ML20078L757
| ML20078L757 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/07/1983 |
| From: | Bradley W DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20078L617 | List: |
| References | |
| FOIA-83-434 NUDOCS 8310240059 | |
| Download: ML20078L757 (56) | |
Text
i ,
UNIT E D STATES OF A ME RIC A NUCLEAR REGULATORY C O M MIS SIO N 1
BEFORE THE A T O MIC SA FET Y AND LICENSING BOARD 0:
4 . .. .
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. -a l Ia the Matter ~of: )
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DUKE POWER . COM PANY, et a l ,) Docket N os .- 50-413 9
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50-414 (Catawba Nuclear S ta tion. ) ,
Unite 1 and- 2) ,, -
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JU LY 7, 1983 3:24 P.M.
D E P O SITIO N OF:
WILLIA M H. BRADLEY
['ld 0310240059 830810 PDR FOIA Evelyn Berger Associates AHLERS83-434 PDR STENOTYPE REPORTING SERVICE
......___[' I I.![ 2.*.T .... .....
2 ROBERT G UI L D, ESQ.
C olumbi a, S. C.
3 C ouns el on Behalf of Inte rveno r, P alm e t t o 4 A lli a n c e C or po ra tion 5 RONALD L. GIBSON, E S O.
Charlotte, N. C.
6 C ouns el on Behalf of A ppli c a nt. Duke Power 7 Company 8
Also M s ent: ,
9 George W. -irier Duke Power Company 10 Roger O u e ll e t t e 11 Duke Power Company 12 Clenn H. 3 ell Duke Powe r Company 13 Michael F. Lowe 14 P alme tto Allia nc e 15 P hil Jos P alme tto Allia nc e 16 Betsy L e vit a s 17 C a r olin a E nvir o n m e n t al S cud y Group 19 20 I N D E X 21 WIT N E S S DIR E C T CROSS 22 W illia m H. 3radley 3 --
23
> 24 25 EVELYN $, SERGER CFFICI AL COURT REPORTER f
U. S. DISTRICT COURT FMAR10TTE N c
2A
=
1 E X H I B I T S 2
NUM BER DESCRIPTION PAGE 3
Bradley Exhibit One Memo to file dated 4 8/5/82 47 5 Bradley Exhibit Two Letter f rom G. E.
Ross to Bradley 6 dated 7/31/81 50 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Evt LYN $. 8(RGER OFFICIAL court REPORTER esa invTr as e
Bradley -
Diroct 3 1 The D e po sitio n of W illia m H. Bradley is 2 taken at the corporate o ffic e s of Duke Power Company, 3 C ha rlott e, North C a r olina, on this the 7th day of 4 July, 1983, in the presence of R obert G uild , Attorne r 5 for the Intervenor; and R o nald L. Gibson, Attorney 6 for the A p pli c an t.
7 A ll f o rmalitie s as to c a p ti on, c e r tific a te 8 and tr an s mi s sion are waived. It is agreed that 9 Lynn B. G illia m . Notary Public in and fo r the State 10 ,2f North C a ro lina, may take said D epo sitio n in machtne 11 shorthand and transcribe the same to t y p ew ritin g.
12 Said D e po sition is taken s ubj e c t alone to 13 te s timony for competency, relevancy and ma t e ri ality; 14 and all obj e ctio n s , save as to the form of qu e s tion s 15 asked, are reserved until the H e a rin g.
l 16 l
17 W I L LI A M H. BRADLEY, 18 having been fi r s t duly sworn to tell the truth at 19 3:24 p.m., was examined and t e s tifie d as f ollo w s :
20 21 DIR E C T E X A MIN ATION 22 13 Y MR. GUILD:
23 O M r. Bradley, state your full name for the 24 Record, please. '
1 1 25 A W illia m H a rold Bradlev.
EVE LYN $, 8[RGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT
.... nevr m e
3 r o dle y - Direct 4 s
1 C And your business address, sir ?
2 A 622 South Church Street; C h a rlot te, No rth 3 C a r olina.
4 O And in what capacity are you e m ploy ed 5 ! with Duke Power?
6 A Staff A s sistant to the Corporate CA 7 M ana g e r.
8 MR. GIBSON: Mr. G uil d , if I might 9 interrupt for a couple procedural matters, 10 I as sume we are proceeding under the 11 same stipulations as the other D e p o s itio n s ,
12 Being present at this Deposition for 13 Duke Power are Mr. George Grier and Mr.
14 Glenn Bell; and the same folks as were 15 present in the e a rlie r D e po sition s are her s 16 for P alm e tto A llia n c e .
17 E a rli e r last week we produced docu-18 ments that we identified as the f ollow up 19 or f ollo w through do cument s r ela tin g to 20 the t e c h ni c a l concerns.
21 MR. GUILD: R elatin g to carrying 22 through the technical r e c o m m e nd a tion s.
23 MR. GIBSON: Mr. B r adle y has brought 24 with him two additional documents; one of 25 which became final on June 30, 1983; and EVELYN $. BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT (MAR (QTT(, N C.
1 1
Bradloy - Direct 5 1 the other became final on July 1, 1983.
2 They should be included within that 3 group of docume nt s. I am going to make 4 available to you a copy of both, and I ex-5 pect you will want to ask Mr. Bradley some 6 que s tions about the broader documents and 7 how these individual documents fit in, so 8 I wo n' t attempt to explain the m, but they 9 are associated with a,yihon Thru of h T a s k 10 Force report, which was made available to 11 you e a rlie r this morning.
12 13 BY MR. GUILD:
14 O Mr. B r a dl e y, if you would, sir, for the 15 Record would you id e n tif y the do cu me nt s that Counsel 16 has just made a v aila bl e to me?
17 A These are documents which we have lo c ally 18 identified as s pe cific r e c o m m e nda ti o n s Nu mbe r % P 12 19 and W I19.
20 0 A ll right, sir; let me tu rn to those a 21 little bit later. Mr. B r adley, my na me is Robert 22 Culld: I am C ouns el for Palmetto Allia n c e, and as you 23 may know, we are Intervenors in the o p e r a tin g 24 licensing proc ee ding for the Catawba Station; and I 25 trust that you are aware that we have raised ques tio as EVE LYN $ @fRGER OFFICIAL COURT REPORTER U. 5. DISTRICT COURT ruaarnTTr u r
B r a dloy - Direct 6 1 concerning the adequacy of C u a li t y Assurance and 2 C on s t ru ction at the f a c ilit y.
3 Are you aware of that?
4 A Yes.
5 O I want to show you a document that quo te s 6 the text of what has been referred to as Contention 7 Six.
8 That is a co nt a n tion that describes the 9 concerns that Palmetto has related concerning Quality 10 Assurance at the plant.
11 T hi s is the c o m p an y 's fi r s t Response to 12 a series of qu e s tion s, Int e r r o gat orie s by Palmetto 13 A lli a n c e .
14 On Page Three at the bottom is a quota-15 tion of the text and it goes over to Page Six 16 (indicating).
17 W ould you take a few moments and read 18 that, sir, to your self ? Were you aware of the t e rm s l
l 19 of that co ntentio n bef o re now?
l 20 Have you seen t h at bef ore ?
21 A Not s p e cific ally, no.
22 O I want to ask you some que s tio ns , Mr.
23 Sradley that are in the nature of an ef f o rt to gather 24 e vid e n c e on that issue to use in the o o e r atin g l
l 25 lic e n s in g proceeding.
EVELYN $. 6ERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT FM art 0TTE. N C.
, B ra dloy - Direct 7 1 If I ask a qu e s tio n th at is not clear or I 2 am using a term that you don't f ollow or I am not 3 being clear in the f o r m a tio n of a que s tion, please 4 stop me and ask me to clarify.
5 Your D e po sitio n is b ein g transcribed, and 6 if you don't ask me for cla rifi c a tio n, I will lo o k at 7 the an swe r and presume your answer is re s pondin g 8
to the que s tion the way it was asked.
9 T ell me, sir, if you w ould, the po sitio n s 10 you have held with Duke Power. T ell me when you 11 came with the company and what you went through, 12 the po si tio n s you have held.
13 A I came with th e company in November, '72, 14 with the C on s t ru c tio n De pa rtment. I don't know the 15 exact title that I was hired in at.
16 O Vihat was your area of work?
17 A CA. I was later promoted to Construction 1
18 to a M a na ge r, later to CA M ana ge r, Audit and T rain -
19 later, ing, i 20 When did you get Q Let me slow you down.
21 the p romo tion to GA M ana g er in Con s t ruc tion ?
22 A A bout February, '74.
93
~
QA M anag e r, A u di t C A nd the next position, 24 and--
25 A A nd T r ainin 2.
EVELYN $. BERGE2 0FFICIAL COURT REPORTER U. S. DISTRICT COURT runninTvr u r
B radloy - Dirset 3 1 0 % hen was that ?
2 A May 1st, '74, CA Manager, Engineering 3 F e rvic e s .
4 Q The date?
5 A I don't re membe r.
6 C A pp r oxim a tely, what year?
7 A '76. Later I went to CA Manager, A d mini -
8 s tr ative S er vic e s , February 1st, 1981.
9 O A nd to your present po sitio n ?
10 A A bout February 8, 1982; and that is approx i-11 mate. I don't remember the exact date.
12 O And to whom do you report now?
13 A M r. George G rie r.
14 O Did you e s s entially come on your current 15 p o s itio n when M r. Crier became Corporate CA Man-16 ager?
17 A T ha t's correct.
18 O Okay, what are your d u tie s in your p re s e nt 19 p o s iti o n , Mr. Br adle y ?
20 A I have v a rio u s dutic a. My major duty is, 21 I am f a cilitato r for the Ouality Ci r c l e s Pr o g r a m . I 22 was also the coordinator for the Beiding In s pec to r 23 Task Force r e c o m m e nd a tion s , and I have served on a 24 number of other Task Forces.
25 O Wha t other Task Forces have you served on?
EVELYN $. BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT P 9TTF P
B r a dlay - Direct 9 1 A Cherokee, Cost Reduction T a s '< Force, and 2 1 am C h ai esn a n of the Nonconformance E v alu a tio n 3 T ea m.
4 Q You are now?
5 A Yes.
6 Q A nd tell mu about that last p o s itio n. M h a.t 7 is the Nonconformance E va lu atio n Team?
8 A It is a team of independent engineers and 9 individuals who review each C a ta wb a NC1 f or clarity 10 and c om ple t e n e s s, 11 Q And how long has the Nonconfo ance 12 E valu a tio n Team been in existence?
13 A A pp ro xi ma te ly ten months.
14 C W ho else serves on that team with you, 15 M r. B radley ?
16 A Don M a r k e 11.
17 Q How about t ellin g me who Mr. M a r k e11 18 is, what he does?
19 A He is the Senior QA S p e ciali s t in the 20 Q u a lit y Assurance D e pa r tm e nt.
21 O A ll right.
22 A Mr. Jim Crenshaw, De sign E n gin e e rin g.
23 O A ll right.
24 A Roger Bha ta na ge r.
25 O S p ell that.
eve LYN $. BERGER OFFICIAL court REPORTER U. S. DISTRICT COURT "WAB197TT N P
B r a dley - Direct 10 1 A 3-H-A-T-A-N-A-C-E-R.
2 Q And what is M r. Bha ta na ge r's job?
3 A He is Senior E n gin e e r, Civil Division.
4 Q A ll right.
5 A Mr. Michael Couch, M e c h anic al E ngine e r a t 6 M c G ui r e Nuclear S ta tio n; his exact title, I don't 7 know.
8 O All righ t; is that it, and yours elf ?
9 A No, I have one more, Steve VanM als s en, 10 C on s t ru c ti on Department.
11 Q A ll right, Mr. Bradley, have you had 12 r e s po n sibilit y for eithe r inve stig atin g or r e vi e win g 13 or providing for c o r r e c tive action for concerns raise d 14 by Welding Inspectors at Catawba Nuclear S ta tion ?
15 A I don't understand that que s tio n.
16 O A ll ri ght, sir; have you been responsible 17 in any way for reviewing concerns expressed in late 18 19 81, or early 1982, by various % elding Inspectors a:
19 C a tawba ?
20 A No.
21 Q Have you been r es pon sible for the imple-22 m e n ta tion of the r ec o mmenda tio n s of the Task Force 23 that reviewed those concerns?
24 A Yes.
j 25 Q I want you to describe for me what your EvELYN $. BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE, m. C-
B ra dloy - Direct 11 1 r e s p o n s il:ili t y has been.
2 A My re s pon sibility was to, once the Task 3 Force had issued its recommendations, was to assur e 4 th at individuaia were assigned to take a c tion on thos o 5 r e c o m m e nd a tio n s , take action on those recommendations 6 recorded on appropriate forms; that it was recorded 7 on appropriate forms, that it was properly signed 8 and that it was r e vi e w e d by the a p p r o p ria te depart-9 ment vice president and my s u p e r vi s o r.
10 Q M r. G rier ?
11 A Yes.
12 Q A ll right, sir; did you formulate or par-13 ticipate in the f o r mula tion of the manner in whic h 14 the r e co m me nda tio n s were implem e nt ed ?
15 A A g ain, please--
16 Q Okay, I am t r yi n g to und er s tand beyond 17 assigning the work and seeing that the work was do n e ,
18 did you pa rticipat e in pe rf o r ming the work, you r s elf, 19 th e implementation ?
20 A No.
21 Q And who then was responsible for the 22 substantive work in implementation of the Task Force 23 recommendations. Mr. B r a dley ?
24 A V a riou s and nume rou s individuals.
25 Q The individuals to who m you assigned the EVELYN S. BERGER OFFICI A:. COURT REPORTER U. S. DISTRICT COURT CH A%QTIt. N C.
Brodloy - Direct 12 1 ta sks ?
2 A Let me clarify, I did not as sign the tasks; 3 I assured th at individuals were assigned othe r com-4 petent parts, such as the appropriate division ma na ge 5 m en t.
6 Q Who was ultimately responsible for assign-7 ing the tasks of imple me nt ation ?
8 A A gain, va rio u s individuals f r om each 9 de p a r tm e n t.
10 Q A ll r i g h t ,- let's say--do they f oll ow in each 11 department eff ected by r e c o mm e n da tio n s , was th er e a 12 person responsible for assigning the implementation 13 task?
14 A y..,
15 Q L e t 's say in the Quality Assurance D e p a r t ..
16 m e n t, who would have been responsible?
17 A At least two individuals, Mr. Henry and 18 hi r . D a vis on.
19 Q They were r es ponsible for the task of 20 g nplementation ?
21 A They were responsible for assigning 22 individuals to take action on the recommendations.
23 O W ould they have been responsible for 24 reviewing the a c tio n s that were taken to implement 25 th e re commendations ?
EVELYN S. BERGER OFFICIAL COURT REPORTER Pa$A nTTE N r
D r n dlo y - Diroct 13 1
1 A In a sense, but they would not have 2 nec e s sa rily sign ed the do cumen ts .
3 Q A ll right. I don't mean this to be 4 nec e s s a rily re pr e s en tative, but the last document 5 that you gave me just in terms, is this a procedure 6 that required im pl e m e n ta ti o n work by persons in 7 Q u a li t y Assurance?
8 A y o, 9 Q So what department was responsible for 10 that?
11 A C on s t ruc ti on.
12 g It is w p 12 7 13 A Yes, sir.
14 Q A ll right now, using that as just an e x a m p l e, 15 who would have been r e s pon sible for as signin g tasks?
16 Is that indicated on the document ?
17 A T hi s pa r ticula r individual was the 18 individual in the C on s t ru c tion D e pa r tm e nt w ho assigned 19 the ta s k.
20 % ho was that?
Q 21 A Mr. Ray H o lli n s in this pa rticula r one.
22 He is also the a c tio n party.
23 Q V'he re is it indicated, lik e it says at the 24 top it was assigned to, and he is the one doing the 25 task.
EVE LYN $. BERGER OFFICIAL COURT REPORTER e a nsir u r
Brodloy - Diroct 14 1 Where is it in di c a te d he was the one 2 responsible for as signing the task?
3 A He signed it here (indicating).
4 Q He signed under where it says, " A c tion 5 c o m ple t e d , " at the bottom of the form?
6 A T h at 's correct.
7 O W ho is Mr. Hollins ?
8 A I' m no t sure of his exact title; he is 9 Manager, Con s truc tion S e r vic e s .
10 Q What is the general s u bj e c t of this s pe cifi:
11 r e c om mendatio n here (indic atin g) ?
12 A The general subject is a r ecommenda tion 13 regarding--
14 MR. GIBSON: I will make a copy 15 a vaila bl e to him.
l 16 MR. GUILD: Okay.
17 18 BY MR. GUILD:
l 19 O Down at the bottom of the form as you see.
20 Mr. Hollins signed the " A c tion com ple t ed. " Whose 21 signature appears next to it?
22 A That is Mr. R. L. Dick, Vic e P r e sid ent 23 of C o n s t ru c tio n.
24 Would he be the a pp ro priat e department Q
25 vice president to r e view the im ple m e nta tion ?
EVE LYN S. BERGER OFFICIAL COURT REPORTER U. S. DISTRICT court F want flTTF 1 C.
r- -
Brodicy - Diroct 15 1 A Yes.
2 O A nd then how about the signature that 3 appears sort of dia g o n ally on the face of the fi r s t 4 page?
5 A That is the signature of my supervisor, 6 M r. George G rie r.
7 O So Mr. Grier, after the department vice 8 president Mr. G ri e r r e view e d it?
9 A Yes.
10 Q Is that t y pic al of the process for each 11 of the s pe cific r ec ommendation s ?
12 A yes, 13 Q I want to di r e c t your attention to R evision 14 Three to the Task Force report.
15 hi R . G UILD : Do you v? a n t to get a 16 copy of that?
17 MR. GIBSON: Why don't you go a h e a :1.
18 He cannot put his hands on it.
19 MR. GUILD: Okay.
20 21 3Y MR. GUILD:
22 O I ask you to identify some related 23 correspondence attached to it. It also came f rom 24 your Counsel, Mr. Bradley.
25 A re you f amiliar with the R e vision Three EVE LYN $. SERGER OFFICIAL COURT REPORTER U. S. DISTRtCT COURT
W3RIOTTF N P
B r adley - Direct 16 __
I and the related correspondence that I'm s ho win g you 2 (indic ating) ?
3 A Yes.
4 Q Tell me just g en e r ally why was R e vi s io n 5 Three necessary?
6 A R evi s ion Three was th e r e s ult of a review 7 of R e vi s io n Two and V olum e Two, which had been 8 shown to contain errors.
9 Q W ell why don't you just lead me through 10 th e fi r s t process, fir s t the initial report was issued 11 in V olu m e O ne and Two?
12 A Yes.
13 Q -W h a t ne ce s sitated the fir s t revision of 14 th e T ask Forc e ? What produced the fi r s t r evis ion ?
15 A As I r e c all, it was a r e sult of the Task 16 Force m e mb e r s c o m muni c a tin g their fin di n g s back to 17 the concerned in spectors.
18 Q So it r e fle c t e d the feedback to the 19 in spec to rs ?
20 A yes, 21 Q How about R e vi s io n Two?
22 A I don't r e c a ll.
23 O W hy don't you take a look? I think the r e 24 is probably a cover sheet that at least lists the 25 revisions. That will refresh your r e c oll e c tio n.
EVELYN $. BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE. N. C.
Srndley - Direct 17 1 Did that h elp ?
2 A Yes, I was in error. REV One was as it 3 states here, e di to rial changes in the text.
4 Q Were any of those s ub s t a n tiv e; do you know ?
5 A Not that I r e c all.
6 Q A nd R evision Two?
7 A As I stated e a rli e r, the re sult of inspector 8 feedback.
9 Q How about were th er e s u b s tantive changes 10 there?
11 A I don't r ec all any substancy changes.
12 O Okay, and the third r e vi sion in the revisicin 13 we are asking you about?
14 A Y e s.
15 Q T ell me how you or whoever id e n tifie d the 16 errors and the nature of the errors in R evision Two.-
17 A We wanted to assure that each concern wao 18 s pe cific ally addressed, and that the a c tio n on the 19 recommendation was documented all on one piece of 20 paper to a c c o m pli s h that task, which I did.
21 Q I notic e d on e which I will term t ra ns c riptio n 22 error. T ell me w ha t you mean by t r an s c ri ption errer?
23 A A f ailur e to carry th e inf o r matio n from 24 V olum e Two over to the Volume One report.
25 O V olum e Two was the do c u m en ta tio n of the EVELYN $. BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT
' rHastnTTF N I
1 B ra dloy - Diroct 18 1 o rigin al text?
2 'A Along with the t e c hnic al recommendations.
3 along with the r e c om m en da tio n s .
4 O A ll right, and V olu m e One were the--
5 A In order to a c c o m pli s h the task which I 6 have just outlined to you, I no tic e d one t ra n s c rip tio n 7 error.
8 I brought this to the attention of the Chair-9 man of the Task Force. He r e c a ll e d the Task Force 10 and found additional errors; and sub s equently iss u e d 11 REV 3.
12 Q Okay now, the one page summary of the 13 a c tio n s taken, can you direct my a ttention to that 14 page?
15 Is that a page?
I 16 A O h, a revision page.
17 C No, the page that r e fl e c t e d the summary 18 a c tio n s taken.
19 A I don't unde r s tan d your que s tio n, Mr. G uil d.
20 Q I thought I unde r s tood you to s ay that you 21 were at tem p tin g to put on a piec e of paper the t r ac ki n g 22 the concerns and s p e cific a c tio n s taken.
23 Is th at pie c e of paper a part of the Task 24 Force report?
25 A No.
EVELYN $. BERGER OFFICIAL court REPORTER U. S. OlsTRICT COURT CHARLOTig, a c-
Bradloy - Diroct 19 1 Q % hat is that piece of paper?
2 A I believe you have it, M r. G uild. V bat I 3 r e c all is--
4 Q Can you help me identify it a little better ?
5 A It has a cover sheet on it that says either 6 Task Force R e c o mme nd ations , P o te n ti al Inadequacies 7 or P r oc edu r al Violations.
8 Q M r. Bradley, I think we have just about 9 everything that came to us last week from you.
10 A Here is the programmatic recommendation; 11 it is typical of what I was talking about.
12 O Now you gave me a stack of pape r here 13 (indic atin g) . These are one page for each s p e cific 14 r e c om m e nd a tio n ?
15 A (T h e Witne s s nodded his head affirm atively, )
16 QF F rom the Task Force; is that right ?
17 MR. GI BS O N: D o n't nod, h! r . t3 r a d l e y .
18 THE % IT NE S S: I believe that is the 19 way I f o rmulated it, yes.
l 20 l
21 SY MR. G UIL D :
l 1
22 Q A nd it says, "F ro gr amma tic R e c o m me nd a ti 2 ns.
23 A re all re co mme nd atio ns p r o g r am matic r e co mme nd ations ?
24 A No, there are s p ecific r e c o mm enda tio n s, 25 goo, EVELYN $. GERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT RHARL@TT(n N. C.
D rndley - Diroct 20 1 Q A re there pages for the s p e c i fic recommen -
2 da tion s in here?
3 A No.
4 Q Is there such a document for a s p e cific 5 r e c om m enda tio n ?
6 A Yes, I don't see it here.
7 ( % her eupon, the Witne s s a nd his 8 Counsel conferred off the R ec ord. )
9 10 3Y MR. G UILD:
11 C Are they c o n s ultin g on this que s tion here, 12 M r. B r adley ?
13 A (Mr. Bradley demonstrated he did not know.)
14 MR. GIGSON: hi r . Guild, the docu-15 ment that Mr. Sradley just referred to is 16 a m a t rix pr e p ar ed in anticipation of liti-17 g a ti on in the p r o c e e din g.
18 It is not a sub s ta ntive document that 19 discusses or deals with the concerns, but 20 is a document requested in p r e p a r a tio n for 21 liti g a tio n.
22 We take the p o sition because that l
23 docum en t can be prepared by the expenditu re 24 of tin e and money based on the documents l
l 25 m ad e available to you, we will not make Evrtv1 S. Benata l omCtAL Count acronTen U. S. Disf aiCT Count f M&ELOTTE. N. C.
l l
21 1 i
. I 1 that available to you in the course of these 2 proceedings.
3 I understand you will probably request 4 it, and we will c o ns ide r it at a later time; 5 but that is a document that we will not 6 make available as a pa rt of Discovery 7 because it was pr e pared in anticipation of 8 li ti g a ti o n.
9 MR. GUILD: Why am I holdin g such 10 a document in my hands then ?
11 MR. GI3 SON: Because there is 12 another one prepared in anticipation of 13 li ti g a ti o n because of the Lawyer's involve-14 m e nt.
15 It does not cover the documents that 16 you have in your hand. There are two 17 separate do cum e n ts.
l 18 h1 R . GUILD: You got me, Mr. Gibson.
19 I have a document gi v en t o me, I don't know l
20 where it came f rom except it was handed l
l 21 to me and represented to come f rom Mr.
22 B r a dley 's file s di s c o v e r e d the Saturday
- 3 before the D e po sition commenced.
24 I have a document stated to be the 25 matrix he was preparing, h4 y qu e s tio n to Ev E LYN $,8ERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE, N. C.
22 B radloy - Direct 1 him is where are the s p e cific recommenda-2 tions; and you are t ellin g me you are 3 objecting to p ro ducin g it.
4 MR. GIBSON: You are d e s c ribin g a 5 document, I am not talking about a mat rix 6 dealin g with s p e cific concerns was pre-7 pared in anticipation of li t i g a tio n .
8 We b e lie v e that is a p r i vil e g e d item 9 and it can be prepared by the Intervenors 10 by expending the same time, money and 11 resources that A pplic ant s have expended.
12 I think you will agree that there is 13 a provision in the R ule s of P ra c tic e that 14 makes such a document not available absent 15 some special showing of good cause or 16 special need on your part.
17 MR. G UI LD : I hear you, I am still 18 c o nfu s ed.
19 20 BY MR. G UILD :
21 Q % hat is this document you have given me, 22 Bradley; what is this (indic ating) 7 M r.
23 A T hi s is a li s tin g of the ac tio n taken on the 24 W el din g Task Force p r o g ra mm a tic r e c o mm en dati on s .
95
~
O Is there a lis tin g of the a c tio n taken of EVE LYN $. BERGER OFFl0IAL COURT REPORTER U. S. OiSTRICT COURT CMmLfWi?ft. (n. e-
3radicy - Dir ec t 23 1 s p e cific rec omm enda tions ?
2 A Yes.
3 Q W he re is that?
4 MR. GIBSON: I instruct him no t to 5 answer. That is not included in what is 6 b ein g made available.
7 Absent a R ulin g by the Board, it will 8
not be made available.
9 Q Did you prepare such a document, Mr.
10 B r a dl ey ?
11 3 y,,,
12 Is that in the same form as the document C
13 that relates th e p r o g r a m m a ti c concerns?
14 A B a s ic ally.
15 Why did you prepare the document that you Q
16 have just handed me that relates to the p ro g ra mmatic 17 cone,,,,7 18 A To make sure we covered them a ll .
19 C W hy did you prepare the documencs related 20 to s p e cific concerns?
21 hi R . GIBSON: I am ins tructing him 22 not to answer that.
23 24 BY MR. GUILD:
O nid vnn n anave th e d o cum e nt s recarding EV'E LY N $. BERGER CHICIAL COURT REPORTER U. S. DISTRICT COURT ruantnTTI N P _ _ _ . _ _ _ _ _ _ _
B ra dlo y - Diroct 24 1 the s p e cific concerns to make sure that you covered 2 them all?
3 MR. GIBSON: I am in s t ruc tin g him 4 not to answer that qu e s tio n. Mr. Guild.
5 We have until five o' clock.
6 I will not let him discuss that in 7 other d e t ail. If you want to pursue other 8 areas before quitting time, I suggest you 9 proceed. .
10 He will not be allowed to discuss 11 s pe cific concerns of that document.
12 MR. GUILD: I think your po sitio n is 13 crazy, Mr. Gibson. I would ask that he 14 answer the qu e s tio n.
15 MR. GIBSON: And I' m in s t ru c tin g hi-n 16 not to. What you think of my po sitio n is 17 incon s equential.
18 19 SY MR. G UILD :
20 Q How did you discover this t r an s c riptio n 21 error, Mr. Bradle)
- 22 A In preparation of the reports.
23 O Of what ?
24 A Of the p ro g r a mm a tic recommendations.
25 Q So you dis cove red th e t r a n s c rip tio n error EVELYN S. BERcER OFFICIAL COURT REPORTER U. S. DISTRICT COURT (2HARLOTTEn N. C.
B radloy . Diroct 25 1 in preparing the documents that Counsel has reference 2 to ?
3 A Yes.
4 Q And that produced REV 3 of the Task Force 5 report?
6 A T h at 's correct.
7 MR. GUILD: A nd you are not going 8 to produce that do cument ? .
9 MR. GIBSON: I have stated our 10 p o s itio n and r e a s o nin g fo r not p r e s en tin g 11 that d o c u m e n t. M r. Guil d.
12 13 BY MR. GUILD:
14 O Did you find only one t r an s c rip tion error,
, 15 M r. B radley ?
16 A I only found one.
l 17 Q What did you do when you f ou nd that one?
18 A Id e n tifi e d it to the Task Force C hair ma n.
19 Q Did you complete the r evie w of the other 20 s pe cific concerns?
l 21 A Yes.
22 O In the process of doing that, did you 23 identify other tr an s c ription errors?
24 A No.
25 O There were no o ther s ?
EvtLYN $. BERGER O*FICIAL COURT REPORTER U. S. DISTRICT COURT CH A RLOf i t, N. C.
B ra dloy - Diroct 26 1 A I don't know.
2 O You didn't find any others?
3 A No.
4 Q But the Task Force members did ?
5 A Yes.
6 Q How did they find othe rs ?
7 A I don't know.
8 Q H ave you r e vi e w e d their work?
9 A No.
10 Q A re you not f a mili a r with R e vision Three?
11 A Yes.
12 Q Does R e vi sio n Three respond to the other 13 transcription errors?
14 A I would as sume so; yes.
15 Q Does it id en tif y the other t r a n s c ription 16 orrors?
17 A Yes.
I l
18 Q Can you tell me where those errors 19 occurred?
l j 20 A I can show; they are clearly o u tlin e d in 21 the text.
22 Q Does it explain how tho s e t r a n s c rip tio n 23 errors, the other ones, were i de ntifie d ?
24 A I don't understand your qu e s tion.
25 Q I want to understand how they found the EVELYN $. OfRGER OFFICIAL COURT REPORTER U. S. DISTRICT court fdH ADBS;TT(7. N. C.
B ra dle y - Direct 27 1 other transcription errors.
2 A I surely don't know; I wo ul d as sume by a 3 one by one c o mp a ri s on check.
4 Q The same kind of check that you were doin g?
5 A I would think more details.
6 Q Who did that check; do you know?
7 A M r. Parks could be.
8 Q Now what was the t r an s c rip tion . error.that 9 you dis c ove re d, M r. B r a dley ?
10 A They had f aile d, they, the Task Force, 11 had f ail ed to record in V o lu m e One or the s p e cifi c 12 r e c o mm en da tio n s of Volume Two.
13 Q What recommendation was that ?
14 A I would have to refresh my me mo r y; I think 15 it was concerning the R S 4.
16 Q If you are not certain about that, why don' t 17 you just take a look.
l 18 MR. GUILD: C ouns el, do you have l
19 another copy of REV 3?
l 20 MR. GIBSON: No, we don't.
21 THE W IT N E S S : It was related in 22 special concern R 5 4, 23 24 3Y MR. GUILD:
25 O A ll right. sir; what was that concera?
EvtLYN S. BERotR OFFICIAL COURT REPORTER U. S. DISTRICT COURT
@H ARiL@TTfL N. C.
B rndt ry - Direct 28 1 A It had to do with weld weave width.
2 Q Was that the same subject as the W P 12 tha t 3 you just p r o vid e d me?
4 A Yes.
5 Q And had the Task Force ne glec te d to pro-6 vide for c o r r e c tiv e a c tio n for that s p e cific concern?
7 A No, they had made a r e c o mm en d a ti on. Mr.
8 Guild; but it was contained in V o lu m e Two, not in 9 V olum e One.
10 Q Had the r e c o m m'e n d a ti o n been f ollowe d ?
11 A Not at that ti m e , it was in error. No.
12 O The recommendation was lost?
13 A I wouldn't put it that way.
14 O A ll right, it was overlooked?
15 A yes, 16 Q Is that consistent with other tr an s c riptio n 17 errors that were also s p ecific recommendations, that 18 were overlooked because of the t ran s c ription problem s ?
19 A There were two a d di tio n a l recommendations 20 that were overlooked.
21 Q Okay, they were which ?
22 A R34.
23 Q Wha t was that?
24 MR. GIBSON: I think a copy of some 25 p o r tio n s of REV 3 are already in documents EVE LYN S. BtRatR OFFICIAL court REPORTER U. S. DISTRICT COURT CWLOM, n R
4 B ra dioy - Direct 29 1 Produced, so it might be when you refer 2 to a s p e cific ite m, Mr. Bradley, both of 3 you will have a copy since we are unable 4 to find our other copy.
5 THE WITNESS: R34 refers to W eldin g 6 In s p ec to r, WI19, which you have.
7 Q W ha t is that; id en tif y that concern, please ,
8 A The concern was, as I unde r s tand i t, that 9 the field had made a judgment or e n gin e e rin g decision 10 that should have been made by our E n gin e e rin g Depart-11 ment.
12 Q A ll right, and there was an additional 13 recommendation that was overlooked?
14 A Yes.
15 Q What was that?
16 A D 8.
17 Q What did that relate to?
18 A That a p pa rently d e alt, I don't have the 19 exact concern except in V olu me Two. A p pa r e n tly it 20 had to do with the s t e n cilin g of the w eld e r 's identifi-21 c ation a dj ac en t to a weldment.
22 Q And what re co mm endation numb e r was that; 23 do you know, the a c tio n of the Task Force?
24 A Although they had detected a t r an s c riptio n 25 error, was to take no fu rthe r ac tio n so there was EVE LYN S. BERotR OFFICIAL COURT REPORTER U. S. OlsTRf CT COURT CHOEwrMn7f7, rn. (e.
B ro dioy - Direct 30 1 no fur the r action r e c o mm e nda tion, so to speak.
l 2 Q So the re was no re commendation numb er ?
3 A No.
4 O A nd that lack of further action s ho uld have 5 been noted in the t r an s c ripti on and was not; is that 6 right?
7 A Yes.
8 Q Those are the only three recommendations 9 th a t were o ve rlo oke d ?
10 A Yes.
11 Q The other errors were of what character 4 12 sir; what sort ?
13 A I would classify them as num e ric al in 14 nature, and in truth, t r a n s c rip tion errors, typo-15 graphical errors.
16 O Not substantive errors?
17 A No, sir.
18 MR. GUILD: Counsel, where did this 19 come f rom; out of this file ?
20 MR. GIBSON: T h at 's right.
21 22 BY MR. GUILD:
23 O Now are you aware of the in volve ment of 24 the Nuclear R e gulato ry C ommis sion r evie win g the 25 work of the W eldin g Task I' o r c e , M r. B r a dl e y ?
EVELYN S. BcRotR OFFtCIAL COURT RCPORTER U. S. DISTRICT COURT C~YDLOWW1, H. Cd.
B r adley - Diroct 31 1 A B a s ic ally.
2 Q How did you become aware of their involve-3 ment ?
4 A I made every attempt to keep the NRC 5 R e s id ent Inspector informed of my ac tivitie s as it 6 related to action on the recommendations.
7 A nd he, the R e sid ent Inspector, reviewed 8 my file s .
9 Q A ll right, sir; did you correspond with Mr.
10 VanDoorn? This is Mr. VanDoorn you have reference 11 to ?
12 A Yes.
13 Q Did you correspond with him ?
14 A I provided him with various copies of the 15 Task Force report s.
16 Q Did you w ri t e hi m memos, letters ?
17 A I don't r e c all, I p robably did.
l 18 Q Have you made those available ?
19 A I made my file a v aila ble .
20 Q You don't r e m e mb e r wh ethe r there are any 21 memos or letters to M r. VanDoo rn ?
l 22 A I don't.
l 23 Q A nd did you meet with Mr. VanDoorn?
l 24 A y.,
25 Q C an you r ec all whe n ?
! EVE LYN $ BERGER I 0FFICIAL COURT REPORTER
! U. S. DISTRICT COURT CWOtDin7R, N. @.
B radley - Direct 32 1
1 1 A N o.
2 Q More than one occasion?
3 A Y es.
4 Q Let me show you a document (in dic a tin g) .
5 Can you identify that, Mr. B radley ?
6 A Yes.
7 Q W ha t is that, sir?
8 A It is a memo to file d o c um en tin g a visit 9 by Mr. VanDoorn to my of fic e.
10 Q When did that meeting occur ?
11 A A ugus t 5, 1982.
12 Q Take a look at that and refresh your 13 r e c oll e c ti o n and describe that meeting for me, sir.
14 A Mr. VanDoorn, the purpose of his visit waa 15 to look through my file because I explained my filing 16 s ys tem.
l 17 Q Had you met with him before on this subj e ct 18 before that tim e ?
19 A Not s pe cific ally.
20 Q I don't under s tand what you mean.
21 A I met M r. V anDo orn many tim e s .
l 22 Q I understand, but on this subject?
23 A The subject was to look at my file s. We 24 had not been on th e subj e c t.-to look at my fil e s .
25 Q How about the im ple me n t a tio n of the Task l EVELYN $. BERGER l OFFICIAL COURT REPORTER l u. s. District court
@H ARftRTTE, N. C.
Bradioy - Direct 33 1
Force r ec ommenda tions ?
2 A O h, yes.
3 Q You m et before that ?
4 A Oh, yes.
5 Q When did you me et befor e?
6 A I can't recall.
7 O More than once?
8 A Yes.
9 O -
When would the next meeting have been with 10 M r. VanDoorn?
11 A Prior to A u gu s t 5, 1982.
12 Q When did you fi r s t have re s p on sibility for 13 implementation ?
14 A I do n' t r e call exac tly when.
15 Q Take a look at your file s and see if you 16 can refresh your r e c olle cti o n, Mr. Bradley. How abopt 17 s om e corr e s pond ence, would that help you?
I 18 A It might, here is the correspondence file.
19 A ll I can glean from this, M r. Guild, is prior to i
20 A pril 22nd, 1982.
21 Q All right, sir; Mr. Bradley, did you par-22 ti ci pa t e in a May 25--let me, I'm not c e rtain of the 23 date--did you participate in a me etin g in Atlanta with 24 the NRC r e g a r di n g the Catawba W eldin g Task Force 25 report?
EVE LYN S. BERGER OFFICIAL COUPT REPORTER
- u. S. DISTRICT COURT CH ARLOTTE. N. C.
3 r a dl e y - ns.,-> 24 s
1 A No.
2 Q Were you aware of that me etin g ?
3 A Yes.
4 Q Did you take on this task af ter that 5 mee ting ?
6 A No, that would have been prior to th at 7 m ee tin g .
8 Q Did you meet with M r. VanDoorn on the 9 subject of the Task Force r e c o mm e nd a tion -i mple m e n-10 ta ti on p rio r to that m eeting ?
11 A No.'
12 Q Now the Augus t 5 memo to file r e fle c t s 13 th a t Mr. VanDoorn informed you he was beginning hia 14 r eview of th e Task Force report; is that right?
15 A The que s tion again; what was the que s tion ?
16 Q M r. VanDoorn info r m e d you at that time 17 that he was b e ginnin g his review of the Task Force 18 report; isn't that correct?
19 A T ha t's correct.
20 Q And you described to him your fili n g 21 s ys te m ?
22 3 7,,,
23 T ell me what you had described to him.
Q 24 N. r . G uil d, 3 ,Vell, b a s i c a ll y I showed him, 25 )how to use my file s . which were set un very s imil a r EVELYN $. BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE, N. C.
B ra dloy - Diroct 35 1 to these; and I showed him Quality Assurance pro-2 cedure references and it was his task to dig them ou t.
3 Q And the file s were the file s that are in 4 front of you now that were made available ?
5 A Yes.
6 Q And was that all of the fil e s that were made 7 a v a il a bl e to M r. VanDoorn by you?
8 A My e n ti r e file was available implementing 9 correspondence, everything I did.
10 O Was there anything other than what is in 11 front of us here?
12 A No.
13 O How about V olum e One an d Two of the Tasi 14 Force report?
15 A I made those available on several occasions.
16 Q On this occa sion ?
17 A He borrowed my copy of V olume One and 18 T wo .
19 O It say s he looked through--
20 A Yes, he borrowed my c o pi e s of One and Two 21 for his review at C a tawb a. Yes, he did.
22 O On this occasion of August 5, VanDoorn 23 s pent some ti m e scanning V olu me s One and Two of 24 the Task Force report. He did that in your presence?
25 A Yes.
EVELYN S. BERGER OFFICis L COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE. N. C.
B r ndley . Dir ec t 36 1 Q Did you understand at th at time that he had 2 r e vie w e d those volume s before that date ?
3 A No.
4 Q Do you know whe the r or n ot or did you 5 und e r s tand whe th er or not Mr. VanDoorn had available 6 to him the handwritten concerns of the Vi e l d i n g 7 Inspectors prior to that date?
8 A No, I would have no knowledge of wh at he 9 did.
10 Q Did he relate to you what he had r e vi e w e d i 11 at that point?
l 12 A No.
13 Q Wha t did you unde r s tand Mr. VanDoorn to 14 m e an when, as you not e in your memo to fil e , he 15 explained that he would have to make references to l
16 s ta r ting his review in his we e kly report?
17 A I don't understand your qu e s tio n.
18 Q What does that mean; read that first sente nce 19 there and tell m e what that means ? E x pl ain, please.
20 A R e g ar di n g what he s aid; no more, no less.
l 21 Q Okay, you know no thing more about that?
22 A No.
23 Q He did n ' t s ay anything more than what is 24 recorded in that one sentence on the s u bj ec t ?
25 A Not that I r e c all.
EVELYN $. BERGER OFFICIAL COURT REPORTER U. $. DISTRICT COURT CH ARLOTTE, N. C.
B r a dl e y - Dirnet 37 1 VanDoorn to inform you Q Did you ask Mr.
2 G rie r or anyone else p rio r to filin g that or Mr.
3 report?
4 A A b s olut e'v not.
5 Did he volunteer that inf o rmation ?
Q 6 A No.
7 Q W ha t do you mean, M r . VanDoorn stated 8
he would talk to Mr. Grier prior to filing his r e por t?
O A That is what he said.
10 Ithought he did not say that.
Q 11 A I mi s un de r s too d your qu e s tio n.
12 Q Did he or didn't he say that?
13 A A ppa r ently he did.
14 O Did he or didn 't he?
15 I recorded that in that memo; that mu s t A
16 have been what he said at that ti m e.
17 You are under oath, and I am asking you Q
18 a qu e s tion. The qu e s tio n is to the best of your 19 as you reflect knowledge did Mr. VanDoorn state, 20 in this memo, that he would talk to Mr. G rie r prio r 21 to filin g his re port ?
22 A Yes.
23 Q Did you ask him to m e. k e that co mment ?
24 A No.
25 n. vntunt..vd o that in fo rm a tion ?
EVELYN S. BERGER OFFICIAL COURT REPORTER U. S. Ol57RICT COURT CHA RLOTTE. N. C.
Bradloy - Direct 38 1 A As far as I can r e c all .
2 Q Did he say an .yt hi n g else about the nature 3 of his report?
4 A Not that I r e c all.
5 Q Did he say anything else about his c o m m u ni,-
,I6 cation with Mr. G rie r ?
7 A No, n'o t that I can recall.
8 Q Did he communicate with Mr. G rier ?
9 A I have no knowledge.
10 Q Did he c o m mu nic a t e with you?
11 A On what ?
12 Q A bout filin g his report?
13 '
A No.
14; Q How long had Mr. VanDoorn kept your 15 c opie s of the V olu m e One and Two of the Task Force 16 report?
17 A I do n ' t r e c all.
18 Q A week?
19 A Pos sibly.
20 Q A month ?
21 A Po a sibly.
22 Q Six months ?
23 A No, l
t 24 Q Did you get other c o pi e s of V o lu m e One l 25 and Two to do your work with in the meantim e ?
EVELYN S. BERGER OFFICIAL COURT REPORTER U. 5. DISTRICT COURT CH ARLOTTE, N. C.
3 ro dloy - Diroct 39 1 A Yes.
2 Q Did he return your copies of Volume One 3 and Two?
4 A Yes.
5 Q Still within six months, but you don't 6 remember when?
7 A How long, I d on ' t remember how long.
8 Q "I further committed to supplying him with 9 a copy of the original inspector concerns." What does 10 that mean ?
11 What did you have reference to ?
12 A My files are set up such that there is a 13 file of each individual concern s imila r or identical 14 to what is in Volume Two of the Task Force report.
15 Q Yes, is that what you meant ?
16 A Yes.
17 Q W ell, he read V olume Two in your of fic e.
18 He borrowed your co py of Volume One and Two; and 19 you go on and say, "I fu rthe r committed to supplying 20 him a copy of the original inspector c on ce r n s . "
21 A yes, 22 Q Wha t were you talking about further su p ply .
23 ing him ?
24 A In addition not centained in the whole thick l
25 volu m e of V olume Three, but I had s om e more con-EVELYN $. BERGER OFFICIAL COURT REPORTER U. S. OllTRICT COURT CWLQTW7, C1. fa
Bradloy - Diroet 40 !
)
1 densed versions, if you will, a s m all e r version.
2 O Yes, what were thos e ?
3 A The o rigin al sheets of concerns.
4 Q Were those the original handwritten notes 5 from the ins pe ctor s ?
6 A I had copies of th e m, yes.
7 Q And that is what you are ref er ring to ?
8 A y,,,
9 Q Did you s u p ply them ?
10 A He r e ali z e d he could use Volume Two for 11 the same purpose; and there was no ne c e s city.
12 O Ho never a sked you for the m ?
13 A No.
14 Q Did he ever explain to you why he didn 't 15 need th e m ?
16 A Not that I r e c all.
17 O Did you s u p ply him a clean copy of V olume 18 One?
19 A O h, yes.
0 Q Does that mean one without your no te s ?
A Yes.
22 O A nd did you supply him a copy of the 23 reports and status of the non-technical concerns?
24 A No.
25 O Did he ever ask for it?
EvtLYN $. BERGER OFFICI AL court REPORTER U. S. DISTRICT COURT CH ARLOTTE, N. C.
B r o dloy - Direct 41 1 A No.
2 O Why didn't he ask for them ?
3 A The non-technical concerns?
4 Q yes.
5 A I have nothing to do with non-technical 6 concerns.
7 Q But it says here, sir, that you committed 8 to s u p pl yi n g him a copy of the m; doesn't it?
9 A Excuse me?
10 Q It says in the copy of this memo that you 11 c o m mitt e d to supplying him a copy of the n on-te c hnic al 12 concerns. It does.
13 Did you s up ply a copy ?
14 A No.
15 O He never asked for them ?
16 A That's right.
17 Q Did you have any understanding of why he 18 didn't need them ?
19 A No.
20 Do you have an understanding of whether Q
21 he got them from somebody else?
22 A No.
23 What further c om munic atio n did you have Q
4 VanDoorn af ter this A u gu s t 5 m e e tin g, Mr.
wit h Mr.
25 B r a dley ?
EVELYN S. BERotR I OFFICIAL COURT REPORTER
- u. S. DISTRICT COURT l
CHARLOTTE, N. C.
l
l B r a dley - Dirnet 42 _
1 A I have had many discussions with M r.
2 V anDoorn in the course of vi sitin g C a t awb a. I see 3
him in the halle, I see him in his of fic e.
4 As I have stated e a r li e r, I tried to keep 5
him abreast of my a c tivitie s , how the r e c o mmend a tio n s 6
were progressing in a general sense, and other 7
matters.
8 Q Okay, I' m interested in this matter; and I 9
want you to tell m e what other m e e tin g s you had with 10 M r. VanDoorn on the s ubj e c t of implementation of the 11 W eldin g Task Force.
12 A >1 r . Guild, I do n' t understand your 13 c onno ta tio n of "m e etin g s. " I have contacted Mr.
14 V an Doo rn in his of fic e on num e rou s occasions, but we 15 never had a formal me e tin g as such, such as we are 16 having here now to discuss the W eldin g In sp ecto r 17 Task Force concerns.
18 Q Was this a formal m e e tin g on August 5?
19 A You may c on s t ru e it as that.
20 Q Did he ever c om e talk to you about the 21 imple mentation ?
22 A Not that I r e c all.
23 Q Did you ever go talk to hi m about it ?
24 A Yes.
25
. m_ii -- ___t_ _i _ _ _ _ _ _ _ r _t _ _ t.
.s . . _ , .A3A9
. ~-
b4 "g^g - { g ,gg," "
- u 8 I"'
OFFICIAL COURT REPORTER U. S. DISTRICT COURT C H A R LOTTE. N. C.
F 3rndloy - Direct 43 1 A I said, "Kim, we are g e t tin g along real We have so many lists to do, looking good to 2l good.
3 me; " things of that nature.
4 Q What did Mr. VanDoorn say to you?
5 A P ro bably some s i mil a r remarks, " Good."
6 O Did he ask you to take any further action 7 on any oc ca sion ?
8 A No.
9 Q Did he ask you to provide him any more 10 info rm ation on o c c a s io n ?
11 A W ell, I always s u p plie d him with revisions 12 or a,n y thi n g of that nature that came out to the Task 13 Force r e c omm e n da tio n s .
14 O Okay, you supplied him with the r e vi s io n s ,
15 revisions to one, two and three?
16 A One.
17 Q Did he ever ask you for fu rthe r informa-18 tion ?
19 A No.
20 Q M r. B r a dley, the document s that you pro-21 vided me, which your Counsel provided me e a rlie r 22 today, and those are these with attachments reflect-23 ing s p e cific r e c o mm e n da tio n s ; are those documents 24 c on tained in either V olume One or Two of th e Task 25 Torce report or in the revisions to the Task Force EVELYN $. BERGER OrFICIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE. N. C.
B ra dl e y - Direct 44 1 report?
g A No.
3 O Those are s up po rtin g in f o r m a ti o n, back-4 ground documents behind the Task Force reports?
5 A N0*
6 Q What are th e s e documents ?
7 A They are the same as those documents. or a the bulk of those do cume nt s. T hi s is a form that I 9 d ev elo pe d to keep track and record for p o s t e rit y the 10 s pe cific r eco mm enda tion s , th e action that was taken 11 on the s pecific r e c o mm e nd a ti on s and who did it.
12 O All right, sir; did you p ro vi d e those docu-13 ments to Mr. VanDoora?
14 A Yes.
15 Q He has c o pie s of a ll those?
16 A If the mails are out, he does, sir. I 17 don't mean to be f ac etiou s, but it was sent out this 18 morning.
19 Q The copies of the th r e e that you just gave 20 me?
21 A Yes, the whole stack.
22 O Mr. VanDoorn got sent a copy of the whole 23 stack today?
24 A Yes.
25 Q B ef or e today did he have a copy of this?
eve tvN $ SERGER CFFi;tAL COURT REPORTER U. S. DISTRICT COURT
@M A R LOTTE n N. C.
Brndlay - Direct 45 1 A No.
2 Q There were two item s provided today. I 3 b eli e v e you referred to three.
4 A We have w P12 and WI19, and a third, I 5 guess is not one that came today.
6 Q E a rlie r than today, Mr. B r a dle y, did Mr.
7 V anDoorn ever ask for copies of th e s e s p e cifi c 8 r ecommendation documents ?
9 A No; c o r r e c tio n, Mr. VanDoorn never asked 10 me for c o pie s of those documents.
11 Q You just sent them to him today?
12 3 y.,
13 Q You talked to hi m - -
14 A No, I talked to him yesterday.
15 O W ha t did you talk about yesterday?
16 A T ha t I would attempt to get those down the re 17 to him, and I would attem p t to bring it to him today 18 if I wasn't in the De po sition here.
19 Q How did th e subject of providing those 20 documents come up, M r. B ra dley ?
21 A I und e r s to od --M r. Carr called me yester-22 VanDoorn had day af ternoon and told me ths.t M r.
23 requested that I send a copy of those to Mr. VanDoorn.
24 VanDoorn and told him I then contacted M r.
( 25 I was carrying o tt M r. Johnson's wishes: and I sent EVELYN $. BERGER OFFICIAL COURT REPORTER
- u. S. OiSTRICT COURT CH ARLOTTE. N. C.
Bradloy - Diroct 46 1 him a memo to that ef f e c t.
2 O M r. VanDoorn?
3 A Yes.
4 Q Do you have a copy of your memo to Mr.
5 VanDoorn?
6 A Not with me, sir.
7 MR. G UILD : C ouns el, will you pro-8 duce a copy of the memo to M r. VanDoorn' 9 MR. GIBSON: Would you like us to 10 get a copy of that?
11 MR. G UILD : Mr. B r adley is not goin g 12 to be available beyond this af ternoon; is 13 that right?
14 MR. GIBSON: I believe th a t 's c o r r e c':.
15 MR. G UILD : Yes, I would lik e a copy 16 of the VanDoorn memo, please. We are 17 now r un ni n g what tim e , sir?
l 18 MR. GIBSON: Twenty-five minutes to.
l 19 W e will c a ll a secretary and find s om e -
20 body who can fin d a copy and have th em t
21 do that.
j 22 Mr. G u il d , we have called M r.
23 Bradley's secretary and made arrangemento 24 for her to meet M r. Bell with a copy of 25 th e memo you requested.
EVE LYN $. BERGER OFFICIAL COURT REPORTER
- u. S. DISTRICT court CM ARLOTTE. N. C. )
Bradley - Direct 47 1 MR. G UI LD : L et 's mark this 2 A ugu s t 5, 1982, memo to file as Exhibit 3 One to Mr. Bradley's D e po si tio n, please.
4 ( W h e r eu po n, the document re-5 ferred to as memo to file dated 6 8/5/82, was marked and received by 7 the Court Reporter as Bradley Exhibi t 8
One and entered into the Record. )
9 10 BY MR. GUILD:
11 Q M r. B r a dl e y, I will show you another docu -
12 ment dated July 31, 19 81 (indic atin g). Can you identi,fy 13 th a t, sir?
14 A M r. G uild, it is addressed to me; I don't 15 r e c all seeing it befo re.
16 Q It appears to be a letter from a Mr. G. E.
17 R o s s, QC Supervisor, to you, sir.
18 A Yes.
19 Q And you c an't id entif y it ?
20 A No more than what I told you. I don't 21 r e c all ever seeing it before. Probably I did.
22 O Do you know M r. Ross?
23 A y,,,
24 Q And at that ti m e , July 31st, 19 81, what 25 was your oo sitio n ?
EVELYN $. BERGER OFFICI AL COURT REPORTER U. S. DISTRICT COURT CHARLOTTE. N C. -
B rcdloy - Direct 48 1 A July 31st, 1981, I was QA Manager, A dmini -
2 s t ., a t i v e Services.
3 Q All right, the document appears to r e fl e c t 4 M r. Ross' proposals, s u g g e s tio n s , opinions regarcling 5 th e r e cla s sific a tio n of QC Inspector po sitio n.
6 A Yes.
7 Q What was your r e s po n s ibilit y or du tie s, 8 if any, regarding those positions or that r e cla s sifi-9 c ation ?
10 A At that tim e , sir ? At that time I was 11 res ponsible for a d mi ni s t e ri n g the non-exempt wage 12 as QA Manager of A dmini s t r a tiv e S e rvic e s .
P ro g r am, 13 Q Vi h a t was your involvement in the reclassi-14 fi c a ti o n of the po sitio n s of QC In s pe c to r ?
15 A The r ecla s sific ations ?
16 g 7,,,
17 A I as sisted in the announc e me nt that the 18 r ecla s sification would occur; and I helped to c o m m u n L.
19 c ate the r e c la s s ific a tion to the concerned ins pe c to r s.
20 Affected ins pector s, ho w did you do that.
C.
21 M r. Bradley?
22 A At the tim e we had developed a s li d e pre-23 s entation with hand out s of the non-exempt wage pro-24 gram and how it w ould wo r k.
5 the Weldinc O of the a n ti c a nenoram n- ~
EVELYN 'S. BERGER OFFICIAL COURT REPORTER U. S. Ol3TRICT COURT 4 CH ARLOTTE. N. C.
Brodloy - Diroct 49 1 Inspector po sition ?
2 A Of the e ntir e program.
3 Q As in the QA D e pa rtm en t or beyond?
4 A In the QA D e pa rtm ent.
5 Q And were you r e s pon si ble for that d e v el o p -
6 ment ?
7 A Yes.
8 Q And did you present that s li d e program to 9 the QC W eldin g In s p ec to r s at C at awba ?
10 A Yes; I did n' t present it, I was there at the 11 pre s e ntation.
12 Q And that w o ul d have been in July of 1981, 13 a p p r oxima tely ?
14 A Yes.
15 Q Did you make that pr e s enta tion, your s elf ?
16 Did you speak?
17 A No, I did not.
18 O Did you respond to que stions ?
19 A Yes.
20 Q Were there any que stions ?
21 A Yes.
22 O w ha t were the que stion s ?
23 A I don't r e c all.
24 Q Did M r. Ross ask any qu e s tion s ?
25 A A gain, I don't recall.
EvC LYN $. BERCetR OFFICIAL court REPORTER
- u. S. Di$TRICT court C H A R'.0TTE, N. C.
Brndiny - Diroet 50 1 Q And you don't r e c a ll either r ec ei vin g this 2 letter f rom M r. Ross explaining his obj e c tio n s to a 3 r ecla s sifica tio n, or t a kin g any ac tion on it?
4 A N o.
5 Q L e t 's mark this as Exhibit Two.
6 ( Wh e r eu po n, the document re.
7 ferred to as letter f rom G. E. Ross 8 to W. H. Bradley dated 7/31/81, was 9 ma rk ed and received by the Court 10 R e po r ter as Bradley E x hi bit Two and 11 entered into the R e co rd. )
12 13 BY MR. GUILD:
14 Q Mr. B ra dl e y, what involvement did you have 15 in responding to the Welding Inspector concerns p rio T 16 to the work of the Task Force?
i 17 A None.
18 O Were you aware of the m ?
19 A Yes.
20 Q During th e Task Force efforts ?
l 21 A yes, 22 Q At the time in late '81 and v e ry ea rly '8 2, 23 you worked for Mr. W ells ?
24 A T ha t's correct.
1 25 O And did you p a r tic ip a t e in a n y mee ti n g s with EVELYN $. BERGER OFFICIAL court REPORTER
- u. S. DISTRICT COURT (EM ARWTTE, N. C.
B rn dley - Direct 51 1 M r. W e ll s to dis cu s s the subject of the inspector 2 concerns?
3 A I did not pa rticipa t e in any me eting s with 4 Mr. W ells on wha t--on the W eldin g In s pec to r t e chni-5 cal concerns--to my r ec olle c tio n.
6 O H ow about the non-technical concerns?
7 A No, sir.
8 Q Neither the non-te chnic al o r te chnic al con-9 carns ?
10 A No, sir.
11 Q Did you p ar ticipa te in or attend a July 1st ,
12 19 81, meeting be tween Mr. W ells and the QC Inspectors 13 at C a tawba ?
14 A I can't give you a s pe c ific date, Mr. G uilc ,.
15 I participated in many m e e tin g s during that pa rticu-16 1ar period of time.
17 Q A ll right, sir; let me show you this 18 (indic a tin g). This is a stack of documents provided 19 me by your Counsel, and they were represented to mei 20 to be the Step One recourses and related co rres ponde nce 21 The top one I b e li e v e would be ty pi c al of 22 Does it d e s c rib e, refer to a July 1, all the rest.
23 19 81, me etin g ?
24 A It does.
25 Q With Mr. W ells ?
EVE LYN $. 8[RGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT
@H AR LOTT Eo N. C.
B rodioy - Diroct 52 1 A y..,
2 Q W ould that have been the meeting at which
. 3 the re cla s sification decision was announced?
4 A No, sir.
5 W ha t me e tin g was that?
Q 6
A This m e eting was an attempt to f ollow --
7 c o r r e c tio n, I notic e the date--I did not attend this 8
m e e ti n g, not on that date.
9 Q Do you know what th a t m e e tin g was for?
10 A No, sir; no more than it says there.
11 A nd the meeting that you referred to where O
12 that was af ter the tha slide pre s enta tio n was made, 13 July 1 meeting ?
14 A In that same tim e frame.
15 Did it f ollow the mee tin g at w hic h the p o s i';io n Q ,
16 changes were announced?
I A I don't know.
18 When Mr. C rie r became Corporate QA C
19 Manager, did you and he discus s the Weiding Task 20 Force concerns, the W eldin g Inspector concerns?
1 A At some time f ollowing M r. G rie r 's a pp oi nt -
- m ent, we n a tu r a lly discussed the W el din g Inspector f
l 23 Task Force concerns; but he assigned me the p o s i tio r, 24 of c o o rdin a tin g his r e c o m mend a tion s.
25 Q And did he assign you that p o s ition at the EVE LYN S. BERotR OFFICIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE. N. C.
I Bradioy - Direct 53 1 same tim e as assigning you to th e po sitio n that you 2 now h old with the company?
3 Was that part of your as signm ent?
4 A I was ass i g n e d as Staff A s sis tant prio r to 5 being asigned to th e s p ecific task of coordinatin g the 6 r e c o m me nd atio n s .
7 O When you were assigned the po sition you 8 hold, Staff A s sistant position for M r. G rie r, did you 9 and he discuss the W e lding Inspector concerns?
10 A Not that I r e c all.
11 MR. GISSON: Mr. Guild. I have just 12 been advis ed that the wrong document was 13 sent over by the s e c re ta ry, and she is un-14 able to locate a copy.
15 We can possibly have one telecopied 16 from the site, or give you one in the 17 mo r nin g; but the secretary sent the wrong 18 document over here.
19 It may be that Mr. Bradley can make 20 ano th e r phone c a ll and see. I also ought 21 I think Mr. Bradley has in-to point out.
- 2 dicated on the e a r li e r documents, is a v ail .
23 able tomorrow but is not a va ilabl e next i 24 week.
25 I think we may have gotten that mired EVELYN S. SnRGER OFFICIAL COURT REPORTER U. S. DIETRICT COURT
@H AR3 0TTE, N C.
54 1 up e a rli e r when we were t alkin g; but how-2 ever you prefer us to do that, I think we 3 can de that in the morning or have one 4 telecopied.
5 But it probably won't get here within 6 the next three and a-half minutes.
7 MR. G UIL D : Why don't we just resume 8 in the morning then? Let me ask you this:
9 L e t 's resume in the m o r nin g, but what I 10 w ou ld request, C o un s el, is that if M r.
11 Bradley is going to vouch for this docu-12 ment, if he would search for any other 13 co r re s ponde nc e that he has with Mr.
14 VanDoorn and make that available in the 15 morning also?
16 Nt R . GIBSON: I think that has been 17 done; and in response to your qu e s tio n s 18 about the correspondence p o r tion of that 19 file, he looked at th o s e and there were no 20 others.
21 GUILD: I would a s k him to check.
h1 R .
22 He has found one and--
23 MR. GIBSON: You want to re sume 4
with him tomorrow morning ?
25 MR. G TTI L D : Yes, and Mr. W ells.
EVEl.YN $, BfRGtR OFFICtAL COURT REPORTER U. 5. DISTRICT COURT CHARLOTTE, N. C.
55 t
1 MR. CI3 SON: And we will take Mr.
2 W ells as soon as we are fini s h e d with .N . r .
3 Gradley.
4 For the R e p o r t e r 's b e n e fi t, as I unde r-5 stand we will br eak for lunch tomorrow 6 and that will be it.
7 MR. GUILD: W ell, we will fi ni s h up 8 Mr. Vi e ll s and break for the day.
9 (Whereupon, the D epo sition 10 adjourned at five o' clock p.m.)
11 12 I, William H. Bradley, he r eby c e rtif y that I have read and understand the foregoing t r an -
script and b elie v e it to be a true, accurate and complet e trans cr ipt of my t e s timony.
17 l
l 18 19 William H. 13 r a d l e y 20 T hi s D epo sition was signed in my i presence by Willi a m H. Bradley on the day of l 22 July, 1983.
24 l 25 x,,,,,,... , ,, w i ; ,
EvELYN $. BERGER e OFFICIAL COURT REPORTER U. s. DISTRICT COURT (200(Oft /6FENT, N. (R.
56
- 6. s 1 C E R T I F I C A T E 2 STATE OF NORTH C AR O LIN A 3 COUNTY OF MECKLENSURG 4 I, Lynn B. Gilliam, do hereby c e r tif y 5 that the proceedings were by me reduced to m a c hi n e 6 shorthand in the pres ence of the Witne s s, af terwards 7 transc ribed upo n a typewriter under my dir e c tio n; a n c!
8 that the foregoing is a true and correct transcript 9 of the proceedings.
10 I further c e r tif y that these proc eedin g s 11 were taken at the ti m e and place in the foregoing 12 c a p tio n s p e cifie d.
13 I f urther c e r tif y that I am not a 14 r ela ti v e , Couns el or Attorney for either Party or 15 o the rwis e interested in the o utc o m e of this ac tio n.
16 IN W IT N E S S WHEREOF, I have hete-17 unto set my hand at Charlotte, North C a r olin a , on 18 this the day of July, 1983.
19 20 21 22 LYNN B. GILLI A M Court R eporte r 23 24 My Co mmi s sion expires M ay 12, 1988.
l EVELYN $. SERGER OFFICI AL COURT REPORTER U. S. DISTRICT COURT r 6 ]