NCI and everything was stated properly.
2 Q.
What, if on the basis of the paper work, you determined it 3
wasn't a valid NCI, then what?
4 A.
I tried to explain to the Inspector if I saw another way to 5
handle it.
It might have been a valid discrepancy, but it 6
might have been a much better way to handle the situation, 7
either by process control or just not accepting the work, or 8
a number of specifics.
There are a number of ways you can 9
handle it, depending on what the specific situation was.
10 Q.
If you determined it was not a valid NCI for one of those 11 reasons, would you instruct the Inspector to handle it dif-12 ferently?
13 A.
Yes.
I also make his supervisor aware of those instructions 14 Q.
How would you do that?
15 A.
Usually be telephone.
16 Q.
Is there any form or documentation which you would document 17 those instructions if your instructions were to the effect 18 that the NCI was not a valid NCI, not valid to handle as an 19 NCI?
20 A.
No, I did not document that.
l 21 Q.
What would then be done with the completed 0-1A form that 22 the Inspector had brought to you for review?
23 A.
Give it back to the Inspector.
24 Q.
What would the Inspector do with it?
25 A.
I'm not sure.
g 82 L
I 1
Q.
What was the Inspector supposed to do with it, as you 2
understood?
3 A.
Anything he would like.
There wasn't any procedure 4
requirement at that time.
He could destroy it if he liked, 5
keep it on file for his personal records if he likes.
6 Q.
Was there anyone other than the Inspector employed by 7
Duke Power Company who was responsible for maintaining a file 8
of those NCI's that were not pursued beyond that point?
9 A.
Ones that weren't approved?
10 Q.
Yes.
11 A.
No, not that I'm aware of.
12 Q.
Were copies of those unapproved NCI's filed with the 13 Nuclear Regulatory Commission?
(
14 A.
No.
15 Q.
Did you maintain any records of circumstances where 16 you determined that the proposed NCI was not a valid NCI?
17 A.
No.
18 Q.
Did you maintain any personal diary that would reflect 19 your review of these proposed NCI's?
20 A.
No.
21 Q.
Did anybody else other than the Inspectors maintain any 22 records of the proposed NCI's or your review of them?
23 A.
1 don't know.
24 Q.
To be clear in the circumstances that we're describing 25 where you reviewed the proposed NCI and determined that it was 83
.(
1 not valid, that NCI was not assigned a number nor was it 2
logged?
3 A.
No.
4 Q.
How of ten did this happen, Mr. Baldwin?
5 A.
Not very many times.
6 Q.
More than once!
7 A.
Probably.
8 Q.
More than once a month?
9 A.
No, not that I recall.
Very infrequently.
10 Q.
What would happen if the Inspector's immediate supervisor, 11 who was by this practice to have reviewed and initialed for 12 concurrence the proposed NCI, what would hhppen if the 13 Inspector's immediate supervisor determined it was not a valid 14 NCI?
15 A.
I'm sure that the immediate supervisor did this on numerous 16 occasions.
It just didn't become an NCI because he was commun-17 icating directly with the Inspector.
I'm sure on numerous 18 occasions the Inspcctor questioned their immediate supervisor 19 and he made a determination on not writing an NCI report and 20 handling it in another appropriate means within this program.
l' 21 Q.
Help me if I'm misunderstanding.
Typically what would l
l 22 happen is the Welding Inspector would note the deficiency or 23 the purported deficiency, what the Inspector judged to be 24 a deficiency, he would red tag the work, he would get the 25 Q-1A form which he would complete, he would carry that completec.
84 i
1-form out of the hole into the construction office, he would 2
go see his immediate supervisor if his supervisor was available, 3
and it would be at that point that his immediate supervisor, 4
if this-is what happened, would determine based on review 5
that it was not a valid NCI.
Isn't that the typical?
6 A.
But another side of that is the Inspector may be out in 7
the field working, and he discovers he is not real sure of how 8
to handle, and he seeks the direction of his immediate super-9 visor.
He might feel that it's a nonconforming situation 10 based on that direction and instructions at that point in time 11 that he had had, but he still may have a question so he would 12 go to his supervisor for direction prior to tagging the work 13 or writing the report.
So it could be handled that way.
And i
14 even his supervisor could, with other process that you mentionecL, 15 his supervisor could turn it back at this point which I feel sure 16 that happened on occasion.
17 Q.
You did have frequently both ways, the way you related and 18 the way I related?
19 A.
I don't know how frequently that happened.
I can't speak 20 to the frequency of how many times he did that, but I really 21 wasn't aware of all those situations that might have happened.
22 I know that very likely could have happened.
23 Q.
Either way?
24 A.
Yes.
25 Q.
So just to be clear, let's take the case I posed first and 85
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that's where a form gets written up and the supervisor is in the 2
construction office and the worker comes up with the document 3
and presents the document to the supervisor and you want the d-supervisor to initial those before you saw them, right?
5 A.
Yes, so for a couple of reasons.
To make sure he agreed 6
with it'and make sure he was aware of what his Inspectors 7
were doing.
8 Q.
So at that point, the supervisor, the Inspector's supervisor, 9
says, "This is not a valid NCI," and then the process-- the 10 conclusion of the process would be just as you described it?
11 A.
He would direct the Inspector on what-- you know, give 12 him directions on procedure, another means to handle it if 13 it was a discrepancy.
Sometimes, you know, the Inspector might 14 have determined in his own mind that something was a discrepancy is or violation of procedure which was just his interpretation, 16 but the supervisor would direct him or possibly would have 17 directed him on another interpretation of the procedure or 18 another means to handle it if it wasn't a discrepancy.
19 Q.
What I want to understand is this.
The same result would 20 occur to that piece of paper if it was destroyed at the point 21 where the supervisor-- the immediate supervisor determined 22 it wasn't a valid NCI as occurred if it got as far as you, 23 and you determined it wasn't?
24 A.
The same thing would have happened.
25 Q.
It wouldn't get a number?
(
86
1 A.
It wouldn't be documented.
It really wouldn't become a 2
record.
3 Q.
-It would be destroyed or the Welding Inspector could do d
whatever he wanted to?
5 A.
Yes, I don't feel the supervisor destroyed any.
I feel 6
sure he gave it back to the Inspector.
7 Q.
That's what I meant.
In the instance where you describe 8
the second situation where the Inspector comes up out of the 9
hole before he tags it or writes it up and asks for clarifi-10 cation, I'm thinking about an NCI-- NCI-ing this piece of work 11 and the guidance he gets from his supervisor or the direction 12 he gets from his supervisor is that that's not a valid NCI 13 and in that case, there would be no documentation at all, is t
Id that correct?
15 A.
Well, you might say that.
Our process control has a means 16 to handle that, you know.
You know you have got to sign to 37 this when it's acceptable so, therefore, don't sign it until la it's acceptable.
That could be one means or process control l'
has a rejection block;if he feels it's not acceptable, he can 20 reject it.
21 Q.
Right.
And that way it would be documented on process 22 control form?
23 A.
Yes.
24 Q.
Other than that, there would be no NCI form written at all, 25 would there?
g 87 e -, -.
.,n
i 1
A.
No, not if the Inspector was seeking direction from his 2
supervisor.
3 Q.
Now, what if the Inspector disagreed with the decision of d
his immediate supervisor or with your decision with respect to 5
the validity of the proposed treatment of that deficiency?
6 In other words, his decision, his belief, that the NCI was 7
a proper way of doing it?
8 A.
He had the option of going to the level necessary in manage-9 ment to answer his concern.
10 Q.
How did he do that?
11 A.
By going through each level of supervision that was 12 appropriate, but that wasn't always the case.
He could go 13 directly to the senior QA superintendent at the site or whom-14 ever he felt was necessary if he couldn't get his concern 15 resolved at the site.
He had the option of going all the way 16 to the president of the company if necessary.
I feel sure 17 that each Inspector had been told that.
It's not only do they 18 have the option, but they have the obligation to satisfy their 19 concerns.
20 Q.
Did you encourage them to do that?
21 A.
I don't have any objection.
Yes, I do encourage them to 22 get their concerns satisfied.
23 Q.
Did you encourage Welding Inspectors at the time you had 24 responsibility for this review, to appeal, so to speak; to take 25 their concern to the president of the company?
88 g
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A.
I don't remember directing the Inspector to that, but I 2
never had to answer that question, but I didn't have a problem 3
with that.
I would really encourage that if that was necessary m
4 Q.
You never discouraged that?
5 A.
No, I never discouraged that because I wanted their con-6 cerns answered.
7 Q.
What policy or procedure provided guidance for an Inspector 8
in that situation where he wanted to carry his concerns beyond 9
you, so to speak?
10 A.
I really don't recall any specific procedure or policy 11 at that time that we had to do that.
It was just oral instruc-12 tions to the Inspector.
13 Q.
Was there a technical recourse procedure in place at the
.g.
14 time?
15 A.
Not at the time.
I do recall, I think at that point in 16 time, we did before QC/QA merging, we did have employee 17 relations department that was open to the Inspectors.
is Q.
What was it, did they have a written policy procedure about 19 technical concerns such as disputes about NCI's?
20 A.
I don't recall that.
I'm sure there was a policy.
I 21 don't think they dealt in technical concerns.
They were pri-22 marily responsible for nontechnical concerns.
23 Q.
How about going to the Nuclear Regulatory Commission, 24 Mr. Baldwin?
Was there a policy or procedure with respect to 25 the Inspector who had the judgment that an item should be 89
(
I treated as a nonconforming item going to the Nuclear 2
Regulatory Commission?
3 A.
The Nuclear Regulatory Commission was also available to d
the Inspectors or any employees of Duke Power Company. '
5 Q.
Was there a policy?
6 A.
That policy was posted on the bulletin board.
Everyone 7
was well aware of that.
Even a toll free number, if necessary.
a Q.
Other than the notice that's posted on the bulletin board that has been testified to previously, was there any 10 other policy that you':.4 aware of that specified when and set forth the guidance for Inspectors who had a disagreement about 12 the appropriateness of treating the perceived deficiency of l3 nonconforming items?
A.
I'm not aware of any written policy on it.
15 Q.
Did you have a Welding Inspector ask you about' recourse 7
16 to the Nuclear Regulatory Commission to resolve a dispute of 17 this sort?
'8 A.
I don't recall an Inspector asking me.
It possibly could 3'
have happened, but I think the Inspector knew we had
- 4. site 20 representative of the Nuclear Regulatory Commission, and I 21 l
. feel sure they were in close contact with the Inspectors on a 22 daily basis, so I don't think there was ever any. question.
I 23 felt that the Inspector knew that he had the freedom to go to 24 the representative at' any time that he felt necessary.
25 Q.
Mr. Van Doorn you're talking about?
(
90
f 1
A.
Yes, and Mr. Maxwell probably, and Mr. Van Doorn.
2 Q.
Mr. Maxwell?
3 A.
Yes.
4 Q.
He was the previous resident?
5 A.
Yes.
6 Q.
Did you ever suggest to a Welding Inspector if they had a 7
concern about the appropriateness of treating a construction a
deficiency as a nonconforming item, they should take it up 9
with the NRC?
10 A.
Not that I recall.
11 Q.
Did you ever discourage an Inspector from taking such a 12 dispute up with the NRC?
13 A.
No.
14 Q.
Mr. Baldwin, in your function of reviewing these proposed 15 NCI's, did you ever go back into the work site and review the 16 work yourself?
17 A.
Yes.
18 Q.
Did you do that, was that common?
Did you do that?
19 A.
On several occasions it happened.
20 Q.
Would you do that if the paper work brought to you by the 21 Inspector was not sufficient to resolve the question of whether 22 it was appropriately treated as an NCI?
23 A.
Yes.
24 Q.
Tell me how you'd do that, when you did?
Tell me what you L :would do.
91 g
I i
A.
I make an effort to contact the first line supervisor and 2
the Inspector's immediate supervisor,and we go out and I look 3
at the question the Inspector raises and discuss that.
4 Q.
This would be situations where the Inspector had already 5
written up the Q-1A NCI as well as situations where the 6
Inspector might have come up with a question before he had 7
written the paper work?
8 A.
Yes, either one of those.
I have been out to look at 9
questions with the Inspector with the supervisor prior to 10 NCI's being generated and even after NCI's were generated.
11 Q.
Let's take the situation, the first one, where the 12 Inspector has written up a Q-1A and carried it to you and gone 13 through his immediate supervisor and than to you or if his
('
I4 immediate supervisor wasn't available, he came to you.
The 15 paper work was not sufficient to answer the question.
You went 16 back out and looked at the piece of work.
Would you document 17 your review of it, of the actual work that was the subject of 18 the proposed NCI?
19 A.
No.
20 Q.
You wouldn't treat it as if you were reinspecting that work 21 or inspecting that work?
22 A.
No, I would treat it as giving directions to the Inspector, 23 verbal directions.
24 Q.
Even including situations where you actually looked at 25 the code weld?
92 p
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1 A.
Yes.
2 Q.
Your initials then wouldn't appear on the process control 3 documentation?
4 A.
No.
5 Q.
Counsel, have we had any success in identifying previous o
revisions to review procedure?
7 MR. McGARRY:
He's trying to get them now, and it a
shouldn't take too long; but it could be ten or fifteen minutes 9
to half an hour.
10 Q.
Why don't we take lunch break now and come back after that?
11 LUNCHEON RECESS (11:45 a.m.)
12 13
(
14 15 16 17 l
/
18 19 20 21 22 23 f'
/
2a s'
25 s
93 8
(
I CONTINUING EXM1INATION:
(By Mr. Guild) (1:00 p.m.)
2
-MR. MCGARRY:
Back'on the record.
Let me'make a 3
statement with respect to the outstanding request and that d
is for Mr. Baldwin to review the prior revisions to 0-1 5
to deternine what was the controling procedure.
Mr. Baldwin 6
together with myself have reviwed the prior revisions to 7
Q-1 and for all intents and purposes, the revision 17 is 8
reflective of the procedure that was in affect while Mr.
Baldwin was conducting his technical review.
10 Q.
Mr. Baldwin, you didn't see any significaht difference 11 in the earlier revisions of the procedure with respect to 12 your involvement and review of the items we have talked 13 about?
O
'd A.
No, I didn't.
15 Q.
So, we are looking at revision 17 and that' does set forth 16 procedures as they involve your review of non-conforming items 17 initiated by welding inspectors, is that right?
18 A.
Yes.
19 Q.
Now, then, you have a copy of that in front of you, sir?
20 A.
No, not yet.
21 Q.
Now, if you would direct my attention to the provision 22 that in the sequential process of processing the non-conforming l
23
-- the first one that refers to work that you performed, t
24 A.
I believe that would be paragraph 5.1.2 review the infor-25 mation record it for clarify, completeness and validity.
Have v
94 l
l L
1 I
needed corrections or additions made by the originator and sigr i 2
and date for technical review.
3 Q.
All right.
d A.
Clarity, completeness and validity.
5 Q.
Provision before that 5.1.1-M under the heading " originated "
6 just on the same page, do you see that?
7 A.
Yes.
8 Q.
It states the originator shall sign, date to attest to the accuracy of the information and forward the report to 10 the appropriate individual in construction or Project QA.
11 Now, is it your testimony that you were the appropriate indi-12 vidual in Project QA7 13 A.
Yes.
4.
g-14 Q.
Now, was there an appropriate individual in construction 15 at the time?
16 A.
Yes, there were appropriate individuals in construction.
17 Q.
Who were they?
18 -
A.
I really don't know who they were.
That was for the l'
people in thee construction that generated NCI's.
Usually 20 that was in the Engineering Department.
There was a number 21 of them, of people that were appropriate to do the technical 22 review in the Construction Department.
23 Q.
As this procedure was followed and interpreted at the 24 time, the appropriate individual to whom the originator 25 in the instance of a welding inspector was to forward the
(
95
I report was you?
2 A.
Yes.
2-Q.
And, not construction?
d A.
No.
5 Q. I want to show you a document that is number of pages of 6
handwritten notes, and.ask if you can identify it.
At the 7
top it says, " Catawba Nuclear Station Lack of Support for 8
QC Inspectors and for the QA Program."
It appears to be 9
dated 1/9/82, and there are initials at the top of the first 10 page are JRB.
Can you identify that, sir?
11 A.
I don't know that I have been made aware of this.
This 12 appears to be a concern of a welding inspector.
i 13 Q..
Is there a Jack Bryant, John R'.
Bryant that is a welding s-Id inspector at Catawba?
15 A.
Yes.
16 Q.
Is he still a welding inspector at Catawba?
17 A.
Yes.
18 Q.
He was there at the time you were performing the review I'
that has been testified to?
20 A.
Yes.
21 Q.
Let me see that one second and first direct your attention 22 to a specific part of -- you haven't seen tnis document before?
23 A,
. Not that I recall.
24 Q.
Let's have this marked as Exhibit Four.
Let's look at --
l 25 it's marked at the top as page two side two.
Let me read 96 L
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1 this part for you for the record and take a look at it if 2
you like. "In initiating Q-1A's, welding inspectors have 3
been directed they must allow CRB"--those are your initials, d
aren't they ?
5 A.
Yes.
Q.
" Review Q-1A's prior to securing a serial number for them.
6 7
I do not feel this policy is in accordance with the intent 8
QA program (0-1, page 2, Rev. 13, para. 5-B. ) Also, procedure Q-l~ requires all,0-1A's to receive a serial number for all 9
10 Q-1A's initiated even though they could be voided.
L RD - " '
il t hat 's L. R. Davison?
II A.
Could be.
Q.
Do you know anybody else involved in process of reviewing 13 Id NCI's,and the welding area who initials are LRD?
15 A.
No.
I6 Q.
" Slash CRB," anybody else with those initials besides 17 yourself?
18 A.-
No.
19 Q. "LRB/CRB does not follow this criteria.
After reviewing 20 Q-1A pro blem and they do not agree that it is a problem. "
21 Further, reading from this document, "After reviewing 0-1A 22 problem and they do not agree that it is a problem, their 23 practice is to discard the NCI without a serial number (Q-A 24 procedure Q-1, page 3, Rev. 8, paragraph 5.1.4)."
Take a-25 look at that and review that.
Is that an accurate description 97
(
I 1
of your involvement at the time in reviewing NCI's?
2 A.
I think that's probably true at one time, yes.
3 Q.
Was it true for a significant period of time, for the d
period of time you and I have been talking about before, 5
before this procedure changes have been made?
6 A.
Yes.
7 Q. If you would hand thar back to me.
With reference to a
paragraph 5.1.4 of Q-1, and that's the revision 17 is what 9
I have, but I'm informed the procedure consists of the proce-10 dure that was followed at the time.
Let's take a look at 11 that 5.1.14, and Mr. Baldwin, tell me how it's consistent 12 with that provision of the procedure for you to instruct a 13 welding inspector to void an NCI prior to that NCI being I
14 numbered and logged?
15 A.
5.1.4 revision 17 of Q-1 is referring to Project QA 16 Eng ineer Review which wasn't my review.
17 Q.
Yes, s ir, if a report is determined to be non-valid and 18 shall be signed, filed and no further action taken?
19 A.
That's 5.1. 2 paragraph B.
20 Q.
I'm reading from 5.1.4.
21 A.
Okay, that is also -- that's the responsibility of 22 the Project QA Engineer.
He has that responsibility.
The 23 QA Engineer could also review this and determine it to be 24 non-valid.
25 Q.
But, if the QA Project Engineer determines it to be p
98
I non-valid, it's not to be destroyed, is it?
2 A. No, it's not.
3 Q. Non-conforming item report is to be as it states there completed?
5 A.
Yes.
Q.
And, signed?
7 A.
I'm not aware of any that got to that stage that wasn't a
handled in accordance with the procedure.
O.
Where does it state in this procedure that if you, in 30 your stage of review, determine that the NCI is non-valid,
that it should be destroyed or that it was determined to be 12 non-valid that it should not be handled consistent with the
'3 way it is handled at 5.1.4.
That is completed, signed and
\\
filed for no further action.
15 A.
I didn't determine it to be non-conforming item or valid I6 NCI or a non-conforming item report until it was serialized, l7 I felt the supervision had the responsibility to review what is the inspector was doing and give him directions.
Q. Without writing the matter up?
20 A.
Yes.
21 Q.
Is it your opinion, Mr. Baldwin, that that procedure 22 that you followed was consistent with the provisions of Q-l?
23 A.
I 2elt that it was at the time.
24 Q.
Did any of your supervision ever instruct you to follow 25 the procedure you did follow and provide you guidance to the 99
(
l I
af fect that that procedure was consistent with Q-l?
2 A.
The procedure I followed was the procedure that had 3
been followed by the responsible people prior to my having d
the responsibility of doing the technical review, so I 5
didn't have any reason to feel really that was my interpreta-6 tion.
I felt that I was following the procedure.
7 Q.
It had been done prior to your doing it that way?
8 A.
Yes.
9 Q.
Who had done it before that you are aware of?
10 A.
Larry Davison.
11 Q.
When was Mr. Davison responsible for performing that 12 revie w?
13 A.
Prior to me doing that.
That was from the time that he ld was employed at the Catawba site until he was transferred to 15 the general office' when he was transferred to general office.
16 I was then designated as that individual for my area.
17 Q.
What period of time was Mr. Davison have been responsible
'8 for doing the function that you did after him?
19 A.
What period of time was that?
20 Q.
Yes, sir.
21 A.
I think that was from '75 until '81, I think.
22 Q.
From the beginning of construction --
23 A.
From the beginning of construction until he was transferred 24 to the general office.
I don't remember a specific date on 25 that.
100
(
I 1
Q.
This is the first pageof that same document that has been marked and identified as Exhibit Four.
Again, Mr. Bryant's 2
1 3
notes.
Let me ask you this.
Do you recognize this as Mr.
e d
Bryant's notes?
Do you recognize his handwriting?
5 A.
It appears to be, yes.
6 0
The first page of that document, the third paragraph, 7
" Upper management (LRD ) ", Larry Davison, JW," and who would 8
JW be?
Do you know anybody with the initials JW?
9 A.
Joe Willis, but I don't know why he would be referred 10 to.
11 Q.
How about Mr. Wells, James Wells?
12 A..
It could be Jim Wells.
13 Q.
"LRD, JW and CRB," Charles R. Baldwin,) " stated that they
(
14 reserved the privilege to make any decision that even maybe 15 unconforming to the Duke QA Program without necessarily explain-16 ing or convincing their decisions to the QC Department."
17 Have you ever expressed that view in substance to anybody?
18 A.
I don't recall that.
19 Q.
Is that an accurate statement of your understanding at 20 the time?
21 A.
No.
22 Q. What wron 'g with that?
23 A.
I don't feel that I reserve the privilege to not explain 24 anything to the inspectors.
I feel that is my obligation to 25 explain the best that I can any situation that involves their 4
102
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I 1
job or management procedure.
2 Q.
Did you feel it was within your authority to make decisions 3
about procedures even where those procedures did not conform d
to QA program?
5 A.
No.
o Q.
Looking at the following paragraph. "QC welding have been 7
instructed by LRD," Larry Davison, "CRB," yourself, "that a
the directions given on Ol-A resolution are of no concern 9
to them.
(It has been noted QC inspectors that many Ol-A 10 resolutions do not address the stated problem or resolve 11 the problem within the intent of the QA program. )
Unqualif ied 12 personnel and lack of support for QA/QC upper management 13 (LRD, CRB) want to give verbal direction but do not necessarily
(
14 take responsi bility for them.
Example," and an example 15 follo ws.
Can the record reflect.the identify of the two 16 gentlemen who have just come into the room?
17 MR. GIBSON:
Mr. Guild, these are law students who 18 are employed with Duke Power Company this summer and as a 19 part of their effort to learn something about what goes on 20 in the legal department of a power company, we suggested 21 they sit in on some of your examination if you have no 22 objection to that?
23 Q.
I don't have any problem if they identify themselves.
24 by name for the record.
I would appreciate it.
25 MR. ADAMS:
Glen Adams.
g 103
1 MR. BURGESS:
Ken Burgess.
2 Q.
Let me get you to examine that.
There is an example 3
that follows, Mr. Baldwin, but I'm concerned primarily about 4
the general observation, the last paragraph, and it spills 5
over a little bit.
Is that an accurate description?
6 A.
Accurate description of what?
7 Q.
Of what is set forth there?
8 A.
I don't really understand what he is saying.
I don't 9
see it that way.
That is his opinion of something, and I 10 can't tell you why he has that or what he formed that opinion 11 by.
12 Q.
I respect your prerogative to disagree with the gentlemen, 13 Mr. Baldwin, and I would like for you to express that opinion,
(-
14 but I would like to understand, first of all, have you read 15 those concerns and that comment and that opinion as expressed 16 to Mr. Br yant.
Do you agree with it or disagree with it?
17 A.
I disagree with what he is saying.
I don ' t know that --
18 I wasn't aware that he was told that.
19 Q.
You are not aware of either yourself or Mr. Davison 2e instructing welding inspectors that the directions given on 21 Ol-A resolution are of no concern?
22 A.
They were told that the resolutions of Q-1A wasn't their 23 responsibility, and they did have additional informatio-that 24 might change that resolution, it was their responsibility to 25 bring it forward.
104 l
t.
(
I Q.
If it wasn't their responsibility to resolution of NCI's, 2
why was it their responsibilty in your opinion, Mr. Bald win,
3 to provide information that would change the resolution?
d A.
Sometimes there's a very difficult for the inspection to 5
explain clearly and include all of the facts that might per-o tain to the resolution so therefore, when the resolution 7
was sometimes made, enough information might not have been a
given to explain the situation from the point of view that 9
they saw it.
10 Q.
Make that a little more concrete for me.
What was the 11 inspector's responsibility with regard to describing the 12 resolution of an NCI?
13 A.
To make sure the problem or discrepancy was clearly Id descr i bed.
15 Q.
The inspectors responsibility was to describe the discre-16 pancy?
17 A.
Yes.
18 Q.
Kas he responsible in any manner in your judgement for l'
describing the resolution?
20 A.
Not procedurally, no, not the resolution.
If after the 21 resolution was determined and the disposi ion was put on 22 the NCI and the inspector thought that the person that put 23 the resolution on the NCI had not covered all the concerns 24 that the inspector had at the time that it was written, he 25 had an obligation to make sure that that was understood and 105 g
(
1 brought forth so that it could be dealt with.
2 Q.
Bu t, it is accurate or fair to say that the policy as you 3
understood it was that inspectors' responsibilities did not d
include the resolution of the NCI?
5 A.
No, it wasn't their responsibility to resolve the NCI.
6 Q.
How would they in the course of procedure be informed 7
about the sp cifics of a resolution of the NCI?
e A.
Because the resolved NCI was routed to them.
So, some 9
situations they did have responsibility that you would take 10 part of the corrective action on that NCI and inspections 11 where it might be involved as the discrepancy was corrected.
12 Q.
If they weren't involved in inspections, re-inspections 13 as the discrepancy was corrected, would the NCI be resolved?
l#
I mean would the NCI with resolution be routed to them?
15 A.
Yes, because in most situations they had the responsibil-16 ity of removing the tag af ter it was resolved because they 17 were the person that had originated that and they knew the is location of it, so they would be aware of that.
l' O.
Counsel, just to follow this, these identified exhibits 20 we intend to attach to the record of the deposition, I guess 21 for convenience if the court reporter attaches them to your 22 copy then it's the formal written transcription will have 23 them all.
I'm going to show you a document that is an 24 exhibit to a previous deposition, Mr. Bald win.
This is a 25 docum mt that has been identified as Exhibit Ten to Mr. A11um's
(
106
l deposition, and it's notes -from a welding inspector named 2
y, C. Godfrey.
Is Mr. Godfrey a welding inspector at 3
Catawba?
A.
He was.
3 Q.
He transferred back to welding?
6 A.
Yes, at his request.
7 Q.
Under the heading NCI number 7850, it reads as follows, 8
" Lower pressurized support. Welder overlapped weld to another without getting the pre-heat signed of f.
It (the weld) over-IO lapped about seven inches, but the NCI stated only one inch.
This was written by tech support.
David Gadd stated that 12 he took the welding foreman's word on the amount of the over-
'3 lapped weld.
He also stated that he had no problem with the pre = heated material. " I'm sorr y, "the non-preheated mater-15 ial.
Charles Baldwin told QC welding to remove tag, but then removed tag himself and told QC welding to sign off weld.
Beau Ross also had a note of this action.
I have had several 18 NCI's that I have written, got approval from Beau, but yet trashcanned by Charles Baldwin or Larry Davison.
In Q-1 0
procedure, it states that after an NCI has been written, a 21 number may be obtained.
They never let me get a number on these items."
Take a look at that, Mr. Baldwin, and I 2
want you to tell me whether that is an accurate description, accurate statement, sir?
25 A.
That pressurized support involving that, I can only speak
(
107
l 1
to the f act that NCI was written.
That h was resolved by 2
the appropriate people.
I talked with Mr. Ross.
They wanted 3
to continue work on that, and I talked with him and asked 4
him to remove the tag because the work was to be continued 5
because it had been properly handled by the program and re-6 solved by the appropriate people and he said he would do that.
7 Several hours later, he hadn't removed that, and I couldn't 8
get in touch with him, so I went out and removed the tag and 9
signed of f the NCI that the tag was removed because the NCI 10 was properly resolved.
I didn't have any idea where he was 11 at.
12 Q.
Tell me what you can recall about the recolution of 13 that NCI.
I 14 A.
All that I recall is that there was no re-work as a 15 result of the resolution.
16 Q. Did you approve that resolution?
17 A.
It wasn't my responsibility to approve thn resolution.
18 Q.
Who approved it?
19 A.
That was approved by David Gadd and I'm sure it got a 20 QA approval also.
21 Q.
Did you review the NCI when it wc; presented to you by 22 the originating welding inspector?
23 A.
I don't recall that.
I might have.
24 Q.
Is this an acceptable procedure to take the welding 25 foreman's word on the amount of over-lapped weld?
1 08 g
1 A.
I can't speak to that.
2 Q.
Why not?
3 A.
It wasn't my res pnsibility.
I didn't take his word.
4 I don't know if that was a true statement or not.
5 Q.
IF that is a true statement, is that an acceptable pro-6 cedure as you understand?
7 A.
I would have to have specifics on that.
I don't know 8
what the specific situation vould be in that situation.
If 9
I was resolving, I think I would do that, but I really don't 10 know all the other related information that he might have 11 had.
12 Q.
How about the reference to the non-pre-heated material.
13 Is that reflective of a proper procedure for handling an NCI?
(
14 A.
I can't speak to that.
15 Q.
Why not?
16 A.
It wasn't my responsibility to make that decision.
17 Q.
Was it proper for you to remove the tag?
18 A.
Yes.
19 Q.
Is that consistent. with proper procedure?
20 A.
Yes.
That's not normally the way it's done, but it is 21 proper.
22 Q.
Is there a written procedure that provides the basis 23 for that authority tqat you know of?
24 A.
A lot of the NC1 esolutions were given a code number for 25 responsibility and a lot of those code numbers were my code i
109 i
1 number, and I just passed that on the toe supervising tech-2 nician who would pass it on to the inspector directly.
3 Q.
Help me understand what that means.
4 A.There~ was a code like QCWD instead of putting names down 5
for responsibilities, they would give a code.
6 Q.
And the code would be?
7 A.
QCWD which is supervising technician the code would be 8
SVTW.
9 Q.
What does QCWD indicate?
10 A.
Thatindicated my position of technical supervisor welding 11 and NDE.
I'm not sure what this particular NCI had on it.
I 12 don't know what code it had on it, but it was my responsibility 13 as f ar as removing the tag, my overall responsibility.
14 Q.
When you removed the tag that allowed the work to continue 15 on the component?
16 A.
Yes.
Q.
Where is the lower pressurized support or the piece of 18 work that was the subject of the NCI located?
19 A.
I believe that was located outside of Unit 2 reactor 20 building at the time.
21 Q.
Hadn't been installed yet?
22 A.
I'm sure it has been installed now, but at the time they 23 were f abricating it outside of the building.
24 Q.
Your belief is that the pressurizer to which the support 25 was attached has been installed in the f acility?
l 110 I
1'
I 1
A.
Yes.
2 Q.
Do you know whether or not the lower support is accessible?
3 A.
I'm sure it is.
Q.
Not under concrete or anything?
d 5
A.
No, it's not under concrete.
6 Q.
Which unit was this now.
Do you remember?
7 A.
I ' believe this was Unit 2.
8 Q.
When you removed the tag from the component, Mr. Bald win, 9
did that end the process for resolution of that NCI?
10 A.
The process for resolution was ended prior to me removing 11 the tag.
I wouldn't remove the tag unless the resolution 12 had been stated on the NCI and properly approved.
13 Q.
No further action was required then with respect to 14 that component?
15 A.
I had to sign the original copy, the record copy of the 16 NCI that I had removed the tag, and I did that.
17 Q.
Nothing further with res=ect to that component?
18 A.
I'm not aware of any other.
Let me correct that.
Q.
Sure.
20 A.
I believe that was one of the Task Force evaluation or 21 concerns of that particular inspection, and I think additional 22 work was done,bd>t I'm not sure to evaluate that concern.
l 23 Q.
Is this an accurate description in substance that the 24 rest of that paragraph -
"I have had several NCI's that I 25 have written, got approval from Beau and they got trashcanned I.
111
1 by Charles Baldwin or Larry Davison. "
2 A.
I have never thrown an NCI in the trashcan.
3 Q.
Do you know whether Larry Davison has?
4 A.
I'm not aware of any that he has.
5 Q.
Would it be accurate to say that you voided NCI's under 6
those circumstances?
In other words, af ter sthey have been written and gotten approval from the first line supervision 7
a in this case, Beau Ross, but before they have been logged 9
or had a number issued and you turned the paperwork back to 10 the inspector for him to do with as he pleases and he can-11 throw it in the trashcan?
12 A.
Yes, I think that's an accurate description.
13 Q.
Mr. Baldwin, I want to show you another document previously 14 id entified.
This was marked as Exhibit Twelve to Mr. Allum's deposition, and are more notes from inspector -- I'm trying 15 16 to r emem ber.
I think these are further notes from Mr. Bryant.
I'7 Can you identify those as Mr. Bryant's notes?
Do they appear 18 to be Mr. Bryant's handwriting?
19 A.I can't say that it is not.
I couldn't say that it is.
20 Q. Okay.
Have you ever seen those before?
21 A.
I have seen some of these things that are mentioned in 22 the other concern, but I haven't seen this particular.
23 Q.
f You haven't seen those notes before as far as you can 24 remember ?
25 A.
I don't recall.
g 112 l
l 5
k
(
1 Q.
Hang on to it there.
I have a copy.
Let's look at 2
the first item on there dated 6/15/81, incomplete fusion 3
(per visual found in weld 1-37) (M-19) visually CRB,"
d Charles Baldwin," instructed me to accept the weld per NDE 5
30J criteria.
Violates - " can't read the rest --
6 A.
L80 it appears to be.
7 Q.
Is that accurate?
8 A.
No, it's not accurate.
9 Q.
What is wrong with it?
What is incorrect?
10 A.
I did not instruct them to accept the weld.
This wd1d 11 was in que3 tion.
12 Q.
Yes.
13 A.
And, Beau and I evaluated this situation with NDE 30J Id which is a liquid penetrate, surface inspection method.
NDE 15 30J is acceptance criteria within procedure.
It's used 16 to do surf ace inspection of welds and done af ter the visual 7
inspection, and it's a more sensitive test to discover lack is of fusion, cracks or this type of thing that is not visually 19 would not be detected.
So, he had a question on incomplete 20 fusion on this particular weld.
The weld previously had 21 been visually inspected by a certified visual inspector and 22 had previously been inspected by a certifi e3 NDE inspector.
23 Some repairs, some minor repairs, had been made.
24 Q.
To the weld?
25 A.
To the weld as a result of the NDE inspector and Mr.
l-113
l I
~
1 Bryant was called to verify that no welding or to do the 2
inspection of the repaired areas of this weld, and he had 3
rejected other areas that had previously been accepted by visual inspector and NDE inspector.
d 5
Q.
At the time of his inspection?
6 A.
At the time another inspector inspected that weld.
Two 7
other inspectors, NDE and visual unspector.
I had concerns a
that the visual inspector prior to him had done hic job.
9 I had concerns the UDE inspector had done his job adequately.
I 10 If there was incomplete fusion in that weld, I wanted to 11 know what the problem was.
Through inspections, visual and 12 NDE inspection, so I felt it was appropriate to get the weld 13 reinspected with NDE method, the liquid penetrate method 0
4 14 to determine if there was an incomplete fusion.
Mr. Ross was 15 present. NDE inspection was performed.
I o bserved the in-16 spection along with Mr. Ross.
There was no rejectable indi-17 cations discovered as a result of that reinspection in that 18 area described by Mr. Bryant.
So, I gave directions to Mr.
19 Ross to correct the problem with Mr. Bryant.
I did not talk 20 with Mr. Bryant directly about the situation.
I didn't 21 have any -- Mr. Ross appeared to agree with my instruction 22 that I was g,iving him.
23 Q.
Did Mr. Bryant note a deficiency?
24 g,
- 7. didn't hear any more a bout it until the concerns were 25 presented 'to management of the inspectors and that came up i
4 114
~
I t hen.
2 Q.
Did Mr. Bryant note a deficiency on his rejection?
3 A.
He approved the weld with the note on the back saying 4
I had directed him to sign a weld off which wasn't a true 5
statement.
6 Q.
You directed Mr. Ross?
7 A.
I directed Mr. Ro ss to take care -- in my mind, I had a
verified there wasn't any incomplete fusion in the weld 9
because NDE, the liquid penetrate is a more sensitive test 10 than the visual inspection.
He was detecting this visually.
11 Q.
You directed Mr. Ross to direct the welding insoector 12 to sign off on the weld?
13 A.
I told him to take care of the problem with Mr. Bryant t
14 or explain to him we had done another test and the test --
15 the results of the test were acceptable.
16 Q.
Did Mr. Bryant orig'inate a deficiency notice?
17 A.
No.
s 18 Q.
Did he originate an NCI?
I' A.
No.
20 Q.
Did he inform you or anyone else that he desired to 21 originate a deficiency notice?
22 A.
Not that I'm aware of.
23 Q.
Or NCI?
24 A.
All I'm aware is he put a note on the back of the process 25 control that I had directed him to sign the weld off per i
115
I 1
NE 30J criteria.
2 Q.
How did this weld inspection come to your attention?
Not 3
the original one, but the one by Mr. Bryant.
4 A.
How did it come to my attention?
5 Q.
Yes.
6 A. Through the welding general foreman.
7 Q. How did that happen?
8 A.
He gave me a call on the phone and said you have an 9
inspector that is rejecting work already accepted.
How a bout 10 looking it.
So, I went by and got Mr. Ross and we went down 11 and looked at it.
12 Q.
Had Mr. Bryant -- how had he rejected the work?
13 A.
I think he had indicated rejection in the areas he didn't 14 feel were acceptable on the work himself.
I'm not sure how 15 he handled that on process control.
I'm not sure if he just 16 refused to sign the process control or if it was indicated 17 what the reasons for rejection was.
I don't recall.
18 Q.
You didn't see any paper work?
19 A.
I saw the paper work.
I looked at the paper work to see 20 who the inspectors were who had done the previous inspection.
21 My concern was if he was true -- if he was correct, h is 22 judgement, we had a potential pro blem, and that was my primary 23 concern in determining if the other inspections were 24 deficient, and the retesting to me, to me, proved the other 25 inspections were acceptable.
116
I i
Q.
What about this.
So, I can understand, Mr. Baldwin,
2 a lot of this is a long time ago.
This particular one seems 3
to stick very clearly in your mind, is that a fair statement?
4 A.
Yes.
3 Q.
What about the identification?
You hadn't seen these 6
notes before, and it's two lines.
What a bout that two line 7
description brings back so clearly the details of this a
specific?
9 A. Because I was aware of it.
This question wasn ' t resolved.
10 It was evaluated for some period of time before a final it decision was every made.
Ho wever, I wasn't directly involved 12 in the resolution and investigation into this.
I know it 13 went to the top level of management even design.
A lot of f
14 letters were kTitten and apparently -- a lot of people were 15 involved in it.
I don't know specifically, but I was aware
- 6 there was a lot of attention to this particular item.
17 Q.
What is identifying about this particular item on the is document that we are looking at here that brings all that 19' to mind?
20 A.
This particular weld on M-19.
That 's usually -- M-19 21 that is the procedure that covers containment plate welding, 22 and there's really not that many controversial situations 23 I don't think that came up about that procedure.
24 Q.
This is plate --
25 A.
I just remember this is a plate on the steam generator 117' l.
1 down tank or blow down tank.
I'm not sure what the proper --
2 Q.
Is that a code weld?
i-3 A.
It i s not.
I think this was built to ASME section eight 4
of the code.
5 Q.
Nct an M-4?
6 A.
No, not an M-4.
7 Q.
The next, are you familiar with the recommendations of 8
the Welding Task Force with respect to the resolution of 9
technical concerns of the welders?
10 A.
Yes, I'm aware of it.
11 Q.
Let me direct your attention to table two, welding inspec-12 tion, and It's item under the heading specific action recommen-13 dations.
Item seven.
Pbuld you read that for me for the s
Id record, please, sir.
Item seven in the left-hand column.
15 A.
" Duke level three reinspection steam generators welds-i 16 for acceptibility (R-4 9). "
17
(
Q.
Did you know that recommendations was to conduct that re-18 inspection?
j 19 A.
To conduct reinspection?
20 Q.
As indicated?
That is this weld in this piece of equip-21 ment, is it not?
22 A.
I assume it is.
The only one I'm aware of there is in l
23 controversy.
24 Q.
Do you know that they recommended the reinspection that 25 is indicated there?
(
118 l
l
-e_.
y
,-,,4
~,-
, - ~
~ -, -
s--
w
't
I I
A.
I knew a lot of people had looked at the weld, design 2
engineering, level three, several people had looked at the 3
weld.
Q.
What is level three inspection?
5 A'.
Level thre e i s really a designated -- this particular 6
situation is the highest level of inspector.
Q.
That's the certification level?
8 A.
That' s the certification level.
O.
Second item on what has been marked as Exhibit Twelve I0 to Mr. Allum's deposition, 6/18/81, appears to be weld 43-27 12 A.
Yes.
3 Q.
M-19 was found to be welded downhill with GTAW process.
CRB, Charles Baldwin, would not let me issue a Q-1A, bu t t he is craf t corrected the problem by welding over the top of the 16 previous weld.
Is that accurate?
A.
No, it's not accurate.
Q.
itat is wrong with that statement?
A.
I did not talk to Mr. Bryant about this weld.
I talked 2
with 't. Ro ss.
I assume this is the same weld I recall.
C.
E it accurate you wouldn't let Mr. Bryant issue or origin-
,. c e..cn-conforming item on this matter?
23 A.
If this is the same situation I recall, Mr. Ross called 24 me on the phone and said that Mr. Bryant had found a small area 25 a bracket, I think it was in the same blow-down tank, where the 119
1 steam generator blow down tank.
They were welding a bracket 2
on the wall, a liner plate on this tank, and they had welded 3
up one side across the top and welded about a half an 4
inch down the other side.
This is in violation of the 5
process spec to weld downhill.
Procedure hasn't been approved 6
to allow this.
Mr. Ross wanted my concurrence to allow the 7
craf t to remove the weld and make it correct before signing 8
the weld off.
I concurred with his judgment on that.
I 9
did not talk specifically to Mr. Bryant about this.
10 Q.
Did you know whether or not Mr. Bryant originated a non-11 conforming item Q-1A with respect to this matter?
12 A.
He did not at this time.
I think a Q-1A was originated 13 after the welding inspector concerns is the way I understand 14 it.
I'm not sure on that.
15 Q.
What is a GTAW process?
16 A.
That's an abbreviation for gas tungsten arc welding.
I'7 Q.
Why aren't you suppose to weld downhill with a gas 18 tungsten arc welding process?
l 19 A.
Because the procedures had not been qualified to allow 20 that.
21 Q.
Is there any effect on the quality of the weld?
22 A.
It could have if it hasn't been approved.
This is one --
f 23 I'm not sure if this is what they call an essential variable 24 or non-essential variable.
There is a lot of variables that 25 have to be proven in welding procedure and this is not one 120 l
I
l 1
that had been proven so whether we could say it was or wasn't, 2
it just did not conform to the procedure.
3 Q.
You don't know whether or not it affected the quality 4
of the actual weld?
5 A.
It may or may not have but it wasn't part of thn procedure, 6
so, therefore, should be removed or justified.
7 Q.
What about the reference to correct the problem by 8
telding over the top of the previous keld?
9 A.
I have no knowledge of that.
10 Q.
Do you know how that weld was corrected?
II A.
No, I do not.
12 Q.
Do you know whether it was?
~
13 A.
No, I do not.
V Id Q.
Third item on that list looks like 2/10/81, pin hole on 15 route of
-e can you make out that word?
16 A.
Half coupling.
17 Q. One A deisel generator room accepted by CRB because of no 18 guidelines and QA procedure L-80.
Is that an accurate 19 l
statement?
i 20 A.
I talked with Mr. Brown about this.
21 Q.
Is that accurate?
22 A.
He wanted to write a non-conforming item report on it 23 for perocity.
He first called it lack of fusion in the pin 24 L
hole in the root of the weld.
This wied had been made acces-l 25 sible because they had cut out an adjacent piece of pipe and l
121 i
i I
his instructions were to inspect any welds that were made 2
accessible as a result of cut outs.
As I recall, this was 3
on a carbon steel class C line or piping system.
Mr. Ross 4
was not available.
That was the reason I was directly 5
involved with Mr. Bryant.
I went out to the location of the 6
weld and was able to' convince apparently Mr. Bryant that there 7
was no lack of fusion. He didn't state it in his concern, and a
then the other concern he had was a poor perocity.
Just as 9
I recall maybe greater than a sixty-fourth of an inch, one-10
. fourth perocity that was visible on the I.D. of the weld.
11 Q.
That's a pin hole?
12 A. That is what he classified as a pin hole.
I classify it 13 as perocity.
Id O. That 's the same reference.
You are referring to perocity is and he is ref erring to a pin hole?
16 A.
Yes.
That procedure L-8 0, this was acceptable which was 17 the procedure that he was inspecting to.
18 Q.
What is procedure L-80?
19 A.
I believe that is the correct title.
It's visual workman-20 ship standard for welds.
21 Q.
Were there no guidelines at that time in procedure L-80?
22 A.
On perocity, no.
23 Q. That in your judgment made the weld acceptable?
24 A.
Yes.
Mr. Bryant continued to pursue his concerns, and 25 I explained to him that this meets, there is really no guide-1 122
I lines on perocity for visual standards and procedure at that 2
time, so I told him I would get further explanation of why 3
that wasn't in the inspection procedures, so I went to the d
QA Tech Support Group.
5 Q.
Just to get clear.
This is at the time that he made known 6
to you that he intended to initiate an NCI on this or much 7
later?
8 A.
No, this was the same.
This is the same time frame.
I 9
told h im I would carry his concerns further and try to get 10 him an explanation of the procedure, why it didn't refer to 11 perocity at that particular time.
I still don't think there 12 is any criteria in L-80 at this time for perocity on that 13 particular ASME section three piping welds.
I pursued that 14 through the QA Technical Support Group, and I believe even 15 had Mr. Bryant to come to the office and review the codes to and that was explained to him as I recall.
I made a special 17 trip out to the field that day or some after he had been 18 explained to him and he was still concerned, and he said he 19 didn't agree with the codes and he wanted to -- he was consider-20 ing taking it to the NRC.
21 Q.
Did he do that?
22 A.
I'm not sure.
23 Q.
Did you ever hear about it from the NRC?
24 A.
No, I did not.
Not as I recall.
I Pclked to the NRC 25 on a couple of questions they had, but I don't recall the 123
L 1
specifics.
2 Q.
Help me understand this.
Did Mr. Bryant red tag this 3
particular piece of work?
4 A.
No, he did not.
5 Q. Did he write up a Q-1A?
6 A.
Not that I recall, no.
7
.Q.
Did he come see you at your office?
8 A.
No, I 5ent out to see him at the work location.
9 Q.
How did you learn of his desire to initiate an NCI?
10 A.
Through welding foremen.
11 Q.
How did you learn it.
What did you say?
12 A.
He said John Bryant, you know, is wanting to non-conform 13 a weld as a result of the cut out that was able to inspect, L.
14 and I would like to get you to look at it.
Mr. Ross was not is available, Mr. Bryant's immediate supervisor, so I felt an 16 obligation since Mr. Bryant was under my area of responsibility 17 to go out and look at the weld.
18 Q.
The craft supervisor called you up?
19 A.
I don't know if he specifically called me up.
I happened 20 to be at the location the supervisor was at and he was talking 21 to his general foreman or superintendent or something and he 22 mentioned it, and I said, "Well, let's go out and look at it."
23 Q.
Who was the welding foreman, do you recall?
l 24 A.
B. J. Myers, I believe was the welding foreman.
That's l
25 his initials.
I don't know what his name is.
l 124 r
I Q.
No NCI was ever initiated on this?
2 A..
Not to my knowledge.
3 Q.
We have a cross-reference here to -- if you look on Exhibi:
4 Four, page ten of twelve, let me show you another document here.
5 This is another series of notes.
I think they are also Mr.
6 Bryant's and can you identify that.
Does that appear to be 7
Mr. Bryant 's handwriting.
8 A.
It appears to be, yes.
9 Q.
Page ten of twelve of this document, list of items, under 10 the heading, " Lack of support for the QA Welding Inspectors 11 in the QA Program," and look at this item here and it has 12 been marked in pencil or pen D-24.
Does that appear to be 13 the description of the same weld we have been talking about?
Id A.
Appears to be, yes.
15 Q.
I believe Mr. Baldwin, that those numbering systems are 16 keys to the recommendations of the Welding Inspector Task 17 Force.
Now, look at item number five under table two, 18 welding inspection and the report of that Task Force and in l'
parenthesis the number D-24 appears.
For item five, does it 20 not?
At the end of that item?
21 A.
Yes, D-24 does appear there.
22 Q.
Wbuld you read that, please?
23 A.
" Retrain craft on need for interpass cleaning to renove 24 obvious defects.
Insure adequacy of existing procedures.
25 D-24."
125 t
1 Q.
Are you aware that that recommendation resulted from 2
that concern by Mr. Bryant?
3 A. This doesn't appear to be speaking to the same concern.
4 I'm not sure there may be other concerns that are part of 5
that.
6 Q.-
D-24 is the notification that appears by the description 7
of the item that I showed you just a minute ago.
The pin a
hole on roof of half coupling accepted per directions of CRB 9
because no guidelines in L-80, one A diesel generator.
10 A.
It was accepted because it met the acceptance criteria.
11 Q.
You have explained that, but D-24 does appear by that 12 description of that item, doesn't it?
13 A.
It appears to be, yes, t.
14 Q.
Retraining craft on need for interpass cleaning to 15 remove obvious defects and insure adequacy of procedure 16 doesn't have anything to do with that, does it?
17 A.
I really don't see how that could be related to it.
18 Q.
I don' t e ither.
I understand there has been some transcrip-19 tion errors in noting those recommendations.
I don' t know 20 if this is one of those or not, but that doesn't appear to 21 address that matter at all, does it?
22 A.
Not to me, it doesn't.
23 Q.
Let's try this.
Let's make another stab at this here.
24 Look at item 18 on table two.
This is the corrected version 25 I believe of those recommendations.
Does that say D-24 after 126
I i
it?
2 A.
Yes.
3 Q. Read that one.
4 Q.
" Item 18, review need for perocity acceptance criteria 5
6 Q.
Doas that appear to respond to that concern?
7 A.
Yes.
8 Q.
Do you know whether that corrective action has been 9
taken?
10 A.
No, not really.
11 Q.
The fourth item on the document that is Mr. Br yant 's 12 notes 7/17/81, Q-1A resolution (12213) -- I'm sorry, start is again here, 7/17/81, QlA voided by CRB (hangar LRSM15 91 Rev.
14 1 items ten to itens five) written for excessive undercut, is trap slag in base metal encroachments (violates L-8 0).
Craft 16 told inspector to write it up.
They weren't going to fix 17 them. (Dave Williams).
Is that an accurate statement?
18 A.
I don ' t remember t hat situation.
19 Q.
You don't remember whether or not thbt was an NCI that 20 you voided?
21 A.
I don't recall anything about the situation.
22 Q.
If accept this as reflecting an actual set of f acts hypo-23 thetically, Mr. Baldwin, you voided -- Bryant has a problem, 24 a piece of welding work.
In the process you earlier described 25 you tell him that it's not a problem or not appropriately a-127
I Q -1A.
Xou void it and it doesn' t get issued, and in the 2
craft, they told the inspector to write it up.
They weren' t 3
going to fix them.
In other words, it was not going to 4
be handled simply as a matter of process contrcl.
Would you 5
have any confidence that the weld problem had been fixed?
6 A.
It appears from this that there was process control and 7
Bryant did have a menas to not accept or reject this work.
8 It also appears that the craft were putting pressure on him 9
to write the NCI.
I would possibly take the approach that 10 the work is not completed until the inspection is completed, 11 so, therefore, don't let the craft pressure you into doing 12 something that is not necessary.
Just don't accept the work 13 until it's acceptable.
Don't take directions from the craft.
14 o what you are required to ao.
Don' t let them force you to 15 do someching that's not necessary.
16 Q.
Are you aware of circumstances where the craft pressured 17 an inspector to write an item up?
18 A. No, not any specifics.
19 Q.
I mean in general.
Did that happen?
20 A.
I have heard statements made from the inspectors that 21 the craft says Write an NCI.
22 Q.
Is that sort of like a dare, is that the way you understood 23 that?
Go ahead and write me up?
24 A.
I really don't have an opinion on what that is like.
The 25 buy made a statement to.the inspector.
It appears he really 128
1 wasn't concerned if he had been written up or not.
2 Q.
Let's jump down a couple more.
See that one there, ILD 3
2611,. no filler material listed or H3B with process control.
4 Called for inspection and fit up, no Q-1A was initiated i
5 because QA Tech Support CRB, Charles Baldwin, and RR, QA 6
Tech Support decided that the welder could do it the following 7
day.
(violation M-4 paragraph 4.2).
Is that an accurate 8
statement?
9 A.
I don' t recall that.-
10 Q.
What would ILD 2611 be?
11 A.
That ap pars to be a weld number.
12 Q.
Can you tell where it is by that number?
13 A.
Unit 1, LD system, Isometric 26, weld number 11 on that 14 isometric.
15 Q.
What is LD?
16 A.
I'm not sure what the system function is.
17 Q.
Do you know what the initials stand for?
18 A.
No, not really..
19 Q.
What is H3B?
20 A.
That is the fillament material issue slip issued with the 21 material to the welder.
22 Q.
Is that the _ welding rod?
23 A.
Welding rods, filler material, EB insert ring.
24 Q.
What is the EB insert ring?
25 A. The ring that is used in the fit-up of a weld.
It's a 129
-.u n
.--,-4 g
--y sr,w ar,r-y-
r,
-y
I 1
piece of consummable insert that is actually part of the 2
fit-up process that is consummed in the root of the weld.
3 Q. What does EB stand for?
4
-A.
Electric bow.
5 Q.
Whose initials are RR, do you know?
6 A.
Apparently that's Rick Rouse.
7 Q.
Is he a QA Technical Support?
8 A.
Yes.
9 Q.
Do you have any idea whether the welder did it the 10 following day?
11 A.
I don't know.
12 Q.
Do you have any idea whether the weld was proper?
13 A. No, l'
14 Q.
Is it cons'istent with procedure M-4 to do as described 15 if you assumed those hypothetically, the set of facts?
Is 16 that consistent with procedure M-4?
17 A.
The welder is required to enter the filler material that 18 he uses in making a weld.
If he did not document that on 19 M -4 A, he was in violation of the procedure if that wasn't done.
20 Q. Should have been written up as a Q-1A?
21 A.
1 don't remember the specific.
It i tht have *.en situations 22 or other information that generally it would have been written 23 up on 0-1A, but there might have been some exceptions to that.
24 Q.
Would have been at the time because you said they were 25 writing Q-1A's for things that you don' t think they should have.
I 130 l
.~ - - -
I But, what I want to understand is according to procedure, 2
was it proper to not initiate a Q-1A when that deficiency was 3
noted and to simply allow the welder to do it the next day and d
assume those set of facts, Mr. Baldwin.
5 A.
I'm saying at the time it was probably appropriate to o
document that on the Q-1A at that time, but now, I think the 7
appropriate means would be to write it on an R-2A at this a
time.
9 Q.
Would it have been appropriate to let it stand and deal to with it as a matter of process control?
11 A.
Generally it would not have been appropriate to do that.
12 There might have been circumstances that would have made it 13 appropriate.
I'm not sure.
Id O.
Ubuld it have been appropriate f'or the inspector to go 15 to the weld, see the process control sheet, note that there 16 was no filler material listed on the process control sheet.
17 Walk away from it and allow the welder to correct the problem 18 and do the weld the next day?
19 A. The next day?
No, it would not have been appropriate 20 because the welder is required to turn in his unused filler 21 material material and his H3B that day os that would not have 22 been appropriate, not to be done the next day.
23 Q.
Wbuld it have been appropriate not to have documented 24 the failure by the welder to have completed the process control 25 f orm properly?
131
._..yi, 4._-
.7
I 1
A.
Yes, it would have been appropriate to document that 2
filuare.
3 Q.
Jumping on down.
This is the second to the lact one on d
that page, 9/25/81, INI, 1NI, 162-27 class A.
Can you tell 5
me what that refers to?
6 A.
That refers to a weld number.
Unit 1, NI system.
7 Q.
What is NI?
8 A.
I think the NI stands -- I'm really not sure.
I think 9
it's high pressure injection.
10 Q.
Class A indicates what?
11 A. That's the class of system. That is the highest class of 12 system we have.
13 Q.
Safety-related?
i-14 A.
Yes.
15 Q.
Weld repair made on root side of weld.
Repair area approx-16 imately seven feet from the open end of the pipe.
I could 17 not make a meaningful inspection due to inaccessibility.
L-80, 18 CRB, Charles Baldwin, instructed me to sign the final visual 19 any way.
Is that an accurate statement?
20 A. No, it's not.
21 Q.
Tell me what is wrong with it?
22 A.
I did not instruct him.
I talked to the supervisor about 23 this.
24 Q. Who i s tha t?
25 A.
B eau Ross.
132
1 Q.
Tell me whap happened.
How did you hear from Mr. Ross 2
or get to Mr. Ross or here about this problem?
3 A.
He called me asking for any input on this.
He asked 4
me questions about how -- what would be the appropriate means S
.to resolve this concerns.
6 Q.
He, Mr. Ross?
7 A.
Yes.
8 Q.
All right.
9 A. As I recall, the weld was rejected for a root condition 10 by radiography.
11 Q.
What's a root cond ition?
12 A.
It's the first pass or the first layers of welding metal i
13 put in a weld.
Id Q.
Give me an example of this.
15 A.
On the ID, on the inside of the pack.
It's weld metal you 4
16 can see on the inside of the' pack.
17 Q.
What kind of pro blem would be identified that way?
4 18 A.
You could have excessive penetration, burn through, lack 19 of penetration.
It could have oxidation.
There's a num ber 20 of discontinuities or weld metal defects that could be.
21 Q.
On the root s ide?
22 A.
Yes.
23 Q.
Mr. Ross called you?
24 A.
Said that the craft had attempted to repair the weld 25 by grinding the ID, seven foot.
g 133
1 Q. I'm sorry, say that again.
2 A. On the ID, it was on the root side of the weld.
It wasn't 3
possible for the welding inspector to do a visual inspection d
on that portion of the weld because it was approximately seven 5
feet up in the pipe.
The procedure does not require a visual o
iinspection that far up in a small-diameter pipe.
It requires 7
the inspection of the OD, the outside of the pipe.
8 Q.
Yes.
9 A.
The weld was to be re-radiographed af ter the repair was 10 made.
In my judgment any def ects that wasn't removed would 11 still be rejectable.
M -4 speaks to the accessibility for 12 visual inspection and gives correction of what accessibility 13 criteria for visual inspection.
Id Q.
How about L-80?
15 A.
I think that's really defined in procedure M-4.
I don't 16 think L-80 really describes accessibility criteria.
17 Q.
Do you have any idea what Mr. Bryan'ts reference to L-80 18 is with regard to accessibility?
Do you know what I'm l'
saying?
20 A.
No, I don't.
I think he really meant M-4.
21 Q.
Did you instruct Mr. Bryant through Mr. Ross to sign 22 the final visual any way?
r 23 A.
It appears that they were sure interpreted that way, yes.
24
.Q.
You instructed Mr. Ross to sign it?
25 A.
I instructed Mr. Ross that it wasn't a requirement of l
134 I
l
i i
visual inspection to be performed since it was inaccessible.
2 Outside the accessibility criteria of M-4.
3 Q.
And, that it should be signed off any way?
4 A.
Yes.
5 Q.
And, it was as f ar as you know?
6 A.
As f ar as I know, yes.
7 Q. Help me understand this.
Eow did the craft make the 8
repair on the root side of a weld when the inspector couldn't 9
see -- how did they get access to it to make repair if the 10 inspector couldn't get access to it to visualize?
11 A.
Apparently they put a grinder on the rod or pipe or 12 something and stuck it up in the pipe to grind it.
13 Q.
And, turned a grinder on and tied it to a piece of pipe 14 or something and stuck it up into --
15 A.
That's the only way.
I wasn't there.
I don' t know how 16 they did that.
17 Q. Didn't have a smaller welder than they a welding inspector?
18 There's no other way you can do it, is there?
19 A.
I don't think so.
There's no other way.
As I r ecall, 20 it was either eight or ten inch diameter pipe or ever smaller 21 than that.
It wasn't a very large pipe, so there's really 22 no way --
23 Q. Do you know what system?
24 A.
MI system apparently.
I don't recall according to this 25 note.
I 135 L
I I
Q.
Item 15, again, this is table two welding inspection on 2
the Task Force recommendations.
Item 15, indicated D-30 3
after that item, doesn't it?
4 A.
Yes.
5 Q.
Again, let me see if I can help you, if we can agree on 6
this cross-reference here.
7 b1R. McGARRY:
An observation.
This cross-reference, a
there's a note on the document that you have in your hand 9
there are those numbers D 1, 2 and 3.
10 Q.
Yes.
11 MR. McGARRY:
Where did they come from.
12 MS. GARDE:
One of the attachments to the Mac 13 report. In the attachments to the Mac report, this is raw Id data that the back-up to the Mac report has coded on it.
15 Q.
Someone went through, I presume Mr. Swisler one of the 16 other people.
It's not our cross-reference.
17 MS. GARDE :
It 's the raw attachments.
18 Q.
Take a loot at that.
Item there indicated by my thumb, 19 does that appear -- does that text appear to describe the 20 same concern we are talking about here, the same num ber?
21 A.
Yes.
22 Q.
Is that how that num ber -- does that have that D-30 by it?
23 A.
Yes.
24 Q.
Look by that -- D-30 appears af ter that recommendation, 25 sir?
136
(
1 A.
Yns.
2 "Q.
Would you read that?
3 A.
"The requirement for the use of inspection by remote d
means on welds inaccessible for formal inspection should be 5
conveyed to the inspector, D -3 0. "
6 Q. What does that mean, any idea?
7 A.
Yes.
You use mirrors, bore scopes, telescopes, small 8
inspectors or whatever is available to him.
9 Q.
How do you do remote -- we saw the ways you can't do it.
10 Let's figure out how you do remote inspection in circumstances 11 like this.
12 A.As I said earlier, you can use bore scopes, mirrors, t ele -
13 scopes, anything that would give you the visibility to be 14 able to allow the u se of those instruments to inspect those.
15 Q.
Why wasn't a matter of telling Mr. Bryant what he should 16 do?
17 A.
I'm sure Mr. Bryant had used everything that was available 18 to him at that time to attempt to do an inspection.
i 19 Q.
Using those means, he was still unable to do a visual?
20 A.
Apparently he was to satisfaction, yes.
21 Q.
Didn't have a long enough stick to tie the mirror on?
22 A.
Seven foot up in a pipe is difficult to get' an image of l
l 23 what the weld looked like, and h e didn't f eel comfortable l
24 with doing that.
j 25 Q.
How does this recommendation address the problem he had?
137
[
l
t I
If, in fact, he used everything at his disposal, how is he 2
going to solve the problem to simply convey to inspectors 3
the means available to do removed inspection?
Isn't that d
something he knew and everybody else already knew anyway?
5 A.
It appears thatit would have been, yes, because that's o
in the procedure to tell thtm to use remote means or v'isual 7
aids.
8 Q.
Not particularly helpful as a recommendation as far as 9
improving work _of welding inspection at Catawba in your 10 opinion?
I mean was it helpful to you or to the welding 11 inspectors to have the Task Force issue that recommendation, 12 Mr. Baldwin, in your opinion?
13 A.
It didn't really change that particular s'ituation.
Id Q.
Now, sir, in this particular instance, you instructed IS Mr. Ross such that it was your instruction that the inspector 16 in this case, Mr. Bryant, sign off on that weld, is that right?
17 A.
It was my directions to Mr. Ross that the inspection is could be performed in accordance with the procedure M-4 and 19 L -8 0.
L-80 didn't really address it, but L-80 coes address 20 using visual aids such as bore scopes, mirrors or whatever.
21 Q..But, the affect of your instruction to Mr. Ross, through 22 Mr. Ross to Mr. Bryant, was that he should sign off on that 23 weld, correct?
24 A.
If he could do the inspection in accordance with procedure 25 yes, and it appeared to me that he could meet the intent of 138 4
h t
I i
the procedure.
2 Q. How is that?
3 A.
He could do what the procedure directed him to do.
4 Q. Which was?
5 A. If it wasn't accessible and didn't have any means to 6
do inspection or any other visual aids or devices available 7
that he could, you know, he wasn't required to inspect the a
inside of the weld.
9 Q.
So, assume he got that far and that was the case, is he 10 suppose to sign off on that?
~
11 A.
Yes.
12 Q.
Doesn't his signature indicate that he, in fact, has 13 accepted the matter by visual inspection?
14 A.
In accordance with procedure, yes.
15 Q.
Bu t, he didn't do that.
16 A. He did it in accordance with procedure.
17 Q. I don't want to mince words with you, but it is clear, if 18 we assume those facts and got to that point where none of 19 those means available to him would allow him to make visual 20 inspection, then it is clear that he did not visually inspect 21 that weld?
22 A. Not the area that was ground, no, he did not.
23 Q.
Bu t, he was expected to sign off on the process control 24 form?
25 A.
Yes.
139 e
i
I 1
Q. And, that signature --
2 A.
He also had the option of indicating on the process 3
centrol what the signature meant which he has done on several 4
occasions.
S Q.
Is that your instruction to him?
6 A.
I might have instructed him.
I'm not sure, through 7
Mr. Ro ss, you know.
I believe I did tell him, Mr. Ross, if 8
he had a problem to indicate it on the back of the form or 9
anywhere what he was actually signing for.
That is generally 10 my instructions if the inspector has some concern.
11 Q.
Did he do that?
12 A.
I don't recall in this situation.
13 Q.
In this particular situation, do you know whether they l-14 wrote an NCI?
15 A.
I believe there was an NCI written.
16 Q.
At that time?
17 A.
Probably after.
18 Q.
Af ter ?
19 A.
After the inspector concerns were evaluated.
20 Q.
Again, D-30 item 16, this is the same table from the 21 Task Force report, the most recent revision that I'm aware 22 of.
What does that say, sir?
23 A.
It says, " Dis osition of weld 1 nil 62-27 is depnndent on 24 the resolution of NCIR 13955 D-30.
25 Q.
As f ar as you know, Mr. Baldwin, that NCI would not have i
140 l
l
I i
been initiated nor that resolution or any resolution made 2
unless the welding inspectors had voiced those concerns?
3 A.
That's true.
Q. The last item on that page and my date has slipped bff 4
5 the page.
I think it looks like 10/5/81, NCI 13028, are you o
familiar with that?
7 A.
No.
8 Q.
It says voided by CRB which concerns lap over excess 9
penetration and abrupt weld profile on weld ILD 123.
CRB 10 says he had no problem with this root pass.
Beau, Harold 11 Eubanks and myself believe differently.
Violation of L-80.
12 Is that an accurate statement.
13 A.
I don't recall that.
( '
14 Q.
Mr. Baldwin, we can't seem to find any indication of 15 what the resolution of item D-31 was which is that listed as 16 that specific NCI.
You don't recall that instance, and 17 you don't know what the resolution was?
18 A.
No.
19 Q. Let me show you -- we don't seem to be able to find that 20 specific response to that item.
I'm going to show you another 21 document.
Ca:: you identify that.
The handwriting first.
22 A.
It looks like Mr. Ross' handwriting.
23 Q. Mr. Beau Ross?
24 A.
Yes.
25 Q.
Exhibit Five, and have you ever seen that document before?
(
141
I 1
A.
I have seen -- It appears to be the same thing, yes.
2 It might have been in the inspector concerns that I saw this.
3 Q. These are handwritten notes of Mr. Ross and they appear to be keyed to specific inspector concerns and they are a 4
5 chronological list and see how many pages it is.
Eighteen 6
pages long, and if you look at the last page, it's rather 7
poor Copy, but it appears to be signed by Mr. Ross, does it 8
not?
9 A.
Yes.
10 Q.
Can you make that out, the date there, it appears to be 11 1/19/82, and your name or your initials CRB come up quite 12 often in that document, Mr. Eeldwin, and I want to ask you 13 about a few of them.
The very first item is dated August 2, 14 1978.
" Rust no pro blem unless 'very bad ' LRD and CRB,"
is Larry Davison, Charles Bald win.
"I ask el for some workmanship 16 samples to show our people, but got no response.
CRB threatened 17 me with my job.
I questioned Larry on rust guidelines.
CRB 18 said 'If we don' t do job like they want it done (without 19 question), they will get somebody else'"
Is that accurate?
20 A.
No, it's not, 21 j
Q. Do you remember Mr. Ross questioning you about the standarci 22 for rejecting work on the basis of rust?
23 A.
I remember a discussion with Mr. Ross about that time 24 period on rust, yes.
25 j
Q.
A friendly discussion, did you exchange words?
(
142 I
~
l l
l
(~
1 A.
It was a quite lengthy discussion.
2 0. Friendly and lengthy or lengthy and heated?
3 A.
Might have got heated.
4 Q.
Describe the discussion.
I know it's been some time.
5 A.
It's been some time ago, but I do remember.
I had spent 6
some time -- the question on what was acceptable with rust, 7
really there's a lot of room for interpretation in procedure.
8 The procedure was -- had left room for interpretation on what 9
the acceptance criteria was for rust so I had spent some time 10 in trying to arrive at an acceptable resolution in order to 11 give Mr. Ross instructions on what was acceptable and what 12 wasn't acceptable.
I had concurred with the Engineering 13 Department, talked with Mr. Davison and Mr. Lane Friez who 14 is the project engineer at the time.
And, after all this 15 preliminary work that I had done, I finally had felt comforta-16 ble with the instructions that I should g ive Mr. Ross, so I 17 attempted to do that and apparently, he didn't agree with me 18 and could not accept the instructions that I had given him.
19 Q.
Did you say in essence, and I appreciate you got two 20 paragraphs that reflect a lengthy discussion as you character-21 ized, but did you tell him in substance that rust was no 22 problem unless very bad?
l l
23 A.
No.
24 Q. How bad was rust suppose to be before it became a problem?
25 A.
How bad is bad, you know.
The procedure describes hard l
143 1
I 1
-rust or heavy rust.
That's how it defines rust, you know.
2 Whnn I went in te field and looked at hard rust and heavy 3
rust and this type of thing, and an appreciable build up of 4
ru st was acceptable.
5 Q.
This is on work that was in the set up point where it is 6
getting ready to be welded?
7 A.
Well, no rust is acceptible in the area to be welded.
8 This was really the internal cleanliness of the pipe.
At 9
fit up inspection, the inspector had the responsibility to 10 veryify that the pipe meets procedure M-24 as far as cleanli-11 ness on ID.
In additi'on to those cleanliness requirements, 12 there 'is requirements in the process specification that must 13 be met for the area that is to be welded which is different
(!
14 criteria, so the rust criteria wasn't real concerned in the is area to' be welded.
This was only the internal of the piping to system.
17 Q.
Do you know whether the Welding Inspectors Task Force la report addressed this concern?
19 A.
I believe it did address that concern.
I believe it 20 does state it.
I'm not sure a bout this, but I think it's 21 something about that workmanship or recommendations of work-22 manship samples for rust.
Again, I'm not positive of that.
23 Q.
Did you threaten Mr. Ross with his job?
24 A.
I didn't consider it a threat at the time, but I'm sure 25 he took it that way, and I told him if he could not take I
144
.o,
+
m-.-
.,--.-n.-m---,-
y
--w
,7- -,
y
(
1 directions and do his job, you know, I would have to get some-2 one who could to the job which wasn't appropriate.
I realize 3
that now.
That was an error on my part.
4 Q.
What had Mr. Ross done or said that prompted that response 5
on your part?
6 A.
I don't recall that at this time.
7 Q.
Did he ask you for a workmanship sample?
8 A.
I don't really recall that.
He may have.
9 Q. Did you g ive him one?
10 A.
No.
11 Q.
Under programatic recommendations, item 4 there, would 12 you r ead that, Mr. Bald win.
That, ag ain, is the latest revi-13 sion of the Welding Inspector Task Force recommendations.
14 A.
" Consider the use of workmanship samples or pictures to 15 illustrate the differences between acceptible and unaccepti-16 ble work especially on items that are somewhat judgmental 17 or on which regular or periodic high volumn of NCI's occur."
8 Q.
Are you aware of any response by the Task Force to l
19 Mr. Ross' concern with respect to your threatenting him on 20 the loss of his job?
21 A.
No, 22 i
Q.
That's not a technical concern?
23 A.
I don't think so.
24 Q.
Let's look at under March 6, 1980, Q-1A and it appears l
25 to be 7850, resolution not correct, notified D. Gadd, unclear I
145 l
l L
I 1
name and CRB.
CRB says, "Take tags off anyway.
It is 2
causing a hold up."
As I was discussing a problem with Gadd 3
and QA, CRB goes to field, takes tag of f and signs Q-1A off.
David Gadd changed the resolution to read remove the weld 4
5 in question.
Next page, it continues, but when he heard 6
that Charles had cleared the NCI, he went back to original 7
resolution. At the time only about six inches of root pass 8
was affected, but now the entire - weld is made over this 9
root.
I went back to Charles to try to get support for 10 repairing the weld and getting the error corrected on the 11 statement of resolution, but he would take no action.
That 12 describes an incident that we talked about, already, isn't 13 it?
l.
14-A.
I believe that -describes appears to be describing the is incident on the lower pressurizer support.
16 Q.
Yes.
And, the item we discussed previously where you 17 couldn't find Mr. Ross and you went back and removed the tag 18 yourself?
19 A.
Apparently he was talking with Mr. Gadd at the time I 20 had directed him to take the tag off of the item.
21 Q.
How about this business about changing the resolution?
22 Are you aware of that?
I j
23 A.
I can't speak to that.
The only thing I know about that i
24 is Mr. Ross says he was concerned.
25 Q.
Other than what you told me already about the matter, you i
146
(
1 removing the tag yourself you don't know about them changigg 2
the resolution on that NCI as a result of you having taken 3
the tag off yourself?
4 A.
I didn't see any changed resolution on the NCI, no', I did 5
not.
6 Q.
Are you saying you are not aware of it?
7 A.
I was only aware of it after Mr. Ross had written that 8
concern.
He might have mentioned it to me, but I don't recall 9
that.
I'm sure he did, but I just don't recall it.
10 Q. Well, is that consistent with procedure, change the reso-11 lution on the NCI?
12 A.
If he felt that his first resolution was incorrect, yes, 13 it's appropriate to change that resolution.
14 Q.
Was it appropriate to change it back simply because you 15 had gone and taken the tag off?
16 A.
No, that was his reason.
I don't know that he did that.
17 Q.
I'm asking you to assume -- I'm not asking you to confirm is a fact you don't know, but you assume those f acts stated l
19 correctly.
Does that reflect a proper compliance with proce-20 dure at the time?
[
21 A.
If he did that because I took the tag off, and I don't l
22 see any technical decision that could be made or should be 23 made because I took the tag off.
l 24 Q.
So, it would not be a proper procedure?
I 25 A.
No, it would not.
i i
147 L
I 1
Q.
Do you know whether that weld is correct now?
2 A.
I feel sure that the weld is correct, yes.
3 Q.
Wh ?
i 4
A.
I feel that this was evaluated as a result of the concern.
5 Q.
Do you know whether it would have been evaluated and/or 6
made correct if those concerns wouldn't have been expressed?
7 A.
As I told you earlier, I don't think it would have been.
8 Let me clarify that statement I made.
9 Q.
Sure.
10 A.
I don't know that the weld was incorrect.
I don't 11 know that there was anything to correct as a result of this 12 concern.
This was re-evaluated.
I don't know the outcome 13 of that resolution or that evaluation.
14 0
Well, see if we can find it.
Item R-13 under NCIR 15 resolution in the last version cr the Task Force Report to recommendation, item two there, R-13 af ter it.
17 A.
Yes.
18 Q.
Would you read that resolution?
19 A.
" Perform hardness test to determine the hardness of the 20 heat-affected zone in the area in question.
If hardness ex-21 ceeds BHN 220, the weld in question shall be removed.
As 22 concerns J-5, R-13 and H-1. "
23 Q.
Do you know whether those hardness tests were performed?
24 A.
No, I do not.
25 Q.
I believe Michael Lowe from Palmetto Alliance has just 148 w
I 1
joined us.
Mr. Baldwin, further along here, August 21, 1980, 2
again, these are Mr. Ross' notes. " Talked to Charles B.
about 3
some concern expressed by inspectors about lack of support 4
for program.
Too, inclined to go along with craf t and keep 5
work working rather than strictly following program."
Is 6
that an accurate statement?
Did Mr. Ross say that to you, 7
I guess is what I want to know first.
8 A.
I don't remember it.
9 Q.
What his note suggests that he told you is it accurate in to your opinion?
11 A.
I believe that he could have felt that way, yes.
12 Q.
You think that's true?
13 A.
No.
('
14 Q.
What is that written in the margin by that concern?
15 A.
Non -t echnical.
16 Q.
And, the number by it?
17 A.
No.
18 Q.
Do you know whether that concern has been addressed?
19 A.
No.
20 Q.
Did they address non-technical concerns?
21 A.
I don't know.
22 Q.
Are you aware whether they have been addressed and correc-23 ted?
24 A.
I feel sure they were.
l 25 Q.
NWhat is your understanding of what concerns were classified 149 l
l
I 1
as technical and what concerns were classified as non-technical?
2 A.
My understanding anything that would be adverse to 3
quality would be considered technical.
4 Q.
Yes, and non-technical?
5 A.
That would not necessarily in some situations be adverse to quality because someone makes a general statement or they o
7 assume something or they exprecs their opinion, I don't how you would think that would be technical.
8
- se 9
Q.
Well, if there was a lack of support for the quality 10 control program, and that if the supervision, youself, for 11 example, were too inclined to go along with the craf t and 12 keep working rather than follow the program strictly, are you 13 saying that doesn't affect quality?
14 A.
Not directly.
It could indirectly.
15 Q.
Because indirect, it's not technical, and, therefore, 16 not appropriately resolved with the technical concerns?
17 A.
Apparently they made the decision.
I can' t answer 18 why they considered it non-technical.
I could have my 19 views on it, bt I don't really know.
It wasn't my job to 20 do the evaluation.
21 Q.
I'm interested in your view, and I want to know why yc2 22 think they did things this way or that way.
What do 23 you think, Mr. Baldwin?
24 A.
Why I think probably they considered it more appropriate 25 to handle as non-technical concern, and I believe that's true.
I 150
t
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1 Q.
That means they handled it less seriously?
2 A.
I don't think so.
It might have been handled more ser-3 iously.
d Q.
Do you know?
5 A.
No, I don't.
6 Q.
Fe brua r y.10, 1981, you got another non-technical, and see 7
what they have to say about that.
Welder told John to 8
get off scaffold after John rejected his work.
Told CRB this was interferring with job.
Harrassment and intimidation 10 of inspector.
No action taken.
Welder later apologized to M
John.
That's an accurate statement to your knowledge?
12 A. Pro bably happened.
It seems that I recall something.
I O
don't remember the specific wording on that, but I do recall Id a situation similar to that.
15 Q.
Throwing off scaffold situation, do you remember that 16 one?
17 A.
I remember some discussion about that, yes.
la Q.
Sound like that one there?
19 A.
Yes.
20 Q.
What do you remem ber about that?
Tell me what you remem-21 ber.
2 A.
That's about the extent of it.
I just remember some 23 discussion about it.
24 Q. That's not a technical concern?
25 g,
y,: wasn't handled as a technical concern.
151
I 1
Q.
That seems clear.
In your opinion that is not a technical 2
concern?
3 A.
No.
4 Q.
Doesn't affect quality?
5 A.
Not really, not directly.
6 Q.
Mr. Baldwin, if I'm a welding inspector and a craf tsman 7
whose work I'm inspecting threatens to throw me off a 8
scaffold if I flunk his work, don't you think there is a 9
pretty direct relationship between that occurrence and the 10 ability of me as a welding inspector to perform my job and 11 assure quality in welding?
12 A.
Not this particular welding inspector, no, I don't think 13 go,
(.
14 Q.
Why not?
15 A.
I don't think -- this is my opinion again --
16 Q.
Please.
17 A.
I don't think it would affect him or hamper him from 18 doing his job.
19 Q.
Who is the welding inspector in question?
20 A.
I think it was John Bryant.
21 Q.
Why don't you think it would hamper John Bryant?
22 A.
I don't think he would allow someone to interfere with 23 him doing his job.
24 Q.
Including threatening to throw him off a scaffold?
25 A.
Including that.
I 152
4 I
Q.
Why is that.
Why is Mr. Bryant stand out as someone 2
who wouldn't be af fected by such a thing?
3 A.
I h not so sure he stands out any more than some of the l
4 other inspectors.
s 1
5 Q.
Help me understand.
6 A.
They are very persistent at their job.
i-7 Q.
And, do I understand you and reading you right in saying a
that while somebody might take a threat like that from a 9
craf tsman in such a way as to hamper their ability to do 10 that function, inspection, but this particular individual, 11 this welding inspector, in your judgment that it wouldn't 12 affect him that way?
13 A.
It might have had some slight affect on him.
I don't 14 think he would have mentioned it if it hadn't had some affect is on him, but I don't think it really hampered in from doing to his job.
1 17 Q.
Is it acceptable as far as you are concerned for craft is to be threatening your welding inspectors?
19 A.
No.
20 Q.
What do you do about it when it happens?
l 21 A.
Try to corr ect it.
22 Q.
What did you do about it in this instance?
23 A.
I don't remember.
24 Q.
Did you do anything?
25 A.
I don't think so.
I think he came back and said they had
(,
153 3
v
..-..-----,,,,.-,m.
(
l apologized and everything was okay.
So, what do you do in 2
a situation like that.
It s emed to be a misunderstanding, 3
and a moment of heated words, and was over shortly after that d
so it seemed to be more appropriate not to take any action.
5 If it had continued, I'm sure some action would have been 6
taken.
7 Q.
What would be done about the general subject of threats 8
and harrassment and intimidation by craft against your inspec-9 tors, Mr. Baldwin?
If that specific instance because the 10 inspector involved or the circumstances, the apology or what 11 have you didn't require a response, tell me as a general 12 matter how you address that kind of problem?
13 A.
Usually what happens, it it's more than just heated words t
14 or appears to be something that could be a problem, that's 15 evaluated.
Both sides of the disagreement are vieted and 16 looked at and discussed with management and supervision on 17 both sides.
Evaluated to see if it's a potential problem.
18 Q.
How about generally.
I don't mean you get a fight that 19 ahppens.
I can address a specific altercation, but what 20 generally have you done in order to address the conflict 21 between craft and the welding inspectors, if anything.
22 A.
Generally, I can't tninx of any general terms to explain 23 what has been done, but I don't think that's a problem.
I'm 24 sure we have done something if that has been a problem.
25 Q.
You are not aware of any in particular?
154
1 A.
I can't recall, nothing comes to mind.
2 Q.
You consider that normal part of the work of tne welding 3
inspector to have to put up with that?
m 4
A.
I consider any time you have a group of people working 5
together that you are going to have disagreements and I 6
consider peopl e disagreeirg as a normal part of day to 7
day occurrences that could happen.
8 Q.
Do you agree that those kinds of -- disagreements and 9
conflict is particularly likely and particularly a problem 10 in a relationship between a welding inspector and welding 11 craft?
12 A.
I think it's something that used to be evaluated in each i
L.
individual situation and should be' reviewed to analyze the 13 14 significance of it.
15 Q.
That concern was identified as a non-technical concern?
16 A.
Yes.
17 Q.
Do you know --
18 A.
According to that note.
19 0
Do you know whether it was addressed and corrected?
20 A.
No, I don't know what action has been taken.
21 Q.
Here's one that I would like for you tc help me understand, 22 January 14, 1982, talked to CRB about saddle weld Lindsey 23 found in field with no L dimension.
What is an L dimension?
24 A.
I think he is speaking to the length, leg length of a 25 filled weld, t
155
?
y c.
p
-s,,
r y
w, - - *,,
i 1
Q.
I wanted to get L 6imension on paperwork before turning 2
paperwork in and also I raised question about other paper-3 work in field not having proper process control information.
4 Nbuld the L dimension be a piece of process control infor-5 mation?
6 A.
Yes.
7 Q.
Also informed CRB about " thousands" of other welds with a
possible same problem (not enough reinforceraent due to L 9
dimension not being specified).
Are you familiar with that 10 instance?
11 A.
Yes.
12 Q..
First answer, af ter he, that's you, talked to Ron Martin.
13 Who is Ron Martin?
Id A.
Ron Martin is in the group that issued process control.
15 Generally initiated the process control.
16 Q.
The procedures?
17 A.
No, the process control, you know, the travel sheets to is get the work done.
19 Q.
He is in construction department?
20 A.
Yes.
21 Q. "When paper work was generated, the requirement for weld 22 reinforcement was different."
(Bu t, we finished the weld 23 today so today's criteria have to be followed).
T wo, second 24 answer, next day, "We used CP 427 for this criteria ( but, this 25 CP is strictly for process control generation).
Wanted to 8
156 s.
I 1
know if we did not use this CP all the time. (We never, to 2
my knowledge, use this process control procedure).
Ron 3
Martin did not want to recall paper kork to put L dimension 4
on paperwork.
This is the only way to assure that proper 5
size weld is installed.
I talked to welding technical support 6
and they agreed to put L dimension on this paperwork and to 7
recall other paperwork with same problem.
Charles did 'not a
want to press issue.
I asked about this requir ement reinforce 9
ment on certain welds, CN 1676 drawings.
Does that mean some-10 thing to you?
CN?
11 A.
Yes, that's the welding drawing that describes a fill up 12 in welding.
13 Q.
When I first came to Catawba but was told if it was not
(.
14 on process control, don't worry about it.
It doesn't apply.
15 Give you back this piece of paper and take a look at that.
16 I want to understand if that is an accurate statement?
17 Have you had a chance to look at that?
18 A.
Yes.
19 Q.
Is that an accurate statement?
20 A.
No, it's not complete 1.y accurate.
21 Q.
How about filling in whatever needs to be filled in to 22 make it accurate.
23 A.
To begin with, you have to understand to begin with 24 on the job with process control was issued, the welder and the 25 welding inspector were given directions of the process speci-4 157
i I
fication as to determine the size of the filled weld.
2 Q.
What is a filled weld?
3 A.
A filled weld is not a butt weld.
It's something other 4
than a butt weld.
5 Q.
On a horizontal surface?
6 A.
It's usually where your welding is -- you ar e welding 7
something that usually is ninety degrees.
You are adjoining a
two members at a ninety degree.
Information was available 9
to the walder and the inspector to determine what the leg 10 length of the filled weld size should be.
11 Q.
What was that information?
12 A.
In the process specification.
13 Q.
Not process control?
Id A.
No, it was in process specifications which inspectors had 15 access to at each inspector has that procedure or those 16 procedures.
They were trained as welding inspectors that 17 was part of their training how to determine the length of the 18 leg on a filled weld.
19 Q.
Is that construction procedure?
20 A.
No, that's a QA, that's a part of the welding program 21 procedure which is a QA procedure.
22 Q.
Can you give me a reference?
23 A.
Reference to the procedure?
r 24 A.
Yes, sir, L-200, L-300, those are two examples.
25 Q.
What are those generally deal with?
What do those subjects g
158
I' 1
generally deal with?
2 A.
L-200 generally deals with the welding specifications 3
used in the GTAW which is the gas tungsten arc welding.
L-300 which is SMAW which is shielded metal arch welditg.
4 5
It was determined later as a construction was getting more 6
involved that it would be better to specify the leg length 7
on the process control so that the welder and the inspector 8
would not have to determine this from the process specifica-9 tions.
It was also an admininstrative decision not to recall 10 all of the paperwork that had been generated just to do 11 that because the information was available.
My discussion 12 with Mr. Ross, he did have a construction procedure available 13 to him that told him if he had any queition abcut what the 14 required size of the weld was that he could determine that in 15 addition to the process specifications.
He had the construc-16 tion procedure that gave him the size weld.
17 Q.
Are those welds in question on safety-related systems 18 of components?
19 A.
Yes, I'm sure a number of those welds were on saf ety-20 related systems.
I might add that if I remember correctly, i
21 there was a major reinspection program implemented to re-22 inspect those welds.
23 Q.
That' resulted from the Task Force recommendations?
24 A.
I don't really think it did.
I think that was implemented 25 prior to the Task Force recommendations.
I 159 7
w--
v,s-w-c.
mm-q 9
e-w e-
(
1 Q.
As a result of that concern?
2 A.
No, I don't think it was a result of this concern.
This 3
might have played a part in it.
I'm not sure.
I don't r ecall 4
exactly how that happened.
5 Q.
How many welds where reinsp nted?
6 A.
As I recall several thousand welds were inspected.
7 Q.
When did this happen?
8 A.
1982, I think.
9 Q.
Was this a result of NRC inspection?
10 A.
I don't recall, but it could have been.
11 Q.
Was NRC aware of the reinspection?
12 A.
I'm sure they are.
13 Q.
How do you know?
14 A.
They usually are made aware of any potential problem.
15 This was identified as a potential problem, I'm sure, and 16 Duke Management made the NRC aware of it.
17 Q.
Was any rework required?
18 A.
I don' t recall.
19 Q.
Who performed the reinspection?
20 A.
Welding inspectors.
21 Q.
Did they have a L dimension to inspect the filled welds 22 upon reinspection?
23 A.
They had available to them, I'm not sure if it was 24 specified in the process control they were using for this 25 inspection.
It might have been where they were inspecting 1
160
I 1
to the welding process specifications.
I don't recall wha t 2
they were u sing.
3 Q.
Khat was the basis for the reinspection?
4 A.
I don't really remember that.
I don' t recall what caused 5
that reinspection.
o Q.
What they were looking for ?
7 A.
They were looking for the size of the welds on filled a
9 Q.
Filled dimensions?
10 A.
Yes.
11 Q.
If I could get a r'eference to that reinspection, if thnre 12 is an NRC inspection report reference or some other reference, 13 if 'you could help me track it down, I would appreciate that
('
14 during the br eak.
15 SHORT RECESS (3: 25 p.m. )
16 CONTINUING EXAMINATION:
(By Mr. Guild)
(3 :45 p.m. )
17 MR. McGARRY:
Just before the recess, Mr. Guild, you is asked if we could determine if there was an inspection report 19 that reflected this reinspection activity associated with the 20 January 14, 1982, incident.
We have gone back and reviewed 21 the files and talked among ourselves, and it appears that 22 the reinspection was referred to was totally unrelated to 23 this January 14, 1982, incident.
24 Q.
Mr. Baldwin, did you find anything more about the rein-25 spection, what was the reinspection related to?
g 162
1 A.
The inspection I mentioned earlier?
2 Q.
The reinspection, the thousands of welds you said.
3 A.
It was related to the size of the leg on the socket welds.
4 Q.
Why was there an reinspection?
5 A.
I don't recall how that came about.
I know it was done, o
and I was responsible for the reinspection.
7 Q.
You were responsible for it?
8 A.
Not directly but indirectly.
My people did the reinspection,
9 the people working under my direction.
10 Q.
What were the circumstances of that reinspection?
11 A.
The circumstances?
12 Q.
Yes.
13 A.
I don't really recall what you mean by the circumstances.
14 Q.
If it's not related to the concerns about the L dimensions 15 of the filled welds, what was it related to?
16 A.
It wasn't related to this specific concern.
This specific 17 concern was not directly related to that.
I think reinspection 18 that I mentioned was done prior to this concern.
19 Q.
Prior to?
20 A.
Yes, as I recall.
I'm not sure of it.
As I recall, I 21 think the reinspection was done in '81.
22 Q.
You have no further information about that?
23 A.
Not that I can recall, no, sir.
24 Q.
Did you learn whether or not it was related to an NRC 25 inspection?
163
I 1
A.
No, I don't.
I can't say.
2 Q.
Do you know whether or not all of the welds that Mr. Ross 3
had reference to in this concern were reinspected?
4 A.
I'm sure they were.
I don't know whether they were 5
specifically, but I feel sure his concern was reviewed.
6 Q.
The reinspection occurred before his cc\\cern was expressed, 7
why would you think they would have reinspected the welds he's a
talking about?
9 A.
Because my understanding is all concerns the inspectors 10 have were looked at in great detail.
11 Q.
But you don't know whether the reinspection you're referring 12 to-- you're not saying that reinspection looked at welds he's 13 talking about, are you?
14 A.
No.
15 Q.
Do you know whether or not those welds were reinspected, 16 the ones he's talking about, Mr. Ross is talking about?
17 A.
Not specifically I don't.
18 Q.
Thousands of welds he's talking about?
l 19 A.
No, I couldn't answer that.
20 Q.
On the next page, Mr. Ross's note reflects the following:
21 Bill Deaton, and he's a Welding Inspector Supervisor?
22 A.
He's at this time, yes, and has been for three or four l
23 years.
l j
24 Q.
Bill Deaton was going up I-77 and had a construction worker 25 pull a rifle from a car and point it at him and indicate that 164
I 1
he would shoot him.
This came about as a result of attitude 2
established on the job by this man's supervision.
The worker 3
quit, no action taken.
Are you aware of that concern?
4 A.
Yes.
5 Q.
What do you know about it?
6 A.
All I know about it is what that says there.
I know that 7
Mr. Deaton was going home one evening af ter work, and this e
employee was working in the area that Mr. Deaton was inspecting 9
in, pointed a gun out the window going up the Interstate 10 Highway.
11 Q.
Was the construction worker a welder?
12 A.
1 think he was a steel rigger.
13 Q.
Was Mr. Deaton a Wolding Inspector at the time?
b 14 A.
Yes.
15 Q.
Was he inspeccing the work that the rigger was working on?
16 A.
I think he was, yes.
1:7 Q.
Did he reject the work that the worker was working on?
18 A.
I don't really know.
I don't know.
19 Q.
How did the matter come to your attention?
20 A.
I discussed it with Mr. Deaton recently.
21 Q.
Recently?
22 A.
Yes because I vaguely remembered that was some time ago, 23 and I didn't really recall, so I discussed it with him.
24 Q.
Did Mr. Deaton bring this to your attention or to the 4
25 attention of anyone else in supervision on or about the time 165
(
2 w-n y--
w w
3 y--
-,-w9-,
-.-,e#m-
--m-y--y-
i I
of the occurrence?
2 A.
Yes, Mr. Deaton was an Inspector working for Mr. Ross at 3
the time that Mr. Ross reported that.
I'm not sure whether d
he reported that directly to me or to whom he reported it to.
5 Q.
But it came to your attention about that time?
6 A.
Yes, I was aware of it.
7 Q.
When was that?
8 A.
It must have been approximately four or five years ago.
I 9
don't remember specifically.
10 Q.
What did you do when it came to your attention?
11 A.
When it came to my attention, it was already determined 12 that the guy that did that had quit, and I knew that manage-13 ment was aware of that.
Id O.
How did you know that?
15 A.
Through conversations.
16 Q.
With whom?
17 A.
I don't recall how I made that determination.
18 Q.
What management was aware of it?
19 A.
As I recall, Mr. Doug Beam was the project manager at that 20 time.
He was aware of it.
21 Q.
How was Mr. Beam aware of it, do you know?
22 A.
I think he was made aware of it af ter Mr. Deaton reported 23 that incident to his supervisor.
24 Q.
Who is Mr. Ross?
25 A.
Yes.
166
I Q.
Mr. Ross reported it to you?
2 A.
He might have reported it to me, and I reported it up the 3
line.
I don't recall how that happened.
He might have by-passed 4
me and went directly to Larry Davison.
5 Q.
He, Mr. Ross?
t 6
A.
Yes, and I knew that bit of information.
7 Q.
A little more than a bit of information, don't you consider 8
that a serious incident?
9 A.
It could have been much more serious.
10 Q.
He could have pulled the trigger?
11 A.
Yes.
12 Q.
Don't you consider it serious having pointed a rifle at 13 an inspector?
14 A.
Yes.
15 Q.
Serious, does it meet significant standard to do something 16 about?
17 A.
Yes.
18 Q.
What did you do about it?
19 A.
All I did was report it.
20 Q.
You didn't do anything?
21 A.
It wasn't necessary.
22 Q.
Do you know whether or not the rigger's friend had a gun?
23 A.
The rigger's friend?
24 Q.
My point is, you may have addressed this.
This may have 25 corrected itself.
The man apparently quit, right?
j 167
I 1
A.
Yes.
2 Q.
What's to stop someone who is standing next to him or in 3
the same car or learning about it the next day from repeating 4
the same threat or one of equal or greater significance unless 5
you took some kind of corrective action?
6 A.
What corrective action can you take to keep someone from W
7 pulling a gun?
8 Q.
I don't know.
I'm asking you.
You don't know of any?
9 A.
I don't know of any you can take.
10 Q.
You're satisfied you did everything that needed to be done?
11 A.
Yes, I am.
12 Q.
Who was the worker involved?
13 A.
I don't even know the name.
I 14 Q.
Did you ever know the name?
15 A.
No, I didn't.
1-6 Q.
Did you ever ask?
17 A.
Yes, I'm sure I did.
18 Q.
Did they tell you?
19 A.
I'm sure they did.
I don't recall who it was.
20 Q.
You knew it at one time?
21 A.
I don't know the worker.
I was told the name, but I 22 really don' t know the worker.
23 Q.
But you were told the name?
24 A.
I'm sure I was.
-25 Q.
Did you make a written report?
168 4
_~
E I
1 A.
No, I did not.
2 Q.
Did you ever see a writing or document that reflected the 3
incident?
4 A.
No, I did not.
5 Q.
Do you know who the man worked for when he was on the job?
6 A.
No.
7 Q.
Do you know what crew he was in?
8 A.
I know he was on steel rigger crew, but I don't know who 9
his supervisor was.
10 Q.
Did you speak to his supervisor about the matter?
11 A.
No.
12 Q.
Is it accurate to say that is Mr. Ross's statement says 13 here no action was taken?
t 14 A.
As far as I know, there was no action necessary after the 15 guy quit.
16 Q.
Or taken?
17 A.
I don't know of any that was taken.
There might have been is some that was taken.
19 Q.
The next paragraph, Lindsey Harris, the same supervisor, 20 that's the supervisor who, according to Mr. Ross's opinion 21 here, by this man's supervision, the man with the rifle, this 22 same supervisor mentioned in the above incident, told Doug 23 Beam, Lane Freiz, Larry Davison, and Charles Baldwin in front 24 of Lindsey that he told Lindsey he was going to get his teeth 25 knocked out.
No action taken.
Do you recall that incident?
169 y
I-1 A.
Yes.
2 Q.
Did you remember a supervisor saying in front of Mr. Harris 3
he was going to get his teeth knocked out or words to that 4
effect?
5 A.
Yes.
6 Q.
What were the circumstances?
7 A.
I'm not sure.
I think Mr. Harris was doing random pre-a heat or interpass temperature check or something.
I'm not 9
sure.
He was doing inspection.
10 Q.
Random inspection?
11 A.
Yes.
And there was a disagreement that resulted from 12 that.
13 Q.
What was the nature of the disagreement?
(
14 A.
As I recall, the supervisor didn't agree with the' manner 15 in which the inspector was performing that inspection.
16 Q.
Can you explain it?
17 A.
The supervisor felt that he wasn't performing the inspection 18 appropriately, and he wasn't doing it-- what he was doing 19 wasn't appropriate in some way, and the manner in which he l
l 20 did it.
I don't recall specifically that, but that was the i
21 nature of the incident.
22 Q.
Was it a welding inspection?
I 23 A.
Yes, it was a welding inspection.
24 Q.
How do you do a random preheat?
25 A.
I'm not sure if it was a preheat or interpass temperature l
170
I 1
inspection that he was performing.
As I recall and Mr. Harris 2
was checking the temperature of the adjacent base material with 3
a temp stick to verify what the temperature was.
I don't 4
recall the specifics on what really happened.
I don't really 5
know if he checked the interpass temperature or preheat at 6
the time.
7 Q.
This is the time the weld was being performed?
8 A.
I think the welder was actually in the process of welding 9
the joint.
10 Q.
The inspector comes up to him and does a random check on 11 a piece of material?
12 A.
Yes and checked the material with the temperature indicating 13 crayon.
L 14 Q.
That's the temp stick you're talking about?
15 A.
Yes.
16 Q.
And found something that was in violation of a standard in 17 his opinion?
18 A.
In the inspector's judgment, it was a violation.
19 Q.
Was he trying to write it up as a violation?
20 A.
I don't recall if he did write it up or what really 21 happened.
22 Q.
Who would typically have done-- how would you write it up?
23 A.
If he had determined that would have been handled on a 24 Nonconforming Item Report probably.
25 Q.
Do you know whether a Nonconforming Item Report was 171 i
w~
.m
I 1
initiated?
2 A.
No, I don't.
3 Q.
The supervisor involved, who was the supervisor?
4 A.
I don't recall.
I can picture him, but I can't recall 5
what his name is.
6 Q.
Can you tell me what you know about him?
7 A.
I'just know that he was supervisor over steel rigging crew, 8
and that's about the extent of it.
9 Q.
Is he still working on the job?
10 A.
Yes.
11 Q.
Still doing supervising steel riggers?
12 A.
Yes.
13 Q.
Tell me what you remember about him, black, white, young, i
14 old, tall, skinny?
15 A.
He was a white guy.
He's probably in his fifties.
What 16 else?
17 Q.
Anything else?
Any other identifying about the man?
I'm la interested in finding out who he is, Mr. Baldwin, and it's a 19 matter like telling what color hair and what color eyes and i
20 how tall he is.
Tell me what you would tell somebody who is i
21 trying to track down a suspect.
l 22 A.
Mr. Ross doesn't mention his name in that?
23 Q.
No, sir, he doesn't say.
He says the same supervisor.
He 24 doesn't say.
25 A.
I don't know if it was the same supervisor, but I do 172 l
L
I I
remember the supervisor Mr. Ross is mentioning is a result of 2
Mr. Harris.
He is a supervisor that worked for Shorty Shelby 3
who is the Craft Superintendent, and I'm sure if you need 4
specifics--
5 Q.
Is that enough to identify him?
He works for Shorty Shelby?
6 A.
Yes, Shorty Shelby and was involved,in the Lindsey Harris 7
in that particular situation and I feel sure that's enough to 8
identify him.
9 Q.
Is this an accurate description?
10 A.
His first name is Tom.
I do recall that.
11 Q.
Is that an accurate description?
12 A.
What specifically are you talking about accurate?
13 Q.
The way he described'it there?
Id A.
I don't think Mr. Beam was involved in the situation.
15 Q.
All right, he wasn't present at the time?
16 A.
He wasn't present, no.
That's not a correct statement.
17 No action was taken.
18 Q.
What action was taken?
19 A.
I'm sure that Tom Mullinax, I do recall the guy's name, 20 Mullinax, I'm sure that he was severely reprimanded; in addition 21 to that, I really don't know what action was taken.
That was 22 handled in the craft management by the craft management.
We 23 don't get involved in the corrective action.
24 Q.
You took no corrective action?
25 A.
Other than making the appropriate management aware of that.
(
173
I l'
I Q.
.Who was that?
2 A.
That was Larry Davison, 3
Q.
Who did you make aware of it?
4 A.
I made Larry Davison aware of it.
We had a meeting where 5
we called these people in.
Larry Davison, Lane Freiz, myself.
6 Q.
Mr. Freiz is in construction?
7 A.
Yes, he's in construction and the Craft Superintendent 8
at that time.
The superintendent of the job over the Con-9 struction Department was present.
10 Q.
Who was that?
11 A.
We have had three or four.
You're about to pick my brain 12 today.
13 Q.
I'm trying to.
14 A.
I don't recall his name.
I will recall it later.
15 Q.
The action you took was to refer to construction management 16 and you're satisfied they took the appropriate action, is that 17 the testimony?
18 A.
Yes, I felt that's what was necessary to correct it.
19 Q.
That action was, as you said, to severely reprimand?
20 A.
I'm sure that was done, any sort of action.
21 Q.
The gentleman still works on the job, doesn't he?
22 A.
Yes.
23 Q.
Tell me what you know about the corrective action.
How 24 did you know of that and how do you know he was severely repri-25 manded, or are you just assuming?
g 174
1 A.
Just from the actions, I assume.
My observation of what 2
happened.
Shorty Shelby was the Craft Superintendent respon-3 sible.
He was reporting directly or indirectly through 4
another level of supervision; and as I recall, he was on 5
vacation and was called back in to handle that.
6 Q.
Mr. Shelby?
7 A.
Yes, that's what I recall.
8 Q.
Did you communicate that action, the corrective action, to 9
Mr. Ross?
10 A.
Yes, Mr. Ross was made aware of that that he was repri-11 manded, but Mr. Ross wasn't able to see anything other than 12 what I told him, so apparently he didn't accept what I told 13 him.
He didn't see anything on the surface to indicate that I
14 apparently.
15 Q.
He saw Mr. Mullinax back on the job?
16 A.
Yes, and he didn't see any other action that was taken 17 apparently.
I don't really know, but that was the feeling I 18 developed.
19 Q.
Well, as far as you know, there was no action that was 20 apparent to anybody else except to you; and as you related it 21 to someone else?
22 A.
Yes.
23 Q.
You're not aware of Mr. Mullinax being publicly reprimanded 24 in front of the craf t about the inappropriateness of his 25 behavior or anything like that?
175
I 1
A.
No, I don't think he was whipped or anything like that.
2 Q.
Or forced to sit in a room with a bunch of lawyers for 3
an e.. tire day?
John Bryant, this looks familiar.
Welder 4
told him to get off scaffold.
Told Charles B.
this was 5
interfering with our inspection.
No action taken. Parenthesis o
Welder later apologized for his conduct.
End parenthesis.
Had 7
problems with Ed McKenzie.
No action taken.
Is that the 8
John Bryant instance about the scaffold that we talked about 9
earlier with Mr. Bryant's notes?
10 A.
Could I see this?
11 Q.
Sure.
12 A.
This probably was the same instance about the scaffold.
13 Q.
What is the reference to Ed McKenzie, if you know, if 14 that's the name Ed McKenzie, it looks like.
15 A.
Ed McKenzie is a pipefitter supervisor.
I don't recall 16 any specific situations relating to Mr. Bryant.
17 Q.
John Rockholt shouldered by-- bad copy here-- Cathcart
[
18 it looks like.
CRB no action taken.
Do you have any idea what l-l 19 that reference is?
l 20 A.
Yes, Mr. Ross reported to me that Rockholt was shouldered I
[
21 in the parking lot on the way out and says this guy deliberatelf
(
r 22 bumped into him.
At the time, I don't even think he knew who 23 it was.
l 24 Q.
Do you know what that name is there?
l 25 A.
I thil.k you were correct. - I believe Cathcart is the name.
g 176
I 1
I believe that's correct.
2 Q.
Did you do anything about it?
3 A.
I really didn't know at the time who it was.
I really 4
didn't know any action I could take.
5 Q.
Because you didn't know who it was?
6 A.
I didn't know at the time.
7 Q.
When did you know it was Cathcart or that name tha', was 8
connected with it?
9 A.
I do recall that sometime later, Mr. Ross came to me and 10 had determined who it was and he was working in the building.
11 Q.
What craft?
12 A.
I'm not sure what craft he was working in.
13 Q.
Did you do anything about it when you learned the identity e
14 of the man?
15 A.
I didn't feel it was necessary.
I didn't know if it was 16 an accident.
I didn't have any reason-- you know, when you 17 have three or four thousand people going out a gate at one 18 time, it's very likely that someone could accidentally bump t
19 into you.
20 Q.
Rockholt seemed to believe it was work related?
21 A.
He thought it was deliberate.
I don't know that Rockholt 22 had been inspecting any of this guy's work.
23 Q.
You didn't take any action?
24 A.
I don't recall any.
25 Q.
It looks like problems with-- this is Rockholt again.
177 g
s
I 1
Problems with this is a guess, it's a very bad copy.
Mike 2
Brasell cursing an unprofessional.
It's a guess, attitude.
3 No action taken.
Do you know Mr. Brasell?
4 A.
Yes, there was action taken.
5 5
Q.
What was the action taken?
6 A.
At this time, this problem was brought to the attention 7
of the Personnel Relations Department.
It was handled 8
through Personnel Relations Department.
That was in the 9
Construction Department at that time when Quality Control was 10 under the Construction Department.
Il Q.
What did they do?
12 A.
They did an investigation of both sides of the disagreement.
13 Mr. Rockholt withdrew his charges.
We got the two people l
Id together.
That was Employee Relations.
Mr. Ross and I 15 with Ken Webber, Rockholt, and Brasell.
16 Q.
Ken Webber is in Employee Relations?
17 A.
Ken Webber was Mechanics Superintendent and the Employee 18 Relations representative, and we resolved the problem through 19 discussion.
Each side was investigated by the Employee 20 Relations and all this was brought out and after the discussion, 21 Mr. Rockholt withdrew his charges.
22 Q.
Did he say it didn't happen?
23 A.
No, it happened.
24 Q.
He was satisfied with the resolution?
25 A.
He was satisfied with the resolution.
It was resolved.
178
Q.
Did the craftsperson apologize?
A.
I really don't know exactly what happened in the situation.
2 3
Q.
Was it determined--
A.
It seemed to me at the time that Mr. Rockholt was satis-4 fied with the resolution.
5 Q.
Was Mr. Rockholt's charge substantiated or were they 6
7 unsubstantiated, if you know?
8 A.
I think it was determined that it was a disagreement and 9
a argument resulting from input from both parties.
10 Q.
On this next page, the name Jackson, Larry Jackson, is n
that right?
12 A.
Yes.
13 Q.
Larry Jackson.
Problems with Ed McKenzie.
No appreciable
(
14 action taken.
Who was Mr. McKenzie?
15 A.
He is a pipefitter foreman.
16 Q.
What do you know about that, if anything?
17 A.
Well, there again, you know-- I'm recalling a situation is from brief notes that are written by a supervisor out of 19 possibly thousands of things that this supervisor had in his 20 mind.
.I know the situation that did involve Mr. McKenzie and 21 Mr. Jackson.
22 Q.
What do you know about them?
23 A.
I know they got into an argument.
24 Q.
Did it relate to Mr. Jackson's inspection work?
25 A.
Yes.
179
\\
i Q.
Tell me about it.
2 A.
What would you like to know about it?
3 Q.
What were the circumstances?
4 A.
As I recall, there was some question about whether or not 5
the pipefitter was using an approved grinding disc.
6 Q.
Proper markings?
7 A.
Proper markings on the grinding disc, and there is some 8
question in Jackson's mind of whether the disc was identified 9
properly to be used on that piece of material that it was being 10 used on, so they got into a disagreement on the marking of the 11 disc.
12 Q.
What did Mr. McKenzie do?
13 A.
I don't really know.
I wasn't there, but I know both of v
14 them approached my desk in the Construction Office,and both of 15 them were terribly upset with each other as it appeared to me.
16 Q.
You saw that much, right?
17 A.
That's what I assumed from the way their expressions were 18 and some of the words.
19 Q.
They had been involved in some kind of fight?
20 A.
They had been involved in some type of word debate, I 21 guess you would call it, and they didn't agree with each other.
22 Q.
What did you do about it?
23 A.
My first objective was to try to get the situation under 24 control and to try to sit down and logically determine what 25 their problem was and what we could do to resolve the situation 180
1 and get both of the parties calmed down.
2 Q.
What did you do?
3 A.
I started going back and asking each of the men involved 4
what happened, you know, and trying to reasonably objectively 5
approach the situation.
6 Q.
What did Mr. Jackson have to say?
7 A.
He was making accusations that he had discovered the 8
craftsman using an improperly marked grinding disc, and he 9
approached him, angrily approached him or something, and he 10 came back or something and marked it, and Mr. McKenzie didn't 11 agree with the way he was describing the situation.
12 Q.
Was Mr. Jackson trying to write up an NCI?
13 A.
I think at that time he was trying, I believe, to write an 14 NCI.
I don't recall specifically, but I think an NCI was 15 involved in that.
16 Q.
Did the craftsman allegedly alter the marking while the 17 inspector was in the process of trying to originate an NCI?
18 A.
Yes, I think that's what it was.
Or the craftsman 19 allegedly altered the marking on the disc while the inspector 20 was trying to approach; the inspector indentified the improper 21 markings from some distance away, and I believe the inspector 22 was trying to get to him and get the disc and verify it was 23 correct and the inspector felt they had altered markings in the 24 process of him trying to get to the point--
25 Q.
That would be inconsistent with procedure if that happened?
181
(
1 A.
If he didn't have the disc, if it wasn't properly marked, 2
yes, that would be a violation of the procedure.
3 Q.
That would also be a violation to alter the markings while 4
the inspector was trying to perform an inspection?
5 A.
Yes, it would be misrepresentation.
6 Q.
What did you do, what else did you do?
What did you find?
7 How did you resolve this dispute?
8 A.
This went on through recourse procedure.
9 Q.
What recourse procedure?
10 A.
Employee Relations.
Recourse procedure through Employee 11 Relations Department.
You should have all the records.
12 Q.
I'm sure.
They threw some records at us.
Is that what 13 they did, Mr. Baldwin?
14 A.
They gave you everything you asked for.
15 Q.
I want to know what they did about this problem?
Did they 16 do anything about this problem?
l
(
17 A.
Yes, it was investigated.
h 18 Q.
What other resolving, do you know?
19 A.
They looked at it from every possible viewpoint it could 20 be evaluated from.
21 Q.
What did they do about it is what I want to know?
Did 22 they correct the problem or keep looking at it and write up 23 paper about it?
24 A.
Yes, the problem was corrected.
25 Q.
How, do you know?
i l
(
182
1 A.
It doesn't exis' anymore.
2 Q.
Did they correct the problem by seeing that the proper disc 3
was used and the craftsman didn't change the markings while 4
the inspector was trying to perform the inspection?
5 A.
Yes, proper action was taken on that.
6 Q.
What was that?
7 A.
Proper action was that.
8 Q.
What was that proper action?
9 A.
I'm not sure.
I don't recall that.
An NCI could-- if it 10 was handled on an NCI.
I don't recall specifically what 11 happened.
12 Q.
Has the NRC interviewed you with respect to these incidents 13 involving nontechnical concerns as characterized by the company,
t 1d the incidents of harassment?
15 A.
I have been interviewed by the NRC?
16 Q.
On these subjects?
17 A.
On a number of subjects.
I don't remember.
I'm sure these 18 subjects came up in the interview.
I don't recall specifically,
19 but I feel sure that was part of the interview.
20 Q.
Who interviewed you?
21 A.
Mr. Kim Van Doorn.
22 Q.
Anybody else?
23 A.
No.
24 Q.
When did Mr. Van Doorn interview you?
25 A.
Approximately six months ago.
I'm not sure.
183
l 1
Q.
About December of '827 2
A.
Yes, a few months back, yes.
3 Q.
Where were you when you were interviewed?
4 A.
I was at the construction site.
5 Q.
Did you go to his office?
6 A.
Yes.
7 Q.
How long did the interview take?
8 A.
Two days.
Two portions of two days.
9 Q.
How long?
10 A.
The first day was about two hours.
The second day was 11 about two hours, as I recall.
About four hours altogether.
12 Q.
Were you by yourself?
13 A.
Mr. Van Doorn and I.
(l 14 Q.
Just the two of you?
15 A.
Yes.
16 Q.
Did Mr. Van Doorn make a transcription of the interview, 17 take a tape recorder, was a court reporter there, were you 18 under oath?
19 A.
I don't remember.
I don't know if he did or not.
20 Q.
Were you under oath, do you remember?
21 A.
No.
22 Q.
Do you remember a court reporter being present?
23 A.
No one present except Mr. Van Doorn and I.
24 Q.
Did Mr. Van Doorn or others prepare a written statement 25 for your review reflecting your interview?
1
=w-a 4--w r
-.y-wy m-m,,
r n.-
m
-w--
v
-e
=
y 1
A.
No, I didn't see a written statement.
2 Q.
You never reviewed a written statement?
3 A.
No.
4 Q.
Were you ever asked to prepare an affidavit on the subject?
5 A.
With Mr. Van Doorn?
6 Q.
Yes.
7 A.
No.
8 Q.
Or anyone else from the NRC?
9 A.
No.
10 Q.
You told Mr. Van Doorn everything you told me on the 11 subjects of harassment?
12 A.
I answered his questions to the best of my ability.
I 13 don't remember what his questions were.
14 Q.
Did he ask you about the Bill Deaton incident with the 15 rifle?
16 A.
I don't recall that.
17 Q.
The Lindsey Harris incident with the threat to knock his 18 teeth out?
19 A.
He might have.
We talked quite lengthy, and I don't 20 recall specifically.
We talked about a number of situations.
21 Q.
How about John Bryant situations about throwing him off 22 the scaffold?
23 A.
I don't recall.
24 Q.
Or Rockholt incident about Mr. Cathcart or Mr. Brasell or 25 Mr. McKenzie?
185 g
I 1
A.
I don't recall any of those specifically.
2 Q.
Did Mr. Van Doorn ask any questions from the documents 3
I have shown you today?
4 A.
He asked me some questions from the Task Force about the 5
concerns presented to the Task Force.
6 Q.
Did he appear to have the final Task Force report?
7 A.
He had individual concern for the Task Force report is all 8
I saw.
9 Q.
The large volume that has been identified as Volume 1 10 of the Task Force?
11 A.
I don't know if he had that.
I only saw some of the 12 ones that were relating to me directly.
He probably did have 13 that.
l.
14 Q.
Mr. Baldwin, I have shown you a number of documents today 15 that are notes from Welding Inspectors that mention you by name 16 or' mention your initials or appear to indicate you.
Did 17 Mr. Van Doorn show you those notes?
18 A.
I saw some notes on some of the Inspector concerns that i
19 were taken from the Volume 2 of the Task Force, I believe.
I l
20 Q.
But not the notes I have shown you?
21 A.
I didn't see-- no, I didn't see those notes from 22 Mr. Van Doorn.
23 Q.
Have you seen these notes before?
24 A.
I have seen those.
I recall seeing those you have there 25 from Mr. Ross.
186 l
l
f 1
Q.
These are Mr. Ross Exhibit 5?
You have seen those 2
before?
3 A.
Yes, I think I have.
4 Q.
The Bryant notes I don't think you have seen before?
5 A.
I might have, but I didn't recall at the time.
6 Q.
Are you sure that all of the hardware problems that may 7
exist with welding at Catawba have been identified and correc-8 ted?
9 A.
What problems are you referring to?
10 Q.
I want to know if you know of any, sir?
11 A.
I know of nothing that hasn't been corrected or is in the 12 process of being corrected.
13 Q.
Are you sure that the concerns expressed by the Welding ld Inspectors have been satisfied?
IS A.
Been satisfied to the Inspector?
16 Q.
Have been satisfied.
'7 A.
Yes, they have been satisfied, yes.
la Q.
Are you aware of any notice that Duke Power Company I'
has posted with respect to the protection available for workers 20 who complain to the NRC or who make public any actual or 21 potential problems affecting the safety of the plant?
22 A.
Notices ~have been posted.
23 Q.
Yes?
24 A.
Normally I don't read the bulletin board, but I do know 25 each Inspector has been made aware that no adverse action will
(
187
I be taken towards them for any action they feel is necessary.
2 Q.
How do you know that?
3 A.
Because I have been present in a number of meetings they 4
were told that.
5 Q.
By whom?
6 A.
They were told that by George Grier, I believe, is one; 7
Mr. Larry Davison; Mr. Joe Willis.
8 Q.
When was that?
9 A.
I don't recall.
That's just general remembering these 10 meetings.
That came up.
11 Q.
How long ago was that?
12 A.
Within the last three months.
13 Q.
Is that a meeting in which Mr. McGarry was present?
id A.
It could have been, yes.
15 Q.
Were you at the meeting when Mr. McGarry was present?
16 A.
Yes.
17 Q.
Was that subject talked about then?
18 A.
I believe it was.
It has been mentioned several times l'
that no recourse will be taken against anyone, so I believe 20 that was specifically mentioned in the meeting with Mr. McGarry 21 Q.
You're not aware of any written instructions, letter, 22 notice posted, any written information that described the 23 provisions of the Federal law and regulations with regard to 24 protecting workers?
25 A.
It could very well be on the bulletin board.
I don't recall g
188 s,
{
k
U L
1 specifically.
I do know there's a number of things posted in 2
reference to the employees' rights and responsibilities.
3 Q.
Counsel, maybe you could help clarify that.
Has that 4
notice that the board directed the company to post with 5
respect to workers' rights been posted?
6 MR. McGARRY:
Yes, it has.
7 Q.
I don't have any interest in prolonging the deposition, a
Mr. Baldwin, but I would like a copy of that notice to use in 9
questioning Mr. Davison.
10 MR. McGARRY:
We'll get you a copy of that.
11 Q.
Mr. Baldwin, I appreciate your answering my questions.
12 That's all I have.
Thank you.
13 EXAMINATION:
(By Mr. McGarry) 14 Q.
I want to clarify the record.
I think a couple of hours 15 ago we were talking about the M-4, and I made a statement that 16 it wasn't related to the Task Force report, and I think it 17 was related.
I'm informed now M-4 was a modification to the l
18 Task Force report, and you have been furnished that document.
19 I have no questions.
20 21 C. R.
BALDWIN 22 23 l
1 24 25 189
(
t i
I' 1
STATE OF NORTH CAROLINA
)
)
CERTIFICATE 2
COUNTY OF MECKLENBURG
)
3 4
9 5
I, the undersigned Commissioner and Notary Public, in and 6
for the State of North Carolina, do hereby certify that 7
C. R. Baldwin was duly sworn prior to the taking of his 8
deposition.
9 I do hereby certify that the foregoing one hundred and 10 eighty-nine pages constitute a true and accurate transcript 11 of the evidence given by the said witness as taken down by me 12 and transcribed under my supervision.
13 This the twenty-fourth day of July, 1983.
14 l
15 BARBARA V. HAAS 16 Commissioner and Notary Public My Commission Expires:
18 April 23, 1987 19 20 21 22 23 24 25 190
I INDEX 3
2 Exhibit 1 Page 65; Line 17 3
Exhibit 2 Page 65; Line 18 4
Exhibit 3 Page 73; Line 9 5
Exhibit 4 Page 96; Line 24 6
Exhibit 5 Page 141; Line 25 7
8 9
10 g
11 12 N
13
\\
14 15 16 17 18 19 20 21 22 23 24 25 191