ML20078L785

From kanterella
Jump to navigation Jump to search
Transcript of Bw Deaton Deposition in Charlotte,Nc Re Contention 6
ML20078L785
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 07/14/1983
From: Deaton B
DUKE POWER CO.
To:
Shared Package
ML20078L617 List:
References
FOIA-83-434 NUDOCS 8310240065
Download: ML20078L785 (49)


Text

-

e 6

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket Nos.

DUKE POWER COMPANY, ET AL 50-413 (Catawba Nuclear Station 50-414 Units 1 and 2)

DEPOSITION OF:

Billy Wayne Deaton July 14, 1983 f

+

A79 8310240065 830810 Evelyn Berger Associales P

ER 3-434 PDR STENOTYPE REPORTING SERVICE P. O. BOX 19444 CNARLOTTE. NORTH CAROLIN A 28219 4

a e

L A W Y E R'S NOTES Page Line

' 1 The deposition of Billy Wayne Deaton was taken on the 2

14th day of July 1983 at the legal offices of Duke Power 3

Company, 500 South Church Street in Charlotte, North Carolina.

4 APPEARANCES:

5 Ronald L. Gibson, Esq.

For Duke Power Company 951 South Independence Blvd.

6 Charlotte, North Carolina 7

For Palmetto Alliance Robert Guild, Esq.

2135 1/2 Devine Street 8

Columbia, South Carolina 29205 9

(The deposition commended at 2:08 p.m.)

10 BILLY WAYNE DEATON, 11 having been first duly sworn, was examined and deposed as 12 fnyygygg I3 MR.'GIBSON:

Mr. Guild, this is Mr. Deaton, available 14 for his deposition.

I presume we are proceeding under the I

same stipulations.

Present are Mr. Henry and Mr. Bell.

16 BY MR. GUILD:

I O

ir. Deaton, I am Bob Guild.

I am counsel for Palmetto IS l

Alliance.

We are intervenors in the Catawba licensing 38 proceeding.

We have raised questions about quality assurance l

90 l

~

and construction at Catawba.

Have you heard that?

Are you 01

~

aware of that?

l o,

~~

A Yes, sir.

l a3 0

Okay.

With me is Mr. Philip Jos, of Palmetto Alliance,

~

24 and Ms. Besty Levitis with Carolina Environmental Study Group in Charlotte.

She is running a tape recorder and l

svetva osaasa associar...r aome moarme saavice.cuaatorra. acara caaou==

l

. 1 maintains a record, which the court reporter is also 2

transcribing.

If I ask any questions and I am not being clear 3

in my question, you don't understand a term I am using or I 4

am just not making myself understood, please stop me and ask me 5

to clarify and I will try.

I want to understand that your 6

answers, when they are transcribed, are responsive to the 7

question as asked.

I want to show you, first -- first let me 8

get you to state your full name.

9 A

Billy Wayne Deaton.

10 4

How do you spell your first name?

11 A

B-i-1-1-y, prefer to be called Bill though.

12 0

And, Mr. Deaton, what is your position with Duke Power 13 Company?

14 A

I am a welding inspector supervisor.

15 0

Okay.

Are you a supervising technician?

i 16 A

Yes, sir.

17 G

That's your former title?

18 A

Yes, sir.

i 19 G

Okay.

And where are you employed, sir?

20 A

At the Catawba project.

21 G

Okay.

Let me ask you to take a moment and review the i

text of our contention number 6, which is a legal contention 23 that has been raised in the case - about quality assurance.

24 This is a December 31st, 1992, document.

It is an answer by 25 Duke Power Company to some questions that we asked in discovery.

l avstyn samaan AssociATas. sTawCTyne mEPORTING senWCE. CHARLOTTE. NORTM CAnOUNA i

3 x

l 1

Mr. Deaton, would you look at the bottom of page 3 there, this indented single-spaced quote, and it goes over to page 4, 2

3 and down to the bottom.

Take a few moments and read that, sir, 4

to yourself.

5 (The witness read the document requested.)

6 G

Have you had a chance to review that, Mr. Deaton?

7 A

Yes, sir, I looked over that.

8 0

Had you seen any of that before?

9 A

I think this is the first time I have ever seen it, to a

All right, sir, thank you.

Mr. Deaton, how long have 11 you held your present position at the Catawba station?

12 A

I think since 1980, I believe May of '80.

13 0

Okay.

Where were you prior to that?

14 A

I was at the same job but at a different position.

15 G

What were you doing before that?

16 A

I was an inspector before that.

17 Okay.

And you got promoted to a supervisor in May of '807 l

18 A

Yes, sir.

19 0

Okay.

And who did you work for when you were working as 20 a welding inspector?

21 A

Beau Ross.

22 0

Okay.

And what position did you hold before you were 23 welding inspector?

l 24 A

A welder.

1 5

g All right.

When did you become welding inspector?

.mv........oc.res. sr ~orvas== onraa==avica camorr= aoara caaoun.

4 1

A I believe sometime in 1977.

I don't know the exact date.

G In 19777 3

A

'77, sometime in '77.

4 G

Okay.

And had you been doing welding work at Catawba?

5 A

Yes, sir, since '76.

6 4

All right, and what uid you do before 19767 Construction work, outside construction work.

8 G

At Ca*.auba?

9 A

No, sir.

10 0

All right.

Where had you been employed before '767 11 A

A company called Industrial Textile and Pipf 12 G

All right.

And can you recall when you joined Juke Power 13 Company?-

14 A

1976.

15 G

In '76.

Had.ou been doing welding work before you joined 16 Duke?

17 A

Yes, sir.

18 G

Okay.

How long had you worked as a welder before?

19 A

That is a hard question for me to really answer because 20 I worked as a millwright, a welder and a rigger, a fitter, 21 all that work for the past several years prior to that.

In other words, my field has always been in the construction \\

23 field.

A lot of companies you work for, they require you to 24 fit, they require you to rig, they require you to wald, and 25 I ha"* alm 5"3 -- I hr10 50:n 20:Ociated with it since way back EVELYN SERGER ASSOCLATES. STENOTYPE REPORTING SERVICE. CHAMLOTTE. NOwm CAROUhA

0

.5-1 in the early sixties.

2 O

Okay.

You have done including welding work, but all 3

those other things as well, going back into the early sixties?

4 A

Yes, sir.

5 4

When you.were a welder at Catawba, is that the only 6

nuclear joD you worked on as & welder, here at Catawba?

7 A

Yes, sir.

8 G

And you are a certified welder?

9 A

Yes, sir.

10 g

Okay.

What kind of certification did you hold?

11 A

Shielded metal are and flux core.

12 G

Mr. Deaton, wht> is on your crew now?

What welding inspectiors 13 work for you, sir, at the present time?

14 A

Are you asking for all of the names?

15 4

A list of names, yes.

Maybe we could get Mr. Bell's list.

16 MR. GI3 SON:

Go ahead and start and we will give you that 17 list.

18 A

Let's see, Joe Hinson, Charlie Farrell, Tom Barnes, Jr.,

19 Darrell Robertson, Johnny McCoy, Kenneth Carrikar, C. D.

20 Cloninger.

21 0

How did you spell that man's name?

22 A

C-1-o-n-i-n-g-e-r.

23 0

Okay.

24 A

Alan Gault, Dennis Wright, William McNeil, David ::immermar,

25 Jerry Stanridge.

EVELYN SERGEle ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROLINA

g

' 1 S

Is Mickey Stanridge out there as well?

2 A

That's his brother.

8 G

Okay.

Thi= ts Jerry Stanridge, right?

4 A

Yes, and Tim Musen.

5 G

How do you spell that man's name?

6 A

M-u-s-e-n.

7 4

Now, Mr. Deaton, have you always had approximately 13 8

welding inspectors working for you?

8

'A It fluctuates from 10, 12, 13, somewhere in this area.

I8 It fluctuates.

II O

Now, when you became first-level welding inspector supervisor, how many other first-level supervisors wera there at Catawba?

I3 A

One.

14 g

And that was Mr. Ross?

15 i

A Right.

l 0

Mr. Ross was your supervisor at the time?

Was he the only 17 supervisor of welding inspectors before you were promoted to 18 that position?

19 A

He was the only one with a supervising technician title.

20 0

What else was there besides that?

21 A

You had your - what I call your nondestructive examinatio ri,

NDE supervisors.

23 0

And they did not supervise the visual inspectors 7 24 A

No, sir, they handled the NDE work and radiography.

25 a

Whn

  • ra n r3a 4 n er 4hm&

if i;

yk svatvu annaan associatus. svamoryps naponrimo senvice. cuantorra. nonvn camouma

}

-7 I

A Al Napier.

2 4

Someone else?

3 A

I am trying to get on RT.

I want to say Ray Petit, but 4

I may be wrong there.

5 0

Mr. Napier and one other person, in any event, were 6

supervising inspection of weld but not in the visual area.

They did NDE?

A NDE and RT.

4 And what were their titles, if you can remember them?

10 What did they call them?

11 1

I really --

I o

Would they be like level 3 inspectors as opposed to 13 supervicing technicians?

14 A

I would think they would be some type of supervising tech-15 nicians.

to r G

Okay.

Now, why did they, if you know -- how do you under-17 stand or why do you understand they had only one supervisor 18 over the welding inspectors at the time when you worked as a 19 welding inspector?

Mr. Ross supervised 20 or 30 welding "O

~

inspectors at the time?

21 A

Somewhers in that neighborhood, yes.

0 Okay.

And you now have 13 under you, and why do they have a'l all that many welding inspectors reporting to one supervisor,

~

24 if you knew?

25 t

T don't kmv.

T don't think T mn really answer that EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA

_e.

I because that's upper managements, you know.

G You don't have any understanding as to why they had it set 3

up that way?

4 A

Just one supervisor, no, I don't know.

5 G

When you became supervisor, how many of the welding 6

inspectors went under you, roughly?

A Let's just say approximately ten.

8 G

Okay.

And so Mr. Ross kept more under him than went 9

under you when you got promoted, roughly?

10 A

You know, I can't -- I really don't remember the answer 11 to that question as to he had more than what I did or I had more than he did.

The exact number, I just don't know right now.

13 G

All right.

Would it be fair to say that they roughly 14 split them between the two of you when you got the supervisor 15 position?

16 A

That would prooably be a fair statement.

i 17 G

Okay.

Now, would it be approximately true, there were 18 between 20 and 30 welding inspectors at the time when you became 19 a supervisor, visual inspectors?

20 A

I would say it would be closer to 20 than 30.

21 G

Okay.

22 A

That would be just more of a guess.

23 4

And how many welding inspectors are there now on the jcb, 24 if you know?

25 8

That'a 2 gced queation.

EVELYN SENGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA

-9 1

g About 45?

Does that sound about right?

2 A

I would say somewhere in that general area, maybe less, 3

maybe more.

I can't put an exact number on it.

4 4

Okay.

Now, besides yourself and Mr. Ross, we just left 5

off with Mr. Sifford, he is a supervisor of welding inspectors 6

out at Catawba, and he just came from McGuire, who else 7

supervises welding inspectors now?

8 A

Stanley Ledford and Bob Harris and Beau Ross.

9 4

Okay.

Now, where did Mr. Ledford come from?

10 A

He was transferred up from the Cherokee project.

11 4

Okay.

12 A

It was Mr. Ledford, right.

13 0

Yes, Stan Ledford.

Had he done that same job at Cherokee, 14 as far as you know?

15 A

Yes, as far as I know.

16 G

And Mr. Harris, where did he come from?

17 l

A He come down from McGuire.

l 18 l

Okay.

And approximately when did they come over?

19 A

Bob Harris has not been down with us too long, around six 20 l

months.

21 O

Okay.

22 A

Stanley has been down I would say approximately two years.

23 I can't put an exact date on it.

24 G

Okay.

Now, how many of the inspectors under you, Mr.

25 C00 ten, God te 1.m ;;DE 144.puuLvu bufusa chuy son crained and EvELYN SERGE R ASSOCIATES. STENOTYPE REPORTme SERVICE. CHARLOTTE. NORTM CAROUNA

,~

-10 I

certified as welding inspectors?

Do you know?

2 A

Right now some of the boys are from Cherokee, and they had 3

the certification from Cherokee.

I think David Zimmerman and 4

William McNeil --

5 G

Okay.

6 1

== went through our extensive training program to be a 7

visual inspector.

They were NDE inspectors, and they went 8

through our training program to become visual inspectors.

9 G

Okay.

And the man that came over from Cherokee?

10 A

They come up with the certification.

11 0

They had been welders before, welding inspectors but not 12 necessarily?

13 1

I really don't know the answer to that.

I don't know.

14 G

Who came over from Cherokee?

l l

15 A

Alan Gault and Dennis Wright.

16 G

Okay.

And the rest of them had been welding inspectors 17 at -- the rest of the welding inspectors at Catawba came up i

18 from being welders before they were welding inspectors?

19 A

Okay.

K. W. Carriker and C. D. Cloninger transferred 20 down from McGuire. I can't speak for the rest of the guys.

21 MR. GIBSON:

Why don't you call cut the names?

22 G

Mr. Carriker and Mr. Cloninger, had they worked as 13 welders before?

24 A

They came down from McGuire.

I just don't know.

i l

25 0

I have Joo Hinson.

l avaLvm esposR AssociATas. sTamoTves REPORTING SERvlCE. CHARLOTTE. NORTM CAROUNA

. 1 A

Yes.

~

G He had done welding?

3 A

Yes, sir.

4 G

Charlie Farrell?

5 A

Yes, sir.

6 G

All right.

Tom Barnes, Jr.?

A Tom went through our training program just like David and 8

Mack.

G Okay.

He had been an NDE before?

0 A

He was an RT and NDE.

11 G

And that was Tom Barnes, Jr.?

I A

Jr.

13 0

RT and NDE7 a4 A

No, just RT.

15 G

Just RT, okay.

Now, Daniel Robertson?

16 A

Yes, sir, he had welded before.

17 G

Johnny McCoy?

18 A

Yes.

19 G

And Tim Musen?

20 A

Tim Musen is in a training program right now.

21 0

Has he been a welder before?

m

~~

A I can't answer that.

I don't know.

23 O

Had ha worked as an RT7 24 A

Eo has worked as an RT.

25 a

n'e n y _

avstru sanaan associAres. syswOrves narOnrimo senviCs. CHAnLOrts. NORTH CAnOUNA 1

A He is from RT.

That's his group.

2 S

Okay.

Formerly been an RT inspector?

3 A

Yes, sir.

4 G

Okay.

5 A

Plus UDE too.

6 G

Okay.

Mr. Deaton, along about late 1981 or late 1982 7

a number of welding inspectors expressed some concerns that 8

Duke has characterized as technical and nontechnical regarding 9

work at Catawba, and you are aware of those concerns, aren't 10 you?

11 A

Yes, sir.

12 G

All right.

And you and Mr. Ross, in addition to the welding 13 inspectors, expressed concerns yourself at the same time, didn't 14 you?

15 A

Yes, sir.

16 S

Now, I want to show you what I think is a copy of some 17 handwritten notes of yours.

I am afraid my copy seems to spill 18 a little bit over the page here.

Let me show you that.

Do 19 you recognize that as your notes, reflecting your concern?

20 MR. GIBSON:

I think this copy is a little better.

I 21 think it does have the first sentence of each word in the margin.

22 You can see where lining up causes the problem.

Why don't we 23 have him look at this one and saa if that is better.

24 A

What was the question?

G First of all, can you identify that?

Is that your EVELYN BERGER ArSOCIATES STENOTYPE REPORTING SERVICE. CNARLOTTE. NORTH CAROUNA

. 1 statomont?

o

~

A Yes, sir.

3 0

Okay.

Now, tell me the circumstances under which you made 4

the statement, this statement that you did, Mr. Deaton.

How 5

did you come to do that?

6 A

Okay.

I see three statements here.

7 0

I want to get you to explain.

Tell me the circumstances 8

about how you came to make the statement itself.

Why did you 9

write it down?

10 A

I think this is where we were asked to put our concerns 11 in writing.

12 G

Okay.

And who asked you to do that?

13 A

I can't put a name on it.

I don't racall who asked.

14 G

You recall a meeting where Mr. Davison talked to a bunch I

15 of folks in welding inspection and asked if people would put 16 their specific concerns in writing?

l A

I am sorry, but -- there may have been.

I just don't 18 recall.

19 0

Okay.

Do you reme:pber a meeting that would have been 20 probably the lith or 12th of January 1982, sometime in January 21' 1982, meeting with welding inspectors with management?

22

(

, A.

I am sorry, again I don't recall either.

23 0

Okay.

In one way or another it came to you that someone 24 requested that you put your concerns in writing, and you 25

M O'ba-"

d4 d, correct?

systvm menosa associares. sismoryps naposmma senvics. cuantoria. wontw canoWNa l

. 1 A

Yes.

2 O

Okay.

Did you discuss with Mr. Ross and welding 3

inspectors the nature of your concern?

Have ycu talked about 4

it among yourselves?

5 A

My concerns are my concerns.

6 Okay.

Let's look at them then.

You started to tell me, 7

and I am afraid mine doesn't --

8 MR. GIBSONr Why don't we pause for about 30 seconds and 9

we will get copies-of this one.

10 MR. GUILD:

I am going to mark that.

11 (Thereupon, a short break was taken between 2:35 p.m.

12 and 2:36 p.m.)

13 g

Mr. Deaton, do you have a better copy there in front of 14 you?

15 A

Yes, sir.

16 0

Now, I would.like, if you would, to explain -- I see it 17 labeled 3, A, B, and C.

18 A

Would you like for me to summarize what I have here?

19 0

Let me just ask you.

The first one I see, "I feel there is l

20 a lack of interest or support from the QA technical group on i

21 NCI's," and then you go on and elaborate about that.

First 22 of all, who was the QA technical group that you had reference 23 to there at the time?

24 A

That's basicall'f, what I said, our QA technical group.

25 Wa do have a group, a QA technical group, and our NCI's and I

svaten es=osa associares. stenorves asec=rino seawes. cuantorra. nonra canouna

. ~

  • 1 stuff gone through this technical group.

2 G

Who was in that group at the time in early 19827 3

A I want to say Joe Shropshire.

I might be wrong, but I 4

want to say Joe Shropshire.

5 4

Joe Shropshire, okay.

And anyone else that you can recall.

6 A

Mr. Bob Morgan was there but I can't remember in what 7

capacity.

8 All right, Mr. Morgan.

9 A

I might be totally off base there.

10 G

All right.

Anyone else come to mind that was in the QA 11 technical group that you had refsrence to there?

12 A

There were a lot of people working in this technical 13 group.

You want me to try to name the peopla that were working-14 in this technical group?

15 G

I want to understand it in this context.

I want to show 16 you an NCI.

Let's take this -- let's see, we had one here.

17 Here is an NCI that we talked with Mr. Shropshire about earlier, 18 and this is from about 1981.

This is frem about that time pericd.

19 Now, when you are talking about the support of QA technical 20 group on NCI's, you are talking about the QA review that 21 got performed, that is reflected on that document, aren't you?

22 A

Yes, sir, the QA group.

23 0

The QA approval?

24 A

The form, yes, sir.

25 0

This is exhibit 1 from Mr. Shropshire's deposition.

On twtLYN SERGER ASSOCIATES. STENOTYPE REPORTING SE RVICE. CHARLOTTE. NORTH CAROUNA

a 0 I that NCI form, the Q-1A, there is a place where Mr. Shropshire 2

at the top, it's originared by Mr. Bryant in this case, 3

correct?

4 A.

Correct.

5 G

Mr. Bryant was a welding inspector and was then?

6 A.

Right.

I G

It has technical review, and that is the reviaw performed 8

in this case by Mr. Baldwin, correct?

9 A

Right.

10 G

Okay.

And Mr. Baldwin was - he was your supervisor at II the time, correct?

He was over you?

12 A.

Yes, sir.

I3 G

Okay.

And then from Mr. Baldwin it went to Mr. Shropshire,

I#

and he did the QA review?

15 A.

Yes, sir, is G

Now, that's the review of the origination, and you are 17 also talking about the QA review of the resolution of the NCI, 18 correct?

A.

Right.

20-G Okay.

And that's what is shown down the bottom of the l

form under the heading " Correction Action," and it has got a QA approval down there too, right?

A.

It has another QA approval here.

l 04

~

G I am sorry, I missed that one.

Okay.

There is a QA 25 review of the cricination. OA mview of the mi n t ion. correct.

EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA

=

. 1 also signed in thia case by Mr. Shropahire?

o

~

A Yes.

3 G

And than a QA review of the correction action, also Mr.

4 Shropshire?

5 A

Yes.

6 O

Ncw, in your statement, Mr. Deaton, you say that the 7

evaluation justification. action and inspection requirements 8

do not answer the problem as stated on some NCI's, but that 9

NCI's get QA approval.

Tell me what you meant by that please.

10 A

We have to go on to where what my concern is there.

11 G

All right.

A And my statement is my concern is that my responsibility 13 to question these resolutions or to accept them without regard 14 to the answer.

As to the support from the supervisor, it is 15 their job to make decisions on problems.

I may not fully 16 understand but accept it as a. person whose experience is much 17 greater than mine.

And I do havq the chance to express myself 18 l

if I disagree.

In other words, what I am trying to say is, 19 l

13 his c:cpertise to be questioned or not.

20 G

Gnay.

And that was with respect to the QA technical 21 l

group's roview and approval of the NCI, is that what you are m

~

talking about?

23 A.

Ycs, I feel sure this went to that group.

24 G

That's what I mean, when you are talking about whether 25 4 ' ""

7^"" "0CCE?iIllii7 t0 T22*.102 th02 ICCC10tiOEI, IE#

EVELYN.ERGER ASSOCIATES. STENOTYPE REPORTING SE RVICE. CHARLOTTE. NORTM CAROUNA i

t

-la.

1 you were talking about the resolution by the OA technical 2

review?

3 A

What I am trying to say is, my expertise is at a level.

4 Their expertise is at a higher level.

Should I question the 5

answer when I do not have the expertise what the higher level 6

has?

7 G

Okay.

All right.

And how was that concern of yours 8

resolved, Mr. Deaton?

9 A

I think i'c has given us the opportunity to take NCI's to back, whereas the statement, the deposition of the value 11 justification may or not-truly have answered the questien and 12 get them rewritten, the deposition and the justificatien.

I3 ~

G What's changed to allow you to do that that you couldn't I4 do that before?

15 A

Better communication 16 l

G Did you have any procedure changes that allow you to do that i

t 17 i

that didn't exist before?

18 A

Idon'tthinkso.

19 G

Okay.

Wall, how do you answer the question that you had 1

l w

I then?

You had a question then, as I road you, Mr. Deaton, 91

~

which sid, you know, am I supposed to question these resolutions, l

1 or am I supposed to just defer to the man with more experience

~~

23 who is my boss, and how did you answer that question?

Were 24 you supposed to accept it or were you supposed to question it?

l os A

Acain it comes down to what I call ccmmunication, not knowing

\\

EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CNARLOTTE. NORTH CAROUNA l

19-I how to communicate.

I think communication, part of it has 2

greatly.been improved.

Have I answered your question now?

3 G

Well, I guess I am still left trying to understand what 4

the answer to your original question was, and that, is it 5

my responsibility to question these resolutions or to accept 6

them without regard to the answer.

That's your question.

I 7

want to know how you answer that if you have got an answer.

8 A

I e.m going to answer that b; saying that if'I feel like 9

the evaluation justification is erroneous to a statement, 10 I will question the NCI at any time.

11 G

Okay.

Now, what I want to understand now is, if you have 12 such a question, how is that question resolved?

13 A

I pass it back up through my supervision.

14 G

Okay.

Is it thair job to resolve it?

15 A

They will get together and come back and either show me 16 justification or the NCI would get reevaluated.

17 G

Mell, they would either show you justification, and what 18 happens if they don't show you justification?

19 A

I keep on protesting.

20 0

Okay..

Let me ask you one question.

Did you get inter-21 viewed, Mr. Deaton, by Mr. Zwissler',' the consultant to the task 22 force that was looking into these concerns?

Dc you remember?

23 A

The name just don't ring a bell.

24 G

Okay.

You don't recall speaking with a consultant task 25 force?

EVELYN SERGER ASSOCIATES. STENOTTPE REPORTING $$RVICE. CNARLOTTE. NORTH C%ROUNA 1

1 I talked with some = embers of the task force but names 2

I do not remember.

3 G

Okay.

4 MR. GUILD:

Do you have notes --

5 MR. GIBSCN:

The Zwissler dormment indicates the persons 6

he interviewed.

We can pull that document and see.

His 7

report indicates who he interv#.ewed.

Iir. Deaton does not appear 8

on the list of quality assurance personnel interviewed.

He 9

doesn't appear in construction personnel interview nor the task to force personnel interview.

11 MR. GUILD:

Okay.

12 C

Under the procedure as it c. Misted at about the time that 13 you wroto these concerns, Mr. Deaton, if a welding inspector 14 under your supervision identified a deficiency that he believed 15 should be treated as an NCI, should be nonconformed, what was 16 your involvement in that?

How did you deal with that issue?

17 A

I would think the inspector would write the doncription 18 of the itam and a statement of the problem on the Q-1A form, 19 and I would review this statement on the form to see that it 20 was procedural riolation.

91

~

0 Okay.

22 A

And then I would co-initial it with the inspector to show 23 that I had reviewed it, to see that it did make a clear statement 04 of the problem.

O Okav.

And where would you initial it. Mr. Deaten?

EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE CHARLOTTE. NORTN CAROUNA

. I A

In with the inspector.

2 O

In the origination block there?

3 A

Yes, sir.

4 0

Okay.

And what initials did you use?

5 A

I just used BD.

6 G

All right.

That was your practice generally, was to put I

the initials on them?

8 A

Right, that's when I reviewed it for clarity, to see if 9

it needed any wording or what have you.

IU G

Okay.

And you reviewed it to see if in your opinion it II was a valid nonconforming item?

12 A

Yes, they were valid, you know, and I just reviewed it I3 to see mainly that it did state the problem.

I4 0

Okay.

Did you understand that the procedures in effect 15 at the time required you to initial the document?

A No.

O That was just your practice?

18 A

Okay, that was a deal to where it got originated back to, 19 it could, through our office mail, could get back to me.

G Uh-huh.

21 A

In other words, with the number of inspectors and supervisors, V

y~

the initial there, it would come in, you know, a stack available 23 would come in, and you could say this one belonged to Beau or 94 this one belonged to Bill or this one belonged to Stanley or 25 what have you.

.v.tvu.... associares. sr=~ome aemar=a ss=r.< cuaa'om aoara caaouaa l

1 S

Then you would initial it showing you had seen it?

2 A

Right.

3 G

Then what?

Give it back to the inspector?

4 A

Yes, the inspector then would take it for a technical

.5 review.

6 G

Okay.

Now, at that time who did the technical review?

7 A

Well, what time are you speaking of?

8

{

G By the time of these concerns >

9 A

It would be Mr. Baldwin.

10 Charles Baldwin?

II A

Right.

12 0

Mr. Baldwin, he was your supervisor at the time?

13 A

Yes, sir.

I4 0

He would take a look at it, and what would Mr. Baldwin is do?

I6

'A He would sign it and then pass it on to our technical, 17 QA technical.

18 g

If Mr. Baldwin reviewed and his technical review concluded 18 that it was not a valid nonconforming item, how would you hear 20 about it, and what would you do?

01 A

He would usually call me back or get with me on it, me

~

22 and the generator or the originator.

23 G

The inspector.

He would call you both in?

A Right.

25 0

And you would talk about it some?

EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NCRTH CAROUNA

  • 1 A

Yes.

2 g

What happens if Mr. Baldwin continued to hold the opinion 3

that it was not a valid NCI?

4 A

Well, rephrase that for me or restate it.

5 0

You and inspector go in and see Mr. Baldwin, and you talk 6

about it, and the inspector says yes, this is an NCI, and it 7

should be written up as NCI, and you agree with your inspector.

8 fir. Baldwin disagrees and says no, it's not a valid NCI.

You 9

have to get the guy to rework the item, or don't write it up.

10 What happens then?

11 A

I am tninking.

12 MR. GIBSON:

Do you need to confer with me?

13 THE WITNESS:

Yes.

14 (Mr. vibson conferred with the witness.)

15 A

I reckon the only time that I recall of a situation like 16 this happening to me was when the craftsman was there, and the l

17 craftsman says, " Hey, lcok, I will get rid of the problem."

18 I will say, "The material did not have no identification.

Which 19 one of our procedure requirements to check for is material?"

l l

20,

Tha craftsman says, " Hey, I will cut it out."

l 21 Then, you know, he is going to cut it out, we have solved i

22 the problem.

The problem was that the material was unidentifiable, 23 and he is going to git it out and get an identifiable material, 24 so really the problem is solved.

l l

25 4

Okay.

EVELYN SERGER ASSOCIATES. STENOTYPS REPORTING SE RVICE. CHARLOTTE. NORTM CAROUNA m-,.

  • 1 1

That.'s one of the only cases that comes to my mind as 2

the answer to your question there.

3 G

Okay.

4 A

The craft was there, and the craft was willing to remove, 5

and again I an using material I had as an example, and they 6

were willing to cut it Cut and discard it, threw it in the trash 7

can, what have you.

8 0

Okay.

Now, in that situation, that actually happened, 9

correct?

10 A

Yes, I am pretty sure we had one case where that happened.

11 O

Okay.

In that case, had a Q-1A been written up?

12 A

Yes, sir.

13 0

Okay.

How did this happen?

Tell me what happened.

What point did you get with the craft and the craft say, "I will take 14 15 care of the problem"?

At the point when you got to Mr. Baldwin?

16 A

Yes, sir, when we got to Mr. Baldwin's office for review, l

17 craft come in and asked if they could cut out the material and 18 destroy it rather than carrying the NCI through because 19 chances are that would have been the -- the evaluation was to 20 remove said material.

21 G

Okay. What would Mr. Baldwin have said about that?

22 A

Mr. Baldwin says, " Hey, if you get rid of the problem, l

l 23 then we really don't have an NCI."

24 0

His conclusion was to fix the work and we will fix the i

25 problem?

EVELYN B ERGER ASSOCIATE S. STENOTYPE REPORTING SE RVICE. CHARLOTTE. NORTM CAROUNA

,~

. 1 1

Pight.

2 G

And do you agree with that?

3 1

Yes, sir.

4 0

And so the work got fixed?

5 1

Yes, sir.

6 G

What happened to the Q-1A7 7

A It was never -- it just never was in existence really.

8 G

Okay.

Well, it got to the point where the. originator had 9

written it up, right?

10 A

Right.

11 G

And you had initialed it?

12 A

Right.

13 G

And you got to the point where it was going to have a 14 technical review?

i 15 A

Right.

16 G

And I assume Mr. Baldwin didn't sign it at this point 17 because he had figured how to deal with it, right?

18 A

Craft come in.

It don't beccme an NCI until it gets a 19 Serial number on it.

20 g

Okay.

This one hadn't a number put on it?

21 A

Hadn't been serialized.

22 G

or logged?

23 A

Right.

24 G,

And so what happened to 0-1A7 23 A

It would just become invalid.

In other words, it just I

l EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE, NORTH CAROUNA

. 1 didn't go because the craft took it upon themselves to solve th e 2

problem of the justification of the NCI theirself, remove 3

the article.'

4 n

Okay.

But what happened to the piece of paper, the form, 5

the Q-1A form?

6 A

It was probably discarded.

7 0

Okay.

Do you know if any record was kept of that 0-1A 8

or its resolution?

9 A

It never did get a resolution.

/

10 0

It did get a resolution, it just didn't get written up, 11 right?

12 A

I think you are not following me or I am not following 13 you, one.

14 0

Okay.

15 A

The nonconforming item has to go thrcugh steps.

At one 16 point craft and the inspector, myself, and Mr. Baldwin got 17 together, and craft says, " Hey, look, I want to cut it out."

Chances are that the evaluation -- that craf t felt like the is 19 evaluation was going to be cut out, so they wanted to cut it 20 out.

Okay.

They felt that there was no need for the NCI, 21 because, like I said, they wanted to cut it out -- they felt like that's what the justification would be, so really it would 22 boil down to you had a problem, you had a potential problem, 23 but it got resolved before it ever really got reported.

24 0

Okay.

As far as you know, it never did get reported?

g3 EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvfCE. CMARLOTTE. NORTM CAROUNA

,e

A Right.

In other words, it got cut out, which really didn' t 2

require reporting.

3 g

All right.

That was consistent with the procedure as you 4

understood it at the time?

5 A

I would think it was in accordance with the procedure, 6

yes.

G Is that in accordance with the procedure as it exists 8

today?

8 A

Well, today we are operating under somewhat different to guidelines.

11 Q

Okay.

How were they different in this situation?

How 12 would & be handled differently in this situation?

I know Mr.

13 Baldwin is not there.

A Okay.

First of all, the inspector in the field would have I4 15 hold points or process control, which requires signature for 16 him to sign.

17 So it would be fixed earlier to save you a little bit 0

18 of trouble?

1 The inspector would say, " Hey, I am not in accordance with 19 the program, I can't sign your process control."

0 It would be fixed then, and he would sign process control, 21 22 after it had been reworked?

23 A

After it had been reworked and taken out.

24 0

How would that be documented that it had been taken out, 3

now, today?

EVELYN SERGER ASSOCIATE S. STENOTYPE REPORTING SERVICE. CHAMLOTTE. NORTH CAROUNA

-.,_-n.--.

  • 1 A

If the form had a rejection block on it.

The rejection 2

block would be marked as to why it was rejected.

3 G

Would it have a rejection block in all cases?

4 1

In some cases there is not rejection blocks.

In some 5

cases there is rejection blocks.

6 0

If there was a rejection block, how would you document that 7

you were required to rework, had been cut out?

8 A

We use a sign-up sheet.

I don't know whether you have 9

heard of sign-up sheets or not.

10 0

No, sir, huh-uh.

What's that?

11 A

Craft comes and asks for an inspection.

12 Q.

Okay.

13 A

And we put it down on this piece of paper, and if we turn 14 that inspection down, we put a reason on that piece of paper, 15 and that passes it on to the other inspectors because everybody 16 is reading it, and plus they pass it on verbally.

17 G

How long would you use this sign-up sheet?

18 A

We have had them in existence for quite a while.

19 G

Since before these concerns are written up?

N A

Tho shcat that we have went through several revisions.

I 21 can't say that the sheet had all of the information on it that 22 we gather now when the concerns were writ ten up. I can't say 2a that.

24 G

What happens 6 those sign-up sheets? Are they used for s

anything other than just signing inspectors, making sure you EVELYM BERGER ASSOCIATES. STENOTTPE REPO8rftNG SERVICE. CHARLOTTE. NOfrTH CAROUNA

- - - - ~,,

. I have an inspector around to see a piece of work?

2 A

We review them to see what the workload is in what areas, 3

whether we need to up our inspectors or what have you.

We see the i

4 number inspections that the inspectors are making.

We ses problems 5

with potential or problems with fitters or welders or what have 6

you duo to the rejections that is on the sheet.

7 G

What's the name of this form, or has it get a name?

8 A

We just call it a sign-up sheet.

9 0

Did it specify any of the QA department procedures, that to you know about?

11 A

No.

In other words, an inspector, he is out inspecting.

12 A craftsman may ccee, and if I may use an example --

13 G

Sure.

14 A

He will come, and he will put his name down as him being 15 the craftsman.

He will put the type of inspection he wants, i

16 clean up, fit up, final, et cetera, and he will put the craw l

that he works for, and he will put the time, and he will l

17 oven go and put a column location to where he is working at, 18 and then he will go on back to his work area, and the inspector l

19 will come in, and he will check his list, and he will see where 20 21 he has got to go to next.

Okay, if he sees.he has got three finals, for example, he will go out there and he will check 22 the finals.

If all three of the finals is good, he has a 23 little bicek here where it says, " Accept," and he will put 24 three.

25 i

EVELYN SERGER ASSOCIATES. STENOTYPE REPORT 1NG SERVICd. CHARLOTTE. NORTM CAROUNA

. 1 G

Cn the sign-up sheet?

2 A

Right.

If he has got two that is bad, he puts two.

If 3

it is reject, and one is accept, and then he will put out 4

here the reason.

5 G

Uh-huh.

And if it is reject, does he do the reinspection?

6 A

We try to.

7 O

Try to have the same inspector do that?

8 A

Yes.

9 G

What happens if it is the next shift?

10 A

He would --

11 G

Hold it over until he comes back?

12 A

tio, the next shift man would look at it.

13 G

The inspector on the next shift would lock at it?

14 A

Right, or another inspector would do it.

We don't try to hold it to the same individual because all of our standards 15 are the same.

We like for the person that turned it dcwn to 16 look at it.

17 is G

Okay.

19 A

Dut we don't hold it to that.

20 G

okay.

21 G

And who keeps these sign-up sheets, Mr. Deaton?

22 A

For my crow, I have mine in my office.

23 G

You kept them ever since you started using these things?

A No, I don't have that much of a backlog.

I usually keep 24 them six months or what havo you, you know, and review them 25 EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA

. i I

and then I will throw them away.

I probably have si:: months 2

back, maybe a little longer.-

3 0

Okay.

How many things did you generate?

One a day, two 4

a day ?

5 A

We use these sign-up sheets per elevation in my particular 6

area of interest.

Sometimes we go through three or four sheets 7

all in elevation.

8 G

Per shift?

9 A

Yes.

10 G

Okay.

Do you compile any of the information that is 11 on these sign-up sheets, any other kind of report or document?

12 A

Yes, sir, our clerks, when they do a final visual, our 13 clerks take off the final visual, the inspector puts down the weld number, and our clerk uses that with the weld g4 15 packages that come up, and we have a running log of what weld 16 packages come through our office and go to the QA department for QA review.

17

(

ig G

Okay.

How about any of the information you used in

~

talking about any of the monitor or wor' load, number of e

te inspectiens and rejections of work, take any of that informatie n 20 off of the worksheets, off of the sign-up sheets?

What I 21 am interested in is this -- when you got the worxsheet, your 22 clerks or anybody else take off any of the information about 23 how many ir.spections a particular inspector has been performing 24 keep that any place other than on a worksheet?

25 l

EVELYN SERGEst ASSOCIATES. STENOTYPE REPORTING SERylCE. CNARLOTTE NORTM CAROUNA

  • I A

The clerk gives me periedicals.

She willgive me the 2

number of inspections that each inspector makes per week.

3 g

She would do that on a report?

4 A

Just a little piece of paper, she will have the names 5

and the inspections they do.

That is just for my information, 6

to see if I need to reinforce here or mhve inspectors there.

7 g

Okay.

8 A

To be sure that the craft is being adequately covered.

4 Okay.

Do you keep tliose forms?

9 10 A

Yes, sir.

11 g

For how long?

12 A

I don't knew how many back I have got.

I have got scme 13 there in my desk.

I don' t know how many.

Scme weeks the clerk 14 dcn't even get it to me.

15 g

Okay.

s. T 16 A

That's strictly fcr me scheduling my people.

17 g

You use it to evaluate their work?

18 A

Just mainly for scheduling purposes.

19 4

How about the other piece of information, the rejections.

20 for individual welders?

You 'take that information off of a,

w 21 sign-up sheet?

22 A.

Okay.

If we get one particular' person showing a lot of 23 rejections, we will go to his foreman, and we will discuss-it i

24 with him.

j 25 g

How do you document the number of rejections for a particular svetvu manoen Associates. sTamOTves,s',oEmo sanvics. cMARLOTTs, NORTM CAmouMA

I welder?

2 A

Again I go back to the sign-up sheets. If we do have a welder 3

Ehat we are having problems with or a fitter that we are 4

having problems with, the inspectors will come to me, and he will 5

say, "See here, Bill, we turned down two fits here and two fits 6

here and two fits here," and then we will proceed to go on to

/.

7 the craftsman.

5 8

G The inspector brings that information to you and maybe uses 9

the sign-up sheet as a source of information to support his 10 position?

11 A

Right.

12 G

Do you or anyone else use those sign-up sheets other than 13 the inspector for that purpose?

s i4 A

I think craft even comes by and looks at them to see what 15 kind of work they are having done.

I don't know for sure.

I i

16 wouldn't want to say for sure on that.

17 G

Maybe craft supervision would come in there?

l A

Right.

I look at them and my inspectors look at them and j ja 19 when they see they have a potential problem, we deal with the i

1 20 potential problem.

21 0

Does that information get carried over onto any other kind 22 of document or report, information about rejections for 23 Particular welders or fitters?

24 A

The information itself may be also recorded on a process a

control form too.

25 4

EvaLYN SERGER ASSOCIATES. STENOTYPE RSPORT1NG SERVICE. CHARLOTTE. NORTM CAROUNA e

.-r

1 g

I understand that it would be, if it gets noted that there 3

2 was a rejection, if there is a box for a rejection, then that 3

weld or fitter's name is on there, right?

4 A

Right.

5 0

What I want to know is, if it ever gets off the process 6

control form or your sign-up sheet, is there any kind of report 7

that lists John Doe welder had five, you know, rejectable welds

) (

8 this week, or anything like that?

9 A

No.

r

.,c 10 0

Not that you know of?

11 A

(The witness moved his head from side to side.)

12 0

It's just a matter of welder noting it or the welding 13 inspector noting it and bringing it to your attention, or if 14 in fact the welder supervision looks at it?

I 15 A

Well, the inspectors theirselves will deal with the welding to foreman and show him he has a potential problem right there.

17 Are they supposed to come to you too when they do that?

18 A

Yes, sir.

19 0

Okay.

We were going through an example about a 0-1A before 3) the procedures changed, and we had gotten to the point of 21 talking about the technical review, and that was Mr. Baldwin's 22 review at the time and you told me an example of the situation 23 where a piece of work was reworked.

Ncw, I was asking you at 24 that point what happens if you carry the NCI, which you've s

initialed, that's been originated by your welding inspector, EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAROUNA

  • t cond you carry it to Mr. Bald. tin, and Mr. Baldwin decides it's 2

not a valid NCI.

I am not talking about the rework situation.

3 I am saying that is not a valid NCI. What happens then?

4 What happened then?

5 A

I myself, I don't recall a case in which what you are 1

6 stating, I don't recall of a case of that now.

7 0

okay.

8 A

What you are saying is different from what we talked &out 9

a while ago.

to 0

Uh-huh.

I am not talking abc t the rework situation, 11 the instance you remember.

I am talking about a situation, if 12 it ever happened, and if it didn't, tell me, where Mr. Baldwin said that is not an NCI.

13 A

I don't think I ever had that situation arise.

14 15 g

Okay, A

Other than the one, like I say, where we talked about where is it was a mutual agreement.

1; l

18 0

Okay.

A That would maybe cut it out.-

l 39 l

l 0

so for you then for the most part except for that one 29 l

l instance, Mr. Baldwin would look at it, and he would sign off gi I

l giving you the technical approval, and that was your experience,

22 1

he would approve it?

l 23 A

Right.

l 24 l

0 Then it would get a number issued?

23

.mv=.......oci.v...r.~orm n

...vic. co wrra. no.v e..ou.

j l

i 1

. 1 A

Sometimes we would get the number prior to and lay them on 2

his desk, and semetimes we would get technical review.

3 C

First?

4 A

Right, in other words, if he would be out of the office or 5

what have you, you know, we would get a number first.

6 Q

If he was available and chances are you would get a 7

technical review before the number was issued?

8 A

Right.

9 0

The number gets issued and then it gets logged, and then to it goes to the QA people for QA review, right?

11 A

Yes, and the technical, yes.

12 a

You have the technical review already, it goes over to Mr.

13 Shropshire for QA review?

14 A

Right.

15 0

What happens if Mr. Shropshire's evaluation or the technical 16 and the QA technical evaluation is something that you don't agree 17 with?

I am remembering what you said in your concern here, Mr is Deaton.

19 A

Okay.

m 0

We were talking about lack of interest or support from 21 QA technical group on NCI's, the evaluation, justification, act;.on 22 and inspection requirements do not answer the problem as stated.,

23 Now, I am talking about the evaluation first.

Here is Mr.

24 Shropshire, QA technical people evaluating your NCI, and what 25 happens if you don't agree with their evaluation, it doesn't EVELYN BERGE R ASSOCIATES. STENOTYPE REPOfrTING SERvlCE. CMARLOTTE. NOfrTM CANOWNA

. I describe what you found or what your inspector found or doesn't o

state it clearly or correctly or what have you?

8 1

You have about three questions.

4 0

okay.

Take them any order you would like.

5 A

You have got me confused.

Okay.

What I am trying to 6

say here is that this justification evaluation, is it my 7

responsibility to accept what's there?

8 G

Right.

9 A

Being that people with more expertise than what I have 10 write this.

11 O

Right, okay.

That's what I am interested in.

I am sure that 12 I -- I suspect there is no question at all, if he writes some-13 thing dcwn, you agree with it, right?

14 1

Right.

15 0

Fine, but let's say Mr. Shropshire writes scrething down 16 under the evaluation part and you don't agree with it or you 17 don't understand.

18 1

I don't know that Mr. Shropshire would be writing this.

19 0

Who would write this down?

20 1

I believe in this particular case Mr. Sams out of 21 technical support done that one.

22 0

Mr. Shropshire, hd is the one that approved it, right, 23 at this point?

24 1

Here.

25 4

Nhoever, either Mr. Shrepshire writing it up or the person EVELYN SERGER A5bOCIATES STENOTYPE REPORTtNG SERVICE CHARLOTTE. NORTM CAROLINA I

working for hin writing it up, you don't understand or you don' t 2

agree with their evaluation, justification, all right, dis-3 position, what would happen before?

4 A

I would question it.

5 0

Okay.

And then what would happen?

6 A

I would get it sent back through and then I have had 7

them sent back through and have seen the justification on them 8

changed.

9 Q

Okay.

Changed so that you understood it or agreed with to it, one or the other, right?

11 A

Changed to a point where it answered the problem.

12 G That you identified in the NCI?

13 A

Right.

i4 g

Ckay.

What happens if that didn't happen, if they didn't is change it?

16 A

Then I would question it until I got shown satisfaction.

17 0

Okay.

is A

To codes.

In other words, you see, I work by QA procedures.

19 A lot of those evaluations are made from code, m

G So they get the code cut and show you the code that 21 justified their position?

22 A

Right.

23 G

Rcw would you document your question or the question of your 24 welding inspector, if you questioned his justification?

25 A

We wouldn't act on our step.

WWELYN SENGER ASSOCIATES. STENOTTPE REPORTING S$RvlCE. CMAmLOTTE. NonTM CAROUNA

].

1 g

Which would be?

2 A

The SVTW, it says remove the 0-lD tag, and we just wouldn' t 3

act on that step.

4 0

What do those initials stand for, SVT' ?

4 5

A Supervising technician welder.

6 g

That's your signature, that's you?

7 A

Right.

8 0

You wouldn't remove the tag, that's basically the point?

9 A

Just wouldn't proceed on.

10 0

Okay.

And would it appear -- that's like a hold point 11 on that NCI, kind of?

12 A

That NCI, until all of the appropriate action is signed, 13 can't be QA'd.

14 0

Okay.

Would there be any other -- that is simply --

15 that's like getting the rework done., You just don't accept it 16 until it's done right but is there any other way that your 17 question would be documented?

18 A

No more than just bringing the question up and holding onto 19 the NCI.

20 G

Okay.

What happens if all is said and done and you don't 21 get it resolved to your satisfaction?

22 A

I don't know of a case that I hava ever had that hadn't been satisfied.

23 24 g

Okay, good. Now then, let's get to the next step, the 33 final stop, I guess.

What happens if the corrective action the,t I

EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERYCE. CHARLOTTE. NORTM CAROUNA I

l

. l is called for by -- first of all, tell me who writes the correc-1 2

tive action part of the NCI.

Who writes that part up at that 3

time?

4 A

I would think it wouldtm by this originator here, by here.

5 Q

By the QA technical person there, is that right?

6 A

I believe that is put in by the technical group.

7 0

Is that construction?

8 A

Yes.

9 Okay.

The construction people specify the corrective to action?

11 A

I think different NCI's are handled different, depending 12 on the type and who generates.

13 0

Okay.

This particular one called for construction for 14 purposes of evaluation, disposition responsibility, right?

15 That's that box checked thoro, the example we are looking at 16 right now, correct?

17 A

Ccme by me again.

18 0

It has construction as the box checked by evaluation 19 disposition responsibility, right?

m A

Yes.

21 g

Okay.

That means that it's construction's responsibility to take the corrective action, is that right?

22 23 A

That's saying that -- no, that is saying that they are going to -- construction is going to do the evaluation and 24 i

justification.

3 EVELYN SERGER ASSOCIATES, STENOTYPE REPORTING SERvlCE. CHARLOTTE. NOeTM CAROuMA 1

O And they did?

2 A

Evidently.

3 G

Evidently that's why this technical, what do they call it?

4 A

That would be what craft terms as their technical support 5

group.

6 g

That's the construction technical support?

7 A

Right.

8 0

Ckay, all right.

And the sama people respond then for 9

corrective action for specifying the corrective action, in to this case remove the Q-1B tag and attach copy of this NCI to 11 the M-19A in question, correct?

12 A

Yes.

13 0

Okay.

14 A

Here is your corrective action, by same individual.

is 0

Who is in construction technical support?

is A

Right.

17 G

Now, okay, and then it says management has already is instructed the welder per resolutien.

Just say, for example, 19 hypothetically you disagree with that corrective action, y

yo.1 or your inspector disagree with that corrective action or 21 you question it, what happens?

A You are not giving me a good -- well, like this one, it 22 23 says management har already instructed the welder per resolution.

24 Okay, I have to take that at face value.

They are saying 25 that they have already instructed.

You are going to have to EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA

\\

l

)

1

. 1 give me a better example of semething here.

2 0

Okay.

Well, let's make that one the example, if we can.

3 You tell me if we can't do it, it just doesn't make sense, 4

you say you don't think that is appropriate corrective action.

5 You say that welder needs more than just being instructed per 6

resolution.

He needs to be sent back to welding school or 7

recertified or something like that.

I am just saying as a 8

hypothetical, Mr. Deaton, what happens if you disagree, you 9

don't.think that is an effective corrective action, what do you 10 do?

11 A

I would pass it back up the line.

12 G

And what does that mean?

Who do you pass it up to?

13 A

I Jould pass it up to Charles.

14 G

Mr. Baldwin?

15 A

Yes, sir.

When I say I would pass it back to him, I would 16 go discuss it with him.

17 7

Right, okay.

And what happens --

18 And then he would probably take it over to Mr. Shropshire 19 and discuss it.

20 g

Okay.

21 1

And then he may get with Mr. Sams and discuss it.

22 G

Who is the technical support man?

z3 A

Right.

24 0

What happens, after all that is said and done, you, as 25 you stated in your concerns here, it doesn't answer the problem EVELYN SERGER ASSOCIATES. STENOTYPE REPf ATING SERVICE. CHARLOTTE NORTN CAROUNA I

as you understand it, do you still have the problem?

l 2

A Chay, after it goes through these steps, they would either 3

redo this or prove to my originator that that is the proper 4

way to handle it.

3 0

Okay.

And what if they didn't?

6 A

I don't know of a case where we hadn't done that.

7 0

Okay.

As far as you are concerned, that either changed it g

or you were satisfied by their explanation?

9 A

Right.

10 0

Okay.

How would your question be documented?

How did 11 the fact that you questioned the corrective action be documented, 12 if you would?

A By not signing the NCI.

13 G

Again, it's like a hold point?,

14 A

YO8-15 16 O

Deyond that, would it be documented in any other way?

g7 Is there a requirement?

gg Here is your documentation right here, you sign off.

A 0

That's the sign off, that ycu took the tag off?

19 A

Right.

20 0

Deyond that, is there any other documentation of your 21 question?

32 A

No.

23 O

Okay.

Now, we have gene through that illustration, and 34 what about the handling of NCI's before?

I am trying to g5

.v.ua....nocim.. maam a.ao==

..avic.. c=-.. ao m caamaa l

44-I understand.

My concern, is it my responsibility to question 2

these resolutions or to accept them without regard to the 3

answar, and do I understand your concern as being should I 4

keep pressing those questions that I have, or should I just 5

take it at face value that my supervision is more supervision, 6

and being my supervision is going to make the decision?

I am 7

trying to understand your concern in the context of the 8

illustration we have using through, Mr. Deatoni 9

A Again, I can summarize it, my concern was, is do I take it 10 at face value.

11 G

Right.

12 A

Or do I have the right to question it?

13 G

Okay.

14 A

And I feel like I have the right to question it.

g Okay.

You weren't clear on that at the point when you 15 16 wrote this concern?

17 A

Right.

I definitely feel that I have a right to questien 18 it.

19 C

Okay.

New then, we have gone through that one, and that

'M was with regard to the Q-1 procedure and the Q-1A form that was 21 used in 1981.

I am going to shcw you, this is a revision, 22 18 procedure Q-1, is that the current revision, as far as you 23 know?

I understand it is.

24 A

I would probably say it is, yes.

25 G

Flip on through there, the QA-1 form.

EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERV 1CE. CHARLOTTE. NORTM CAROUNA

i HR. GIBSON:

I need to check on the docu=ents.

2 g

You have quote the 0-1A form there?

3 A

Uh-huh.

4 0

Is there anything about the way the Q-1 precedure is 5

handled now or the way that 0-1A form is handled now that 6

addresses your concern, Mr. Deaten, about your responsibility 7

to question resolutions or the manner in which you questien 8

those resolutions?

9 A

I think now we are getting into criteria 16, which gives us 10 a whole lot more insight into the -- they are calling it here 11 the deposition of the nonconformist.

12 g

Talking about the R-6 procedure now?

13 A

Critoria 16 evaluation.

14 G

And the use of the R-6A?

15 A

I look at it as criteria 16 evaluation, where they ccme 16 in and maV.e an evaluation.

17 0

They make an evaluation of the significance of the 18 corrective actien?

19 A

Right.

20 0

Have you ever done an NCI where it was part of your 21 responsibility indicated that it should be handled pursuant 22 to procedure R-67 23 A

I don't think so.

24 G

Okay.

How long has that procedure been in place?

Is that 25 pretty now?

EVEL%N SERGER ASSOCIATES. STENOTTPE REPORTING SERVICE. CMARLOTTE. NORTM CAmouNA n

1 A

Yes, it's relatively new.

2 G

Last month maybe?

3 A

tio, I would say it's older than that.

I can't put an 4

exact date on it.

5 G

Six months?

6 A

You have so many that change so much.

I would say that 7

we could go here, 3-11-83 is when this was approved, so I 8

would say -- I don't know.

I would have to get into the 9

procedure.

I do know that's when the revision was, to G

Okay.

What about the use of that criterien 16 evaluation?

11 What is significant about that in addressing your concern?

12 A

It breaks down to show whether it is generic, nongene ric, 13 requires training, et cetera, and sign off on it.

14 G

But you are not aware of your ever having to use one of 15 those?

l 16 A

ch, yes, in other words, sometimes we will have training l

17 on it.

l I

is G

But what I mean is, you are not aware of your ever having 1

19 initinted --

20 A

To have to initiate ene, no.

l l

l 21 0

okay. Would you be responsible for initiating it if it l

22 was done by a welding inspector under your supervisien, 1

23 correct?

24 A

!To, semebody else would be initiating that.

25 G

Pho would be doing that?

EVELYN SERGER ASSOCIATES. STENOTYPE RkPORTING SERVICE. CHARLOTTE. NORTM CAROUNA

. 1 A

That would be in the technical group.

2 G

Mr. Shropshire?

3 A

Mo, technical support welding or technical support CA.

4 G

Mr. Shropshire or his pecple, people under him?

5 A

It could come from his people.

It could core from 6

technical support welding people.

7 G

Okay.

And if it were on an NCI that your people had 8

initiated, you would know about it?

9 A

Oh, yes.

to G

And you are not aware of any that came from your people?

11 A

I am not following you.

12 G

What I don't understand is, are you aware of any NCI's that came from welding inspectors that ycu supervised that la required the use of the R-6 procedure?

34 A

There probably has been but right new I just can't put 15 my finger en it.

is G

Okay.

Let me show you this.

This is the procedure R-6, 17 isn't it?

j ig l

A Yes.

39 l

l O.

Okay.

Look through there, and you have got -- there is y

,)

a form that is attached to that?

l 21 A

Yes.

g l

0 And that form -- what's it now called, an R-6A, correct?

23 A

Right.

24 G

That form would have to be filled out if that bcx were 3

I

. m v...

.....ocim.. m.on..

-.. m ie..co.=o m.

- c..ou.

I checked on the !!CI, right?

2 1

Right.

3 g

And you would he involved in that --

4 1

Depending on the corrective action required.

5 0

If it was CA -- if it requires reinspection, you would be 6

involved in it, wouldn' t you?

7 1

Right.

8 C

Are you aware of ever having completed one of those?

9 1

I don't recall it.

10 G

Okay.

tihat unit are your people working on, Mr. Ceaton?

11 Are you one unit or the other?

12

.3.

I primarily cover the auxiliary building.

13 MR. CUILD:

Okay, Mr. Deaton, thank you very much.

14 That's all I have.

15 3'l MR. GI2 SON:

16 G

Mr. Deaton, are you aware of anything that would cause you to question wh'ther the Catawba Nuclear Station is safely 17 e

18 built?

19 1

The Catawba Nuclear Station is safely built.

20 MR. GIDSON:

All right, thank you.

i 21 (The depositien was concluded at 3:43 p.m.)

22 23 24 25 EVELYN $E RGER ASSOCIATE S. STENOTYPE REPORTING SERVtCE. CHARLOTTE. NO8tTH CAROUNA

e A l 1

1 I, Billy Wayne Deaton, hereby certify that I have read 2

and understand the foregoing transcript and helieve it to be 3

a true, accurate and ccmplete transcript of my testimony.

4 Billy Wayne Deaton 5

This deposition was signed in my presence by Billy Wayne 6

Deaton on the day of 1983.

7 8

Notary Public 9

CERTIFICATE 10 I, Ann P. Harris, court reporter and notary public, do 11 hereby certify that the foregoing 48 pages are a true, 12 accurate and complete transcript of the proceedings during the 13 deposition of Billy Wayne Deaton; that -Mr. Deacon was duly 14 sworn prior to the taking of his deposition, and that the parties 15 were present as stated.

16 I also certify that I am not of counsel for nor in the 17 employment of any of the parties, and that I am not interested, 18 either directly or indirectly, in the outcome of the lawsuit.

19 This 22 d day of July 1983.

20 21 ANN P. HARRIS - NOTARY PUBLIC 22 State of North Carolina County of Mecklenburg 23 My commission expires:

24 June 30, 1336 25 EVELYN SERGER ASSOCIATES. STENOTTPE REPORTING SERvtCE. CHARLOTTE. NORTH CAROWNA 9