ML20078L752
| ML20078L752 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/01/1983 |
| From: | Grogan J DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20078L617 | List: |
| References | |
| FOIA-83-434 NUDOCS 8310240058 | |
| Download: ML20078L752 (27) | |
Text
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UNITED STATES OF AMERICA '
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD s
In the Matter of: )
)
DUKE POWER COMPANY, et al.) Docket Nos. 50-413
) 50-414 (Catawba Nuclear Station, )
Units 1 and 2) )
DEPOSITION g :
JAMES EDWARD GROGAN July 1, 1983 1:45 P.M.
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Eselyn Berger Associates 8310240058 830810 STENOTYPE REPORTING SERV!CE l PDR FOIA P. O. BOX 19444 l AHLERS83-434 PDR CHARLOTTE. NORTH CAROLIN A 28219
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. o L A W Y E R'S' N OTE S
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9 APPEARANCES:
ROBERT GUILD, ESQ.
Columbia, S. C.
4 Counsel on Behalf of Intervenor, Palmetto Alliance Corporation RONALD L. GIBSON, ESQ.
6
. Counsel on Behalf of Applicant, Duke Power Ccmpany 8
George W. Grier 9
Duke Power Corapany 10 Glenn H. Bell u Duke Power Company p~
- toger Ouellette Ouke Power Cc:r.pany I
P.ichael F. Lcue Palmetto Alliance U8 15 Palmetto Alliance le Betsy Levitas l_'
Oarolina Environmental Study Group 18
- 3111ye Garde 19 l
20 21 l g INDEX 23 Direct Cross 24 John C. Rogers 4 --
25 gvELyN SERGER ASSOCIATES. STENOTYPE REPORTING SgnygCE. CMARLc?TE. NORTM CAROUNA
r I
2a g EXHIBITS 2
Number Descrietien Page ,
3 One Grogan Exhibit One 12 4
5 6
7 8
9 10 11 12 13 14 15 16 i
17 18 l
! 19 20 21 22 23 24 l
EyELym gERGER ASSOCIATES. STENOTYPE RSPOftTsNG SERVICE. CHARLOTTE. NORTM CAnOUNA C-
1 The deposition of James Edward Grogan is taken at the 2
Corporate Offices of Duke Power Company, Charlotte, North 3
Carolina, on this the 1st day of July, 1983, in the presence of 4
Robert Guild, Attorney for the Intervenor, and Ronald L. Gibson, 5
Attorney for the Applicant. ,
6 All formalities as to caption, certificate and 7
transmission are waived. It is agreed that Lynn B. Gilliam, 8
Notary Public in and for the State of North Carolina, may take 9
said deposition in machine shorthand and transcribe the same to 10 typewriting. Said deposition is taken subject alone to testi-11 many for competency, relevancy and materiality; and all objections, 12 save as to the form of questions asked, are reserved until the 13
< hearing.
14 15 JAMES EDWARD GROGAN, 16 tiaving been first duly sworn to tell the truth, was examined and 17 testified as follows:
18
, 19 MR. GIBSON: I assume we are pro:eeding under 20 the same Stipulations, all objections are reserved 21 except as to form?
22 MR. GUILD: That is fine.
23 MR. GIBSON: And the same Stipulation regarding l 24 non-stenographic means?
- 25 l
M?.. ?"ILD: : .
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1 DIRECT EXAMINATION 2 BY MR. GUILD:
3 Q State your full name for the Record.
4 A James Edward Grogan.
5 Q And your business address?
6 A P. O. Box 33189, Charlotte.
7 Q Here at the Charlette Offices of Duke Power?
8 A Yes, and Wachovia Center on the Twenty-Second Floor.
9 0 What position do you hold with Duke Power?
10 A Manager of Construction Resources.
11 Q And when did you join Duke Power Company?
12 A March 1st, 1978, 13 Q In what capacity, sir?
14 A As Manager of Employee Resources and Development.
15 Q Employee Resources and Development?
16 A Yes.
17 Q What were your responsibilities generally in that 18
?osition?
19 A When I came here it was to develop a Personnel Program 20 for the Construction Department.
21 Q All right, and what other positions did you hold with 22 Duke?
23 A None other than the two that I've mentioned.
24 0 When did you become Manager of Construction Resources' '
25 A I believe that it was about April of '81.
SVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Grognn - Dirtet 5 1 0 -
All right, and what are your duties in your present 2 position?
3 A My responsibilities are to advise and assist the 4 Vice President of Construction and the other Managers in plannin;r 5 and directing Employee Relations and Labor Relations activities; 6 and also for assuring the collection and analysis of 7 information about budgeting and planning, scheduling, costs, 8 materials, and other construction services.
9 Q All right, sir; to whom do you report?
10 A R. L. Dick, who is Vice President of Construction.
11 Q Do you have any employee:2 report to you, sir?
12 A I presently have two who report directly. Let's see, 13 I made a changer indirectly, probably two hundred fifty. ,
14 O All right, sir; and the two that report directly to 15 you --
16 A The Manager of Construction Personnel Administration l
17 and the Manager of Construction Services.
18 Q And who is the first person?
19 A David Abernathy and the second one is Ray Hollins.
20 0 Could you give me Mr. Hollins' title?
21 A Manager of Construction Services.
22 Q And just give me kind of a thumb-nail sketch of 23 how the responsibilities break down between Mr. Abernathy and 24 Mr. Hollins?
25 A one is responsible for Personnel Services and the EVELYN SERGER ASSOCIATES. STENOTYPS RSPORTING SERVICE. CHARLOTTE. NORTM CAROUNA 1
Grogan - Dircct 6 1 other is responsible for Construction Services.
2 Q Mr. IIollins is the Budgeting and Planning, Financing 3 and Construction?
4 A Yes.
5 Q And Mr. Abernathy, the Personnel?
6 A Yes.
7 Q Now the other people that you say indirectly report 8 to you?
9 A Those are Personnel Managers at the locations and to their staffs, which include Employment, Employee Relations, 11 Training, safety, Security.
12 O What is the relationship between your area and the 13 Corporate Employee Relations Staff?
14 A Our relationship is one that we follow corporate 15 policies and procedures that are developed and implemented on a 16 corporate basis. The recourse procedure goes through the 17 Corporate Relations function.
IS Q But the Employee Relations in the field report to you?
19 A They report to the Personnel Manager who reports 20 indirectly, functionally, now reports functionally to David 21 Abernathy. Until just last month they reported directly to me 22 and now we have changed that.
23 Q How are the Employee Relations' functions at the 24 corporate level distinguished from the Employee Relations' 25 function in the field reporting directly to u?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAROUNA
Grogan - Direct 7 1 A Employee Relations functions in the field handle all 2 Employee Relations problems or Empicyee Relations' Programs on 3 a local basis. If there is a specific need or a recourse that 4 goes to another level, then the corporate folks get involved.
5 Q What other responsibilities would the Corporate 6 Employee Relations Staff have? Mrs. Addis for example?
7 A If there was a problem we had that we needed consul-8 tation or counseling on, we would contact her expertise.
9 Q A source of expertise?
10 A Yes.
11 Q And in addition to that they handle the higher level 12 recourse procedure?
13 A Yes.
14 Q All right, sir; I'm trying to put my hands on a 15 document, I am afraid I will shift gears a little bit here.
16 Are you familiar with the decision made in about July of 1981 to 17 reclassify the position of Welding Inspector, Mr. Grogan?
18 A No, I am not fully familiar with that. That occurred 19 in the QA Department.
20 Q You are aware of that reclassification?
21 A I am aware of that, yes.
22 O Are you aware of the Employee Recourses that were 23 filed by a number of Welding Inspectors as a result of that 24 reclassification?
25 A I am aware that recourses were filed, yes. I am not EVELYN EENGER ASSOCIATES STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROLINA
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Grogen - Dircet 8 1
aware with the details of them.
2 O What was your involvement in either the reclassifica-8 tions or the recourses that were filed as a result of that, sir?
4 A None.
5 Q What was your involvement in responding to the 6
recourses that were filed?
7 A None. To the best of my knowledge that was handled 8
by Corporate Employee Relations folks.
9 Q What was your involvement in resolving the recourses?
10 A No direct involvement.
II Q What involvement did you have, Mr. Grogan?
12 A The asly involvement that I could say that I had of 13 any kind was that there was a person in our department who served on a task force. Other than that, I don't know.
18 Q Who was that?
16 A Steve VanMalasen.
II Q How do you spell his last name?
l 18 A vanMalssen, I believe.
19 Q And what did Mr. VanMalasen do at that time?
20 A He served on the task force. I don't know the detailm 2I of it.
22 Q What was his job in your department?
23 A He is a technical person who deals with technical 94 problems.
25 Q I'm not sure I understand in what recard, in what way EVELYN SERGER ASSOCIATES. STENOTYPE RSpoemme SSRviCE. CHARLOTTE. NORTM CAROUNA
Grogan - Direct '
I is he in your department?
2 A Within construction Services there are Technical 3
Services; and Mr. VanMalssen is a resource of expertise in 4
welding.
5 Q What is his job title?
8 A He is, to tell you the truth, I don't know his exact I
job title. He is an Engineer.
8 Q All right, sir; and to whom does he report?
9 ns.
A He reports to Ray 10 Q He does now?
II A Yes.
12 Q And did at the time he served on the task force?
I3 A I believe so.
I4 Q Mr. Grogan, did you have occasion to participate in 15 the processing of the Welding Inspector Recourses above the 16 second level at the point.where they were presented to Mr. Lee II for Resolution or when Mr. Lee's decision on those recourses I8 was reached?
19 A No , sir, that is handled through Employee Relations, oo the Corporate Employee Relations Department.
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Q Did you participate in implementing his decision on 22 those recourses?
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A I need to ask him a question.
24 MR. GUILD: Sure, go ahead.
25 Nhereunen, the Witnaam anel Mr. dihann ennfarra/
EwSLYN SENGE R ASSOCIATES. STENOTYPE REPONflNG SERvtCE. CHAnLOTTE. NORTM CA.mOUNA
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10 Grogan - Direct I and the deposition resumed as follows:)
2 3 BY MR. GUILD:
4 Q Yes, do you have an answer?
5 A I did not participate in implementation of the Resolu -
6 tion of the Recourse. However, at the time I did communicate.
7 I was given information that the decision had been made and I a did communicate to our Management at the sites that a decision 9 had been made.
10 Q And where did you get the information from?
11 A From Bob Dick.
12 Q Eow did you come by that information?
13 A It was passed, I don't know if it was verbal; I don't 14 remember if it was verbal or a memo of some kind. I'm not sure.
15 O Did you meet with Mr. Dick or others to discuss the 16 communication of that decision?
17 A Discussion occurred between Mr. Dick and myself, yes.
18 Q What was that discussion?
19 A That we would communicate through our normal channels 20 of communications, letting our supervision know so that if they 21 were asked about it they would know a decision had been made.
22 It would not be a bunch of rumors.
23 Q Did you communicate with anyone else concerning 24 communication of that decision?
25 A Not other than Managers at the site.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAmouMA
Grogan - Direct 11 1
Q Before you did that did you speak with Mr. Dick or 2
anyone else in Management regarding the decision?
3 A Not to my knowledge.
4 Q Did you ever talk to Mr. I,ee about it?
5 A No, sir.
6 MR. GUILD: I am trying to put my hands on a 7
letter, and maybe I could save a little bit of time 8
and conclude this pretty quickly. Do you have a copy 9
of a letter that Mr. Grogan sent to those Managers; 10 and I want to get him to identify that?
11 MR. GIBSON: Do you remember which Attachment 12 it is attached to?
13 MR. GUILD: I'm afraid I don't; that is what I 14 was looking for the file.
15 MR. GIBSON: Let's go off the Record, I have 16 some of the separat7. attachments in my office and 17 we don't have to look through the whole stack.
18 (Whereupon, the deposition recessed at 2:06 19 and resumed at 2:08 p.m.)
20 21 BY MR. GUILD:
22 Q Mr. Grogan, I want to show you a document dated 23 January 22, 1982, and ask if you can identify that as the 24 communication that you just had reference to to the Site 25 t".agT Tit 'i.di;0ti.g)?
EVELYN SE AGER ASSOCIATES. STENOTYPE REPONTING SamveCE. CNARLOTTE. NofrTM CAROUNA
Grogan - Direct 19 1
A Yes. That was my reference a minute ago when you aske i 2
the question about Resolutions.
3 Q Right, and attached to that is a communication from 4
Mr. Lee?
5 A To J. R. Wells.
6 Q What is the date?
A January 22nd also.
MR. GUILD: Let's mark that Exhibit One to 8
Mr. Grogan's deposition.
10 (Whereupon the document referred to as Memo 11 from Mr. Grogan dated January 22nd, 1982, with attached Memo from Mr. Wells was marked and received by the Court Reporter as Grogan Exhibit One and entered into the Record.)
15 16 (Whereupon the deposition recessed at 2:09 p.m.
17 and reconvened at 2:12 p.m.)
18
,!!Y MR. GUILD:
20 Q Mr. Grogan, this is the communication you had reference 21 to?
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A Yes.
23 Q Correct?
24 A Yes, sir.
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Grogan - Direct 13 1
A This to the Project Manager, yes.
2 0 All right, sir; the substance of the memo was a 3
product of your discussions with Mr. Dick?
4 A Yes.
5 0 And what of the substance was Mr. Dick's instructions 6
to you in identifying, please?
7 A Essentially what is here, that QA Employees exercise 8
their rights and a decision had been made and it was a final 9
decision; and our supervision has the responsibility to support to it.
11 Q Mr. Dick asked you to include those points?
12 g gem not sure those are the exact points, but this is 13 a summary of our conversation and discussion that we had about 14 Mr. Lee's memo, I am sure.
35 0 Now did Mr. Dick indicate that he had received 16 instructions on a manner in which that decision was to be 17 communicated?
18 A No, sirs not to my knowledge.
18 Q Do you know whether or not Mr. Dick comunicated with 20 Mr. Lee about the matter?
21 A No.
22 O He didn't or you just don't know?
23 A I just don't know.
24 O Now the memo that is attached is the memo from Mr.
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Lee to Mr. Wells; is that correct?
EVELYN SERGER AS$cCIATES. STENOTYPE REPORTihe SERVICE. CNARLOTTE. NORTH CAROUNA
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Grogan - Dircet 14 1 A That's correct.
Q Why is it that the memo from Mr. Lee was not to be 2
3 copied and circulated as you instruct in your January 22nd memo?
4 4 A Many times we feel the most effective communication 5 is person to person communication; and many times the written 6 word is misinterpreted. A: 1 we wanted the same understanding 7
through our supervision in case employees asked supervisiop a they would know about it, be informed about it.
9 We thought this was the best way to do it.
10 Q Your opinion was that oral explanation would be more 11 uniform and less subject to misinterpretation than a written 12 document?
13 A Yes, it is short, it is to the point. There are only 14 about three points to be covered. It is fast.
15 Q Help me understand the basis for the second to the 16 last paragraph, " Construction Supervisors are expected to suppor t 17 this decision in their action and conversations. Under no 18 circumstances should they act in a sneering, taunting, or 19 condescending manner toward those affected by the decision."
20 Help me understand what that was intended to 21 convey.
1 22 A well, we have a large number of people on that site 23 and they are human beings and we wanted to assure that no matter 24 vhat discussions folks had in the past, there was no I told you 25 so or any of that kind of conversation going on.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SENytCE. CMARLOTTE. NORTH CAROUNA l . _ ___ _ . . _ _ , _ . _ . _ _ . _ _ - - ._ _ .-.._ _ _ _____ _ -__ ____ __ . ._ .__ _ _ , _ _
Grogan - Direct 15 1
Q Did you anticipate there might be?
2 A I didn't know, it is a good reminder.
3 Q Was that directed at people in the Construction 4
Department, Construction Supervisors, if you are the Constructio n 5 supervisor?
6 A Yes.
7 Q How abcut folks in the Quality Assurance Department?
8 A I don't know about them.
9 Q All right, sir; the last paragraph, the reference is 10 to calls from the news media. Why did you include that referenca?
11 A I feel it is better for there to be one source of 12 contact between the news media.
13 Q Why did you anticipate there may be a need to note 14 the calls for the news media?
15 A I don't know other than that there were a number of 16 them and I don't know how many recourses there were at that time 4 17 Secause of the volume of it there is always that possibility.
18 '
there is that possibility on any controversial issue.
19 Q Were you aware of any communications from the news 20 media?
21 A No, I wasn't.
22 Q Would you have been?
23 A Not likely unless they contacted one of our folks.
24 Q What do you mean by that?
25 A One of the Construction Site people, you know, a tytLYN SERGER ASSOctATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NOsrTM CAROL.lNA
Grogan - Direct 16 I
Manager at the Site.
2 Q All right, sir; help identify, if you would, the 3
people who were to receive the memo that you have there.
A George Grier at that time was the Project Manager at 5
Oconee. Joe Moore was the Project Manager at McGuire. C. O.
6 Patterson, at Cherokee; John Rogers at Catawba and Carry York 7
C. F. York at Mt. Holly Station, Support Division.
8 Q And all of those had Inspectors working for them
'affected by that decision?
10 A No, none had Inspectors affected by that decisien.
11 They arc the Manager of that Construction Project, not Quality 12 Assurance.
13 Q Right; they all had Inspectors working in there, at 14 their Stations or in t. heir line areas of responsibility?
15 A No, not that were involved in this recourse.
16 Q Which of those did, as you understand it?
17 A None of them.
18 Q Mr. Rogers at Catawba, and he had no Inspectors at 19 l Catawba who were affected by the recourse?
t 20 A No; those-were Quality Assurance Inspectors, not l 21 l Construction.
22 O I am not trying to be overly technical; but which of 23 those individuals had Quality Assurance Inspectors working at I ?4 i
t their sites who were affected by this decision?
N l A Mnna_
l evetTN senosa associATus. sTsNOTTPS R$PONMNG SERvtCE. CHARLOTTE. NOWN CAROUNA
, , Grogcn - DirOct 17 1
Q Mr. Rogers didn't?
2 A No.
3 Q There were not Quality Assurance Inspectors affected by the decision?
5 A There were Quality Assurance Inspectors, but not unde:r 6
the supervision of Mr. Rogers.
7 Q You are communicating this to Mr. Rogers for a 8
purpose.
9 A We are communicating to him to communicate to his to Supervisors so they will be aware a decision had been made and 11 when they hear talk about it they will know a decision had been
- nade, and it is not just talk going around.
13 l
Q Since Mr. Rogers was going to have to communicate to 14 bonstruction people who would be working with Welding Inspectors 15 at his site, does that ,same relationship apply to Mr. York, Mr.
16
- Patterson, Mr. Moore, and Mr. Grier?
17 l A There would have been at McGuire at that time, there 18 l probably were Inspectors. At Oconee and at some areas there would 19 have been a limited number of Inspectors that were associated 20 itith the Oconee Construction folks.
21 At Cherokee on a periodic basis I think there were 22
- tnspectors, I don't know if there were any permanent Inspectors.
23 1:ertainly there were no Welding Inspectors there at that time.
24 This is '81, I am trying to get my dates straight. I don't 25
< h i nic +.ha rm war. m_t cherekee et tg3g gi 3, 9.7 gig y leyfe ;;g7 EVELYN SERGER ASSOCIATES. STENOTYPE REPOff71NG SERVICE. CHARLOTTE, NORTM CAROUNA i
Grogan - Dircct 18 1 Q Mt Holly?
2 A Mt. Holly, none that would be affected. I can't 3 think of any Welding Inspectors there.
4 Q All right, sir; if he had folks working on a nuclear 5 project, this is Support Division, if he had folks working on a 6 project --
7 A He would ccme in contact with the Welding Inspectors.
8 Q Beyond contacting the Construction Supervision, did 9 you have any other involvement responding to the Welding 10 concerns or responses to the Welding Inspector concerns at 11 Catawba?
12 'A Nor. Well, wait a minute --
13 MR. GUILD: Take a moment with your lawyer.
14 (Whereupon, the Witness and his counsel consulted 15 and the deposition continued as follows:)
16 THE WITNESS: Prior to January 22nd, this was 17 back in December sometime in '817 IS 19 BY MR. GUILD:
20 Yes, sir.
Q 21 A Our Management group communicated to all Supervision 22 at Catawba that to eliminate any uncertainty about what the 23 role of Construction was, the Project Manager consnunicated to 24 his staff who communicated to the other lines of Supervision 25 that the Construction job is to be built with quality and Quality EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SENVICE, CMARLOTTE. NORYM CAmouMA
Grogan - Direct 19 1 Assurance is to inspect it.
2 And I met with John Rogers and Charlie Acock about 3 that communication.
4 0 Who is Mr. Acock?
5 A He is the present Manager of Construction.
6 Q What was he at that time?
7 A He was the General Superintendent.
8 Q Over Consts.uction Craft?
9 A Yes.
10 0 Now what position is Mr. Acock?
11 A He is now Construction Manager.
12 Q At --
13 A At Catawba.
14 O How did that meeting happen? First of all the folks 15 at the meeting of your Manage 7 ant Group, when did that happen?
16 You said December of '817 17 A Yes, sometime in '81.
18 Q Who was involved in that meeting?
19 A Rogers and Acock and myself.
20 Q That was the Management Group that you are talking 21 about? You said first that your Management Group met and 22 discussed the matter and you communicated it?
23 l A John Rogers communicated to his Management Staff, l 24 Charlie Acock being one of them. He first talked to Charlie and 25 communicated through Construction and then thought it would be a EVELYN SERGER ASSOCIATES STENOTYPE REPORTING SERvtCE. CHARLOTTE. NORTM CAROUNA
. . Grogan - Direct 20 good idea to conatunicate to all his staff.
Q Your meeting was with Rogers and Acock?
A Yes.
3 Q Describe that meeting.
4 A Actually the meeting was just to follow up to see that 5
that action had been taken.
6 Q All right, what preceded that? What was your involve < -
7 g
ment that preceded the instructions?
g A I had talked with John Rogers. We had been hearing
- * ** *** "** * "f"' " $"" 9" "9 10 feedback that 31 there had been some confusion about what the role was sometimes between construction and Quality Assurance; and to make sure that 33
,3 there was no misunderstanding of that, after conversations we 14 decided that it was best.
Q Did you prepare written descriptions of that instruc-15 16 g A I did not prepare a written description of that instruction. I did write a memo to, I believe I wrote it to 33 19 o a er e mee ng wM Joh and Gade, temng b go what we had done.
21 Q How did it come to your attention that there had 92 been questions or confusion about those roles of construction
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ver-23 Sus A I'm not really sure of that. That has been a year or 24 25 year-and-a-half or so ago. I don't know if it came through EVELTN SERGER ASSOCaATES. STENOTTPE REPORTING SamveCE. CMAleLOTTE. NORTM CARouMA
Grogan - Direct 21 I
feedback they had been getting, I den't know if it came from 2
John or from a recourse.
I don't know. In QA I just got the word and feedback 4
was coming that had occurred. We wanted to be sure there was no 5
confusion, no misunderstanding about the role of Construction.
6 Q Were you aware of a meno that Ms. Gail Addis prepared for Mr. Wayne Owen on relating concerns that had been expressed 8
to her in interviews with Welding Inspectors and a variety of 8
other inspectors?
10 A I have a memory that I saw the memo or it was passed through; but I don't remember the details of it.
12 Q That memo would have been semothing that you would I3 have seen before the meeting that you are talking about?
A I don't know the time relationship.
15 0 If you accept that memo has been identified, that was I
the Third of December --
17 A This occurred in December sometime, so it would
- 18 aave been a result of that.
18 O All right, sir; were you aware of the implementing 90
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t by Mr. Lee on the Fourth of December of a task force to investigate 01 concerns expressed by Welding Inspectors?
22 A Yes.
23
- 0 Would this instruction and meeting have followed thatP t
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l Nould you have done this after Mr. Lee's memo of the Fourth of I 95 3ecember?
evstyn senose asocuras. stenorres menontwo suavice. cwaatorra. aonrw caaouma
l Grogan - Direct 22 1
1 A I don't know the dates, but it may have been. But not i
2 I believe John communicated -- I don't know what the date on it 3 was, I really don't know what the date was -- but the date of 4
the official communication from John to Charlie.
5 Q How was the communication to be made? Was there any 6 written communication describing the role of QA vs. Construction?
7 A Not that I know of.
8 Q
- Do you recall discussing the subject of whether or no b 9
Welding Inspectors, particularly, or Inspectors, generally, had 10 the authority to instruct craft in the performance of craft work 11 involved, which was the subject of an inspection?
12 A That is what the conversation was about with John 13 Rogers and Charlie, to make sure there was no misunderstanding 14 about that.
15 Q What was your understanding of the proper distinction 16 between the role?
17 A Construction building and QA in inspecting to verify 18 that we built according to standards.
l
! 19 Q Was it your understanding that it was or was not
'N appropriate that Inspectors instruct craft in the proper per-21 formance of say welding?
22 A It is my understanding it is not proper for QA to 23 instruct Construction.
24 Q And that was the substance of the conversation that M
went back, instructions that went back down to craf t and QA7 EVELYN SERGER ASSOCIATES, STENOTYPE REPORTING SERVICE. CHARLOTTE NORTM CA40UNA
Grogan - Dircct 23 I i
I 1 A Yes.
2 Q After that time, after the December period and after 3 the Resolution of the Recourse, are you aware of further efforts 4 to instruct Inspectors, particularly Welding Inspectors, on the 5 proper relationship with a Craft?
6 A No, not specifically; that was handled, I assume it 7 was handled in OA by QA's folks.
a Q Are you aware of any training or instructional 9 materials on the subject of the relationship between QA and Craf b?
10 A Not specifically, no.
11 Q Who would be responsible for that or would know of 12 that?
13 A The QA Management, I don't know whether that would be l 14 Neal Alexander or somebody at Technical Cervices. I don't know l
15 their organization that specifically.
16 Q Have you ever heard of a film called The Inspector?
17 A Yes, I've heard of it.
18 Q Were you aware where that was used?
19 A That was in QA.
I' 20 Q 9o you know whether they have a training --
21 A Yes, they have a training area.
22 Q And I believe Neal Alexander is responsible for that 23 area?
24 A Yes.
25 Q Did you have any involvement in either investigating EVELYN SENGER ASSOCIATES. STENOTYPG REPONTING SERVICE. CMARLOTTE. NONTM CAROUNA a-- , ,. , , . , - - - - - ,- - , . - , - - . . - , - - - - - . . . ~
Grogan - Direct 24 1
or implementing the concerns that were considered by the Welding 2 Inspectors Task Force or the recommendations of that Task Force?
3 A Not in implementing; no.
4 Q How about the first part of that?
5 A Lther than what I mentioned earlier, Steve VanMalasen's 6 involvement being on.the task force.
7 All right, sir; I believe that is all I have.
Q Thank 8 you, Mr. Grogen; I appreciate your coming by.
9 FURTHER THE DEPONENT SAITH NOT.
10 (Whereupon, the Deposition was concluded at 11 2:40 p.m.)
12 .
13 14 I, James Edward Grogan, hereby certify that I have 15 read and understand the foregoing transcript and believe it to 16 be a true, accurate and complete transcript of my testimony.
17 18 James Edward Grogan l 19 l
- 20 This Deposition was signed in my presence by 21 James Edward Grogan on the day of July, 1983.
( n l .
23 l
24 Notary Public 25 EVELYN SERGER ASSOCsATES. STENOTYPE REPORTING SERVICE, CHARLOTTE. NORTM CAROUNA I
1 CERTIFICATE 2 STATE OF NORTH CAROLINA 3 COUNTY OF MECKLENBURG 4
I, Lynn B. Gilliam, do hereby certify that the 5 deposition of James Edward Grogan was by me reduced to machine 6 shorthand in the presence of the Witness, afterwards transcribed 7
upon a typewriter under my direction; and that the foregoing 8
is a true and correct transcript of the proceedings.
9 I further certify that these proceedings were taken 10 at the time and place in. the foregoing caption specified.
11 IN WITNESS WHEREOF, I have hereunto set my hand at 12 Charlotte, North Carolina, on this the
- day of July, 1983.
13 14 15 16 Lynn B. Gilliam 17 Court Reporter 18 19 20 My Commission expires May 12,,1989.
21 22 23 24 25 avstv= sanaan assocures. sranorres menonrino senvies. ematorra. nontw camoum
l Q ; .' -
.g f
- ,- CONFIDENTIAL l
January 22, 1982 G W.Grier l' AKMoore 0 Patterson -
. J C Rogsrs l C F yed ,
i Se: @ Recourse you may use the attached memo when explaining Mr f.ee's decision Monday to supervision at your location. However, the memo is g to be copied or circulated.
The ma. lor points you should bring out Monday are:
. 1. @ employees have exercised their rights under the recourse
! procedure.
l
- 2. The recourse was taken to the final step, review by the company
- president, whose decision is binding.
3 After a thorough review, Mr Lee decided that the existing pay grade for Inspectors is proper and will not be changed.
- 4. For those affected by the decision, Mr Lee has called for a
v special consideration to any request for transfer to a craft position.
- 5. Mr Lee has also stated: "Itisabsolutelyessentialt$atthis decision be supported by all levels of supervision...."
Please emphasize the last ooint. Construction supervisors are expected to support this decision in tnelr actions and conversations. Under no circisn-stances should they act in a sneering, taunting, or condescending menner toward those affected by the decision.
t l Should you or anyone on your staff recalve calls from the news media, please i refer them to Ken Clark or Mary Cartwright in Corporate Comunications. If you have questions on the recourse or Mr Lee's decision, please contact me.
5 E Gregen es: R L Dick .
JEE:eJw O
&9;J/M
&~47 -
a . m .. .
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- t. ..
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January 22, 1982 J R Wells Several Welding and Maintenance Inspectors at Oconee, McGuire Operations and Catawba have exercised their right under Duke's Employee Recourse Procedure to ouestion the change in pay grade (from grade 11 to. grade 10) implemented in their positions last July. The reccurse has gone to the third step, the President of the company.
. One can understand how a person would feel upon learning that his or her job
- was reclassified at a somewhat Tower pay grade than before. I understand and am sensitive to the concerns of these fclks in the Quality Assurance Department.
The-matter has been thoroughly investigated,.and I have personally reviewed
- the results in great detail. Whereas the work of these folks is important to our overall company success, out of fairness and equity each job must be evaluated on its true merits.
In short, My decision on this recourse was mailed to those employees today.
the decision is that the existing pay grade (pay grade 10) is the proper pay grade for their positions; therefore, no action regar. ding pay will be forth-coming as a result of this recourse. The decision also ecmits to give special -
consideration to any request for-transfer to craft positions by any of the employees in the classifications where the recourse was initiated, Welding -
l I
h Inspector "A" or Maintenance Inspector "A".
As is stated irr the Employee Recourse Procedure, "the decision of the. President . . .
shall be final and binding on all concerned." It is absolutely essential that this decision be supported by all levels of supervision and management involved.
I am counting on each member of that management team to make sure that their personnel support is late and positive in nature.
On Monday, January X,.1982, I ask that the supervisors of the classifications involved Welding Inspector "A" and Maintenance Inspector "A" inform their employees that special cons,1deration will be given to any transfer requests initiated this week to the Construction crafts. This will apply to employees who were in their present classification on July 6,1981.
I ma deeply convinced that this decision is the proper one, and I know that supervisors will demonstrate their support of this decision in talkinti with the affected persons, and at the same time convey to them management's confidence in them and their contribution to our success.
l W 5 Lee President .
W5L/ak bec W H'0 wen, A C Thies, R L Dick, W 0 Parker m ,_ __,,,---,.._--.,- - %, , . . , _ . , _ _ , ,