ML20078L809
| ML20078L809 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/14/1983 |
| From: | Shropshire J DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20078L617 | List: |
| References | |
| FOIA-83-434 NUDOCS 8310240073 | |
| Download: ML20078L809 (89) | |
Text
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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter oft : Docket Nos. 50-413 and DUKE POWER COMPANY, ET AL 50-414 (Catawba Nuclear Station Units 1 and 2) >
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DEPOSITION OP:
Joe Caine Shropshire July 14, 1983 l
A 30 8310240073 830810 Evelyn Berger Associates A E 83-434 ll PDR
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The deposition of Joe Caine Shropshire 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 For Duke Power Company -
Ronald L. Gibson, Esq.
951 South Independence Blvd.
6 Charlotte, North Carolina 7
For Palmetto Alliance - Robert Guild, Esq.
8 2135 1/2 Devine Street Columbia, South Carolina 29205 9
(The deposition commenced at 8:20 a.m.)
10 JOE CAINE SHROPSHIRE, 11 having been first duly sworn, was examined and deposed as 12 follows:
13 BY MR. GUILD:
l I4 g Mr. Shropshire, would you state your full name and your 15 business address for the record, please?
16 A My full name is Joe Caine Shropshire. My business address II is Catawba project, of course with Duke Power Company.
18 MR. GIBSON: Mr. Guilds I presume we are proceeding under 19 the same stipulations, and the persons present are Mr. Henry 20 and Mr. Bell with Duke Power Companyi 21 A My name is Bob Guild, I am counsel for Palmetto Alliance, 22 intervenor in the Catawba operating licensing proceeding, and 23 with me is Phillip Jos and Betsy Levitas with Carolina Environ-24 mental Study Group, running the machine. As you may be aware, 25 Palmetto Alliance has raised questions about quality assurance EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE. CMARLOTTE. NORTH CAROLJNA
.- e 1
at construction at Catawba. Do you understand that?
2 A Yes, I do.
3 g This deposition is for the purpose of gathering information 4 in evidence on that contention, and I am interested in as 5
complete understanding as possible of how you do your work, 6
and particularly as it relates to welding at Catawba. If I 7
ask you a question and I am not being clear in what I say or 8
I am using a term you don't understand or what have you, please 9
stop me and ask for a clarification, tell me you don!t under-10 stand. Otherwise I will expectrthat the transcript will reflect II an answer to the question as asked, and I presume you are 10~
responding to that question and understood it. Let me show I3 you a copy of our contention number 6 and ask you to take a I4 moment and look at it. This is a quotation of that contention 15 from a December 31st, 1982, response by Duke Power to some 16 interrogatories asked by Palmetto Alliance, and it's a single-I space indented quote, Mr. Shropshire, begins at page 3 and I8 extends over here to the bottom of page 4. Take a few moments, I9 if you would, and read that to yourself.
oo (The witness reads the document requested.)
91
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4 Mr. Shropshire, have you seen that before?
~
A No, sir, I have not.
4 All right. What is your present position with Duke Power 24 Company, Mr. Shropshire?
25 A My present position is cuality assurance engineer, and
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I the area of responsibility is that of mechanical equipment and 2 piping, welding, nondestructive testing and systems testing.
3 0 Mechanical equipment?
4 A And piping.
5 g Okay. And the rest of that?
6 A Welding.
7 S Welding?
8 A Nondsstructive examination.
9 4 okay.
10 A And systems testing.
11 0 Now, would I be correct in assuming that the systems testi ng 12 part of that is a responsibility that has been added as the 13 plants have become more complete in your testing systems? Have 14 you had that responsibility for the duration of the project?
15 A Well, I have had that responsibility, yes, since I have 16 been at the project.
17 G Now, if you would, Mr. Shropshire, give me a history of 18 your work with Duke Power Company. Tell me when you started 19 and approximately when you were promoted to each position that 20 you held.
21 A Okay. I came to work for Duke Power in July of 1978, 22 and at that time I was hired by the QA Engineering Services 23 Division, and I was hired in to develop and train individuals 24 in inspector certifications in the civil areas. My background 25 is a civil engineer and also a background of teaching at the EVELYN BERGER ASSOCIATES, STENOTYPE REPORTING SERylCE, CHARLOTTE. PeORTH CAROUNA
4 I college level, and so I was hired to develop and train inspectors 2 in the areas of soils, concrete, structural steel and coatings.
3 I remained at that position fore about- six months, and at that 4 time I held the title of assistant QA engineer and then was asked 5 to take the job that I now hold at Catawba, and have held since 6 approximately February of 1979 to the present, as QA engineer 7 for the mechanical welding, NDE areas.
8 0 Your position in July of '78 was assistant QA engineer?
9 A Assistant QA engineer, that's correct, sir.
10 0 Where were you stationed?
11 A Charlotte.
12 0 In the company's offices in charlotte?
13 A That's correct.
14 How about a brief history of your professional training 15 and experience before Duke.
16 A Okay. I graduated in 1967 from Virginia Polytech Institute 17 with a degree in civil engineering, with a specialty in 18 structural analysis and materials. I went from that time to 19 work with the Virginia Department of Highway as a structural 20 steel designer in the bridge division, designing both concrete 21 and structural steel or composite structures. I spent time
" with the Virginia Department of Highway as a project engineer 23 doing highway construction as a tunnel engineer on the j
24 Interstate 77, Big Walker Mountain Project. At that particular 25 time I decided to do additional graduate work and took a job at EVELYN SENGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE NO8tTH CAROUMA
1 Bluefield State College in Bluefield, West Virginia, teaching 2 at the two and four-year level in the bachelor of science 3 engineering technology program. Courses taught were those in 4 engineering, mechanics, structural steel and materials, some 5 math, of course, and also returned to VPI to begin graduate 6 study in the area of civil engineering in materials and 7 transportation. In 1970 I went to work for Holding Technical 8 Institute in Raleigh, North Carolina, which is now Wake 9 Technical Institute, as an instructor in civil engineering 10 technology, again major responsibility in civil engineering, 11 mechanics, structural steel, concrete, surveying.
12 Q. All right.
13 A. In 1971 through 1973 I was on the staff as administrative 14 assistant to the president at Bluefield State College with areaa 15 of responsibility in federal funding, doing the work of 16 grantsman, writing federal grants, being a liason officer with 17 HEW, and these grants would include both technical areas as is supervisory training for the mining industry, which we developed 19 one of the first programs in the country, mining supervising 20 training; also areas of audio tutorial teaching; also served 21 on several boards with the West Virginia Board of Regents, 22 namely those of institutional research. I served on the 23 Board of Educational Television at that time, and also responsi -
24 ble for physical facilities there at tne college.
25 Q. Okay.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
1 A Just some of the duties. Of course being administrative 2
assistant you do other things for the top administrator.
3 g Surely. That is through '737 4
A '73. In 1973, '74, I worked with the Virginia Department 5
of Highway again as assistant to the soils engineer in Richmond ,
6 and served as a consultant for the soils labor throughout the 7
State of Virginia in the highway system. 1975 through 1977 8
I was on the staff at Spartanburg Technical College in Spartan-8 burg, South Carolina. I was chairman of the Department of 10 Civil Technology, and we had a two-year technology program, which 11 is ECPD accredited, and also served South Carolina State Board 12 for the CIV Tec, and that was a bo rd which developed again 13 self-paced instruction for civil engineering and engineering 14 technology courses. In 1977, and '78 I worked for Pittsburgh 15 Testing Laboratories as the manager of the Atlanta regional 16 office in Atlanta, Georgia, and that was as their office 17 engineer and manager, and we were a general purpose laboratory 18 doing inspection of structural steel fabrication, welding, 19 welder qualifications, nondestructive examination, soils, 20 concrete, metallurgical examinations, even doing some minor 21 testing there with regard to safety, seat belts, fabrics and
, 22 so forth.
23 In 1978 I came to work for Duke Power Company. I am a 24 registered professional engineer.
25 In what states, Mr. Shropshiro?
G EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. PeORTH CAROLJNA
1 A I am registered in the State of West Virginia, where I 2
received my original registration. I have been registered 3
in Virginia and Georgia also during those periods of practice.
4 a Who did you work for when you first came to Duke?
5 A I worked for Gill Bradley.
6 G And then when you went to the Catawba project --
7 A I went to work for the Catawba projec.. for Bob Morgan and 8
of course for Wayne Henry.
9 G Mr. Henry was there at the time?
IU A Well, Mr. Henry was Bob Morgan's supervisor.
11 G All right, sir. Give me a sketch of your duties at 12 present, Mr. Shropshire.
13 A My duties at present, QA engineer's job that I hold is I4 responsible for the areas I mentioned previously, and that is would include the implementation of the quality assurance program 16 in those areas, and that being mechanical, walding, in the test -
II ing.
I8 G And describe for me your work relationship with welding IS inspectors. What is your normal contact and responsibilities 90
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with respect to the work of welding inspectors?
21 A My normal contact with welding inspectors comes through 29~
the solution of inspection-type problems, if they have those 93
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things that happen in the clarificational procedures. It comes 94
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in contact through the nonconformance program. It comes in 25 contact in workina with necole in training welding inspectors.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CNARLOTTE. NORTM CAROUNA
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I g Do you have a regular responsibility for the ongoing routin e 2 training of new inspectors?
3 A No, not at the present time.
4 % Have you done that at Duke?
5 A original employment, yes.
6 0 Not since you have been at Catawba though?
7 A That's right.
8 % How about racertification?
9 A No, not at the present time.
10 0 Did you do that in your first position?
11 A Yes, sir.
12 0 What sort of training then do you have in mind when you 13 say training activities?
14 A Training activities would include training on revised 15 procedures or new procedures.
16 0 How about training as corrective action for nonconformancea 17 that reflected deficiencies in inspection?
18 A We do not conduct that training. That is usually done 19 by their supervision, sir.
20 G Okay, Now, I am going to show you -- this is a Q-1A form, 21 just a random one, Mr. Shropshire, but it does have your name 22 on it. There is no particular significance to this one. I Z3 am going to show it to you, and can you identify your signature ,
24 appears a couple of places on there?
25 A Oh, yes.
I EVELYN SERGER ASSOCIATES. STENOTYPE REPOGNG SENCE CHARLOTTE. N 3RTH CARQUNA
1 0 That is the results of a welding inspection and the 2 nonconformance relating to welding, isn't it?
3 A That's correct.
4 0 Okay. What's the date when you last signed it?
5 A The date last signed was 7-22nd, '81.
6 0 By you. That's your last signature?
7 A That's correct.
8 4 Now, that reflects the use of that form under a former 9 version of the Q-1 procedure, isn't that right?
10 L That's correct, it has been revised since that time.
11 0 All right, sir. Now, I want to show you -- let's mark this 12 one.
13 (Thereupon, Shropshire deposition exhibit number 1 was received and 34 marked for identification.)
15 0 Let me show you now -- this is a revision 18 to procedure 16 Q-1, and attached to the back is Q-1A form. Do you understand 17 that to be the current revision of that procedure?
18 A That is the current revision.
G What I am interested in, Mr. Shropshire, first of all, 19 20 taking the version of Q-1A form that has caen identified as exhibit 1, and comparing it to the Q-1A on revision 18, tell 21 22 me how your actions with regard to that nonconformance are 23 different or your actions with regard to the nonconforming item form, the 0-1A, are different, if they are, and what I 34 g
am interested in is a comparison under the procedure reflected EVELYN BERGER ASSOCIATES. STENOTYPE r d'# 171NG SERVICE. CMARLOTTE. NORTH CAROUNA
l 1 in this earlier one, the 1981 version, as compared to the 2 Rev. 18.
3 A My responsibilities for the earlier revision with Rev. 18 4 have not changed. There has been a change in the organization 5 of the form, The earlier revision at the origination stage 6 of the nonconformance, the originator of the nonconformance wou ld 7 sign as originator, and there would be a technical review, 8 and that review would be conducted by his supervision, and 9 occasionally by QA when the supervision was absent, and then it 10 came to QA for review. The QA review on the current conformance 11 form and the QA review in the previous nonconformance form has 12 the same guidelines. We check to see that it is a true non-13 conformance. We check to see that either procedure documents, 14 specification, drawings have been --
15 G Let me get you to slow down just a little bit so I can i
16 take some notes here. You reflect you reviewed to see that 17 it is a true nonconformance?
[ 18 A. That's true.
I 19 g I am sorry, go ahead.
t 20 A In that process we check to see that it is truly_a 21 violation of procedure, drawings or specifications. At that 22 time we also look to see who would be the responsible party 23 to resolve the nonconformance and then we make that designatior.
24 and then we sign it if it is in fact a true nonconformance.
25 We also at the present time do meet on a one-to-one basis with EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SEnvlCE. CMARLOTTE. NORTM CAROUNA
I the inspector or hhe originator of the nonconformance.
2 g Okay. Now, that's presently under the Re'v. 18, correct?
3 A That's correct.
4 0 Okay. Now, compare that to under the procedure before, 5 from the point of origination. Under this procedure the welding 6 inspector is the originator, correct?
7 A The welding inspector would be the originator in either 8 procedure.
9 0 Under the first version, the earlier versica of the Q-1 to procedure, the welding inspector originates, and in this case 11 who is the welding inspector?
12 A The originator on the form you have referenced,12,213, i3 is John Bryant, and he is the originator.
14 0 Mr. Bryant originates, and then what was the procedure 15 followed at that time?
16 A The procedure followed at that time is he would go to 17 his supervision. .
ig 0 Who was --
A Who was in this case Charles Baldwin, 19 go G Okay.
21 A That gentleman would be asked to form a technical review.
He would be asked to sit down and talk with his inspector.
22 1
23 He would review the NCI with him to insure that the NCI was l
24 in fact a nonconformance and to insure he handled the situation g properly.
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I g Would he do essentially the s;ame review that you outlined 2 you perform now or not?
3 A That's true.
4 g Okay.
5 A And then, of course, once he reviewed it and signed it, 6
it would come to QA for QA's approval. At the same time QA 7
would ask those same questions.
g g Same review that Mr. Baldwin performed?
9 A Yes, that's true, to 0 Okay. What would QA do then?
11 A If QA again had determinedthat it was a nonconformance, 12 it would be signed at that time, i3 0 So, first of all, we have originator and then we have Mr. Baldwin as the supervisor?
34 15 A Technical review.
16 0 That is called the technical review?
17 A That's correct.
33 G Then to the right of that, the QA review?
l ig A That's correct.
0 And in this case signed by whom?
20 s 21 A Signed by myself.
22 0 Mr. Shropshire, okay. That's called a OA review?
A OA approval.
23 0 QA approval, all right.
24 A In the old form it was OA review, still QA review.
25 EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA i
1 O Okay. Now, in this particular example the origination 2 and the first level of technical review, they both are dated 3 7-17-817 4 A (The witness moved his head up and down.)
5 g And the QA review is dated 7-20-81. Had the nonconformance, 6 the nonconforming item, been originated at the point where the
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7 QA review was performed under the earlier revision?
l 8 A I am sorry, I don't understand your question.
9 0 Had the nonconformance already been originated at the l
10 point where the QA review was performed under the earlier 11 revision?
12 A The nonconformance had been originated, and you can determine 13 that from the date shown on the form.
14 0 It had been originated several days before it came to l
l 15 you?
16 A Yes.
17 0 Now, at what point under the earlier revision wa:: the 18 Q-1A form logged in and the number issue assigned to it?
19 A Under the earlier revision, the nonconformance, when 20 determined to be a nonconformance, the inspector would have 21 gotten'a number at that time.
22 g At what point would that have been?
23 A Determination of the true nonconformance.
24 4 By whom?
25 A The combination of inspectors and his supervision.
EVELYN SERGEJE ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAmouMA
1 0 In this case Mr. Baldwin. Mr. Baldwin made the first re-2 view, technical review?
3 A That's correct.
4 0 And then it wotid be issued a number?
5 A In most cases it would have been issued a number. The 6 procedure at that time did not require the number at that time.
7 In most cases that did happen, a 0 Okay. When did the procedure at that time require that 9 a number be issued?
10 A The procedure at that time allowed the number to be issuad 11 at the time of origination or all the way through the time of 12 QA approval. Now --
13 g Yes.
14 A Most of the time when it came to QA, it had gone through 15 the technical supervision and the Q-1 did have a number.
16 G Were there cases where the 0-1A did not have a number as 17 the point where it came for QA review?
18 A Yes.
19 Q Why would that have happened? What circumstances would 20 result in 0-1A coming as far as you at that time., Mr. Shropshire?
21 A No particular circumstances.
22 (, Okay. If, let's say, under the earlier revision an inspector 23 goes to Mr. Baldwin or supervision for technical review, there 24 is a question about the existence of a true nonconformance, 25 and the inspector and supervisor have a dispute about that, EVELYN SENGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
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1 the welding inspector believes that a nonconformance' exists, 2 Mr. Baldwin disagrees, would a typical situation be reflected 3 where that disagreement was then brought to you for QA review 4 and a number had not yet been issued, then essentially said, 5 "Mr. Shropshire we want you to take a look at this one". Baldwin 6 says, "I d'on't think this is a true nonconformance. We need 7 QA technical review to determine the validity of the nonconform -
8 ing item."
9 A That did happen.
10 g Okay. It was within your responsibility, Mr. Shropshire, i 11 at that time to determine whether or not the NCI was valid, 12 whether it was a true NCI?
13 A That's true, sir.
14 0 And so it would have been within your responsibility, 15 after it had been past the technical review, to still determine 16 that it was not a valid NCI?
17 A That's true, sir.
gg O Now, what would happen in the former version, Mr. Shropshire, I -
19 if it came to you -- first let's take the example where it 20 he.sn't gotten a number yet. It hasn't been logged. Mr.
21 Baldwin and the inspector have a dispute. It comes to you and 22 you basically concur with the conclusion of the technical 23 review, you concur with Mr. Baldwin's position that it is not a valid NCI, would the NCI be voided at that point?
24 g A The NCI could be voided at that point.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERWiCE. CHARLOTTE. NORTH CAROUNA
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I 1
0 If a number had not been issued in the NCI, the Q-1A 2 hasn't been logged, what documentation would be completed 3 reflecting your decision that it was not a valid NCI?
4 A The practice has been that we would write on the descrip-5 tion of the disposition portion of the nonconformance whether the 6 NCI was valid or invalid in this case, and the reason why.
7 G Would that be done in the instance where no number had 8 been issued for the NCI and it hasn't been logged, the point where 9 it came to you?
10 A That's true.
11 O What happened, the number wouldn't be issued for it, and 12 it would be logged?
13 A The number may not be issued for it, but it would be filed .
14 0 Okay. So in the situation where a number hasn' t been is issued and you determined that it was invalid, no number would 16 be issued, correct?
17 A May not be, sir.
18 G May not be but it would be filed?
19 A Yes.
20 g Where would it be filed?
21 A It would be filed in the QA vault and it would be filed
, n by date. I might add that I have a practice in the past, when l
23 an NCI was determined to be invalid, and this is a personal i
24 Practice that I have had, that when I was a QA review person, 25 I acquired a number anyway. That way it was filed numerically l
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CNARLOTTE NORTM CARCUNA l
1 in sequence.
2 g So your personal practice would have been to refer the 3 unnumbered NCI that had your notation that was invalid under the 4 disposition portion to document control for the issuance of a 5 normal NCI number?
6 A Have the inspector or myself go get a number so that it 7 did get logged in and did get filed appropriately.
4 8 G You understand that that practice was not followed by 9 Mr. Baldwin or Mr. Davison when they determined that an NCI 10 was invalid before a number was issued?
11 A I am not aware of that practice, sir.
12 O Give me an idea under this former procedure, Mr. Shropshire, 13 how many NCI's would be in this file, invalid NCI's, NCI's 14 for which a date was isigned and then they were filed and 15 documented for which no number or logging took place.
16 A I have no idea of the number. The number is very small, 17 but to give you figures, I could not do that.
18 G Are there a hundred for the total life of the project?
19 Ten? Give me a ballpark understanding of what order of 20 magnitude we are talking about.
21 A Probably more than ten and less than a hundred.
22 0 Okay. And are those documents still on file?
23 A Yes.
24 O You maintain those in your file?
25 A No, they are maintained in the QA vault.
EVELYN BERt;ER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
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1 O Who is responsible for the QA vault? Who keeps those 2 records?
3 A The responsibility is under Bob Morgan.
4 4 Mr. Morgan. Are any of those, more than ten, less than 5 a hundred, in the welding area?
6 A I couldn't answer that, sir.
7 g You just don't know?
8 A That's right, don't know.
9 0 Under the former procedure, what was the responsibility to of the first-line supervisor of the welding inspector with 11 respect to the Q-1A, to the nonconforming item?
12 A The first-line supervisor had the responsibility of 13 consulting with his inspector in the determination of the non-14 conformance.
15 G Was the result of that consultation documented under the 16 Q-1A7 17 A The consultation would have been documented by his 18 signature on the technical review block.
19 G That's what I don't understand now. You are talking about 20 Mr. Daldwin now?
l 21 A Yes, sir.
G I am thinking about the first-level supervisor, the l 22 l
23 supervising technician.
24 A Okay. You are talking about the welding supervisor and not the technical - 'cechnical supervisor is Mr. Baldwin.
l 25 EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA
1 g Supervising technician?
2 A Okay.
3 0 First-le'el supervisors?
4 A Right, that would be either the welding inspector's direct 5 supervisor, such as Mr. Ross, Mr. Deaton, Mr. Sifford.
6 O That's what I am thinking about, Mr. Ross, Deaton, l
7 Sifford, what was their responsibility on this?
i 8 A Their responsibility was also to consult with their 9 inspector on the nonconformance, and usually the inspector 10 talked to him before he wrote the description of the non-11 conformance, sometimes maybe indicating the form by initials.
12 You will see that on seme nonconformance.
13 0 Where would those initials be?
l 14 A Initials would be in'the origination block above the l
l 15 inspectsr's name, i
0 okay. What circumstances would the first-line supervisor, l 16 17 supervising technician, would his initials be required along 18 with the originators?
19 A There are no circumstances that would require that, sir.
I 20 0 That was just a matter of --
21 A A matter of review, to say he had seen them.
22 g Sometimes the review would take place without the initials?
23 A It may have.
24 O And sometimes the initials would indicate that the review 25 had taken place?
EVELYN BERGER ASSOCIATES. STENCTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA L
1 A True.
2 O Okay. No particular consistent practice?
3 A No procedure requirement for that.
4 g All right. Now, under the present practice, roughly when 5 did the procedure change in the significant way that altered 6 the procedural responsability that you had for reviewing ECI, '
7 when did that change occur?
8 A That basically has not changed.
9 Q It changed in the sense of you having one-to-one contact 10- with the inspector.
11 A Okay. That change occurred in June 16th of '83.
12 g Okay. And that's the point where the QA review occurred 13 at the point of origination essentially?
14 A That's true.
15 g And up until that time, the technical review and QA 16 review took place essentially in the sequence and with the timing 17 reflected in this earlier version of the form?
18 A Approximately that, sir.
19 g Okay. IIcw about the practice or procedure with respect 20 to logging and numbering of the nonconformance? When did the 21 procedure with respect to numbering and logging the nonconform ance 22 change from the procedure as you described it in the earlier 23 version?
24 A It changed also in the 6th of June of this year.
n g Okay. All right, sir. Are you familiar with procedure EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERylCE. CHARLOTTE. NORTH CAROUNA
.- s 1 46, Mr. Shropshire?
2 A Yes, I am, sir.
3 g I am going to show you a copy. This is revision zero.
4 That'.s a current version of R-67 5 A That's correct.
l 6 g R-6 is a new procedure?
! 7 A New procedure.
8 4 What is your responsibility, if any, with respect to l
l
! 9 implementation of the R-6 procedure?
I 10 A My responsibility occurs at the signing OA approval of the l
11 disposition of the nonconformance stage. At that time I determine 12 whether an R-6A is required or not.
13 G How do you udo that, Mr. Shropshire?
14 A You do that by the guidelines of the procedure R-6 and 15 then the valuation you make at that time.
16 G Give me a description of what that standard is and what 17 that procedure is. What do you do to determine whether an R-6A 18 should be issued?
19 A Standard and procedures under 4.3, "The following items 20 should be considered in the evaluation. Is this condition 21 significant? What is the root cause of the problem? What 22 corrective action is required to prevent recurrence? Are there a possible Duke or industry generic implicatiens? Is this 24 condition repetitive in nature to the extent the corrective 25 action should be implemented? Should this condition be EVELYN SERGER ASSOCMTES. STENCTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
1 investigated at other Duke sites?"
2 g That's the standard you apply?
3 A That's correct, sir.
4 g How many R-6A's have you originated?
5 A R-G has only been in effect since June 16th also, and to 6 this time there have been very few.
7 0 Have there been any?
8 A Yes.
9 0 What areas have they been? What have been issued, what i 10 R-6A's have been issued?
11 A I can only remember several.
12 g Tell me which ones you can remember.
13 A One in welding and one in mechanical.
14 g Tell me about the one in welding.
15 A The R-6A issued in welding was for welding outside the i
l 16 range of the field weld data sheet.
17 g What range?
18 A The range for voltage and amperage.
19 0 Too high or too low?
20 A Too low.
21 O Okay. What kind of work was involved?
22 A Welding on containment.
23 g And what was the nature of the nonconformance?
24 A The nature of the conformance identified the problem.
25 It was identified by the welding inspector.
EVELYN SERGER ASSOCIATES. STEWTYPE REPORTING SERvlCE. CHARLOTTE. NORTH CAROUNA
1 Q Okay. Who was the welding inspector?
2 A John Bryant.
3 g Okay. And what was the nonconformance?
4 A The nonconformance was for welding outside the range of th e 5 field weld data sheet.
6 0 Under voltage or under amperage?
7 A Under amperage.
8 G And what was the corrective action?
9 A Corrective action has not been stated at this time. The 10 R-6A has not been completed.
11 G Okay. How have you determined that it is appropriate --
12 did you make the determination to issue the R-6A?
13 A Yes.
14 O And how did you determine that the standards provided in 15 procedure R-6 req 6 ired that it be treated as an R-6A?
16 A Going back to the procedure and looking at the problem 17 to see if it was a generic type of situation that could occur.
18 g Okay. And was that what you determined, that was generic?
19 A I felt this may have happened. Some or the location in 20 the construction needed to pursue that to evaluate the R-6A.
21 Q Why did you determine that it may be generic?
22 A Information provided by the inspector. He raised the 23 question. We discussed it, and we wrote the R-6A.
24 0 What about this nonconformance reflected that it may be 4
25 generic matter?
EVELYN SERGER ASSOCIATES. STENOTYPS REPORTING SERveCE. CHARLOWE. NORTH CAROUMA
- c. ,- - - . , . . - - . . , - - . . - . - . - . . . . . . - , . . . . - . . . . - - , _ _ - - , _ _ _ . , - - - - . . . , _ , _ . _ - , , _ . ~ _ _ - . . , _ - - - _ , - _ _ , _ _ . _ _ .
1 A 1. formation provided by the inspector.
2 g What information was that?
3 A Violation of field weld data sheet.
4 0 Why did you not believe it was an isolated nonconformance?
5 A Based on the knowledge of the-workings of our craft, 6 it was determined between the inspector and myself that we 7 felt that this could have occurred elsewhere, and we asked for 8 them to pursue this.
9 0 For the craft to pursue this?
10 L The evaluator of the R-6A, which is a representative of 11 construction.
12 S And who would that be?
13 A Ray Hollins. ,
14 0 Who is Mr. Hollins? -
l 15 A Mr. Hollins, would for -- I don't know Mr. Hollins' 16 exact title. He works for R. L. Dick in construction services.
17 0 Okay. And when was this R-6A originated, approximately, 18 Mr. Shropshire?
19 A Approximately one, one-and-a-half weeks ago. -
20 g Okay. Where do things stand right now in terms of 21 point of procedure?
22 A As far as procedure is concerned, we are awaiting Mr.
23 Hollins' evaluation of the R-6A.
24 0 Help me to understand, using data as an example, what n part of the procedure -- direct me to the procedure and then EVELYN SENGER ASSOCIATES STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA
I I the R-6A itself and help me to understand where you stand on that i
2 particular item at this point. '
3 A At the signing of the disposition of the Q-1A, QA approver ,
4 whoever that might be, the determination for requirement of l
5 R-6A is made on the block shown on the disposition portion of l
6 the Q-1A. It says R-6A assigned to.
7 4 Right.
8 A At that point in time the QA approver, whoever that might l
9 be, originates the R-6A form by filling out the top portien.
l 10 g Was that you, the QA approver?
! 11 A In this particular case it was.
12 0 So you filled out the block on the NCI that says R-6A 13 assigned to?
! 14 A To construction.
15 g That originated the R-6A?
16 A That caused me to originate the R-6A ferm.
17 0 Okay. Now, who is responsible for the decision to 18 initiate the R-6A, to originate the R-6A?
19 A That is the QA spprover's responsibility.
20 0 So that was your decision,.your decision alone, that was 21 yours to make? .
22 A That's correct.
l 23 0 You made that, and then you originated the R-6A?
24 A I originated the R-6A by filling out the top portion of the
- 25 form.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROLINA I
1 0 Okay. And then what?
i 2 A Then that form was forwarded by construction documents' 3 control to the appropriate party for disposition.
4 0 Mr. Hollins?
5 A In this case Mr. Hollins.
6 0 Okay. And the portion that he is responsible for in the 7 procedure?
8 A He is responsible for the criterion 16, evaluation and the l
a appropriate action, if necessary, to be taken.
10 0 He fills out the whole body of the form?
11 A That's correct, sir.
12 0 And you just completed the top of the form?
13 A That's correct.
14 0 Okay. Now, does anyone have the authority at that point 15 to void the R-6A?
16 A There is no provision in'the procedure for voiding the l 17 R-6A.
l 13 0 And does that mean that no one has the authority to do 19 so?
20 A That's correct.
1 21 4 Okay. Now, will you get the R-6A back?
22 A No, sir.
0 teto will the R-6A go to af ter Mr. Hollins does what he 23 24 does?
A The R-6A, if any action is required, any corrective 25 EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROUNA
_ , - _ . . . . . _ . _ , . . _ . _ _ _ _ . . _ - _ _ _ _ _ . , . , _ _ _ . , . . _ . , , _ . _ - . , . _ . -,._,______m.. _
I action is required, it is his responsibility to evaluate such, 2 the R-6A would come back to construction and the action items 3 would be assigned to the appropriate party and those actions 4 completed. There is a final QA: review for the R-6A form.
5 That review is not to question Mr. Hollins' technical evaluation 6 but it is to see that all appropriate action -- all actions 7 assigned have been completed.
8 g And who makes that review?
9 A That is made by the QA support group on site.
10 0 And who would that be? Who would be responsible for that?
11 A someone in my organization.
12 O Nould be you?
13 A No, not necessarily. It could be myself or one of my 14 senior technicians.
15 g Well, typically would the person in QA who originated the 16 R-6 then be responsible for reviewing -- would that be consistant 17 with procedure?
18 A Procedure does not require the QA final review to be the 19 party who originated the R-6A.
m O Okay. It doesn't prohibit it?
21 A Does not prohibit it.
z! O So it would be you or someone working for you?
l 23 A That's correct.
24 0 What if Mr. Hollins or someone in construction says this i
25 is not a valid R-6A, it doesn't meet the standards specified EVELYN SERGER ASSOCIATES. STENOTYPE RdPORTING SERVICE. CMARLOTTE. NORTH CAROUNA
1 in the procedure R-6, it's not generic, we have checked it outP 2 there is no generic problem here either, in this specific 3 instance we have determined that no one has ever welded outside 4 the field weld specifications, and he wants to void the R-6A, 5 it's not a valid R-6A, what action is he supposed to take?
6 A If his determination is such that the R-6A is not needed 7 and there is a difference between voided and not needed.
8 0 Okay.
9 A He could not void it but he could state such a determination to in the criterion 16 portion and require no action.
11 0 Okay. So it would come back for the QA review stating no 12 action, right?
13 A Correct.
14 And then let's say it's your -- what if you disagree with 0
15 that conclusion?
16 A It's not my responsibility to check these technical 17 evaluations. If I disagree, I can always go back through my 18 management. That is no problem. I can ask someone else to ask I'3 him to reconsider.
20
.O Okay. And how would you do that following the procedure?
21 I could A There is no guidelines in the procedure for that.
" follow a procedure that we have in the personnel for technical 23 recourse if I wanted to go in a written fashion.
24 4 If you had a dispute as to that resolution, in would not 3 be handled through the R-6 procedure itself? You could go EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
l l .. ..
1 outside through the technical resource procedure or some other l
2 procedure, correct?
3 A. That's correct.
I 4
G Okay. Mr. Shropshire, in response to concerns expressed l 5 by welding inspectors at Catawba in late '81, '82, when the task l 6 was organized to review those concerns and a consultant was 7 retained by the company to assist in that review, Mr. Zwissler 8
interviewed you as a part of that review?
9 Yes, that's correct.
A.
19 I G Okay. I have got some notes from Mr. Zwissler's inter-l 11 view, and I believe counsel has a copy, and if they can make 12 l a copy of you those notes --
i 13 MR. GIBSON: Four pages.
14 MR. GUILD: I am going to mark these. I am not going to 15 do it now. Let's mark these as number 2.
16 (Thereupon, Shropshire deposition number 2 was received and marked 17 for identification.)
18 0 Mr. Shropshire, take a look at those notes there. The 19 first page reflects much the same discussion you and I just 20 had, your work history with Duke and professional background 21 before that, correct?
22 A. That's correct, sir.
23 G Okay. Let's look at the second page, about halfway down.
24 First, let me ask you, you were interviewed by Mr. Zwissler 25 on or about the third of February? That's the date that appears EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
4 at the top.
2 A I assume that's correct.
3 0 Okay. Under the heading "Three current prbblems," the 4
comment here " Things not always clear cut. Some procedures 5
don't cover all aspects, of problems." Does that basically 6
focus on the judgment that earlier procedures required to be-exercised by, say, welding inspectors, employment inspection?
8 l
A Yes, that's true.
8 0 " Procedures don't always get the review needed." Is that to new proceJures, when a new procedure is issued, or what did
" Do you recall?
you have in mind there?
12 A The comment was made in reference to comments on procedure 13
, revision.
14
% Okay. Some comments are missed. What comments did you 15 have in mind? Comments from whom?
16 A I don't recall, sir.
17 G Okay. It says, "Have written instruction to inspectors 18 as to how to interpret procedures." Was that a reflection that 19 there were written instructions or that there needed to be?
i 20 A Those instructions were written at the request of local 21 site inspectors for clarification of some minor points. l 1
22 '
4 Okay.
23 A And at times we would provide that information to them.
! 24 G Okay. In what form were those instructions?
25 A Those inctructions could have been taken in the form of EVELYN SERGER ASSOCIATES. STENOTYPE REPOWTING SERVM:8. CHARLOTTE. NORTM CAROUNA
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I what we had at the time of a QC, QA inquiry, which was a form 2 that wac generated by the inspector to ask for clarification on 3 a procedural or code point, and those were forwarded back to 4 him for his information.
5 O Those wara the answers from you or Mr. Morgan to a QC 6 or QA inquiry form?
7 A The appropriate technical group in QA, yes.
i l 8 G Okay. "At times judgments made by tech support are questiotted ,
9 not willing to accept resolution as is." If typically a non=
10 conforming item was initiated by an inspector and came back 11 " Resolution accept as is," would that be the situation that 12 you were relating to?
- 13 A That's what we were referring to. The question by Mr.
I 14 Zwissler was the responsibility of technical support construc-l 15 tion to respond to nonconformances, and the question asks
- 16 .do we accept those, and our answer was that we accept them with t
17 an evaluation and not necessarily as always stated.
18 0 Okay. We are now down through the middle of the third 19 page, Mr. Shropshire, "First task force was good sounding i
20 board." What did you understand by that comment? What was l 21 that question about?
22 A. I don't recall the total discussion. We were discut., sing 23 the inspector task force at the time. The first task force 24 I set up I mentioned to him I thought it was a good idea, 25 was a good place for inspectors and supervision, as well, to go EVELYN EERGE R ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
t I to and ask questions.
2 Okay.
G Now, the second task force, " Individuals are 3
tech support in past resolutions, hence may not provide new 4
independent review."
5 A There was a second task force created, and at the time that 6
task force was small in number, and the expertise to deal with 7 '
the problems were some of the same people who had responded 8
to the nonconformances. And my comment was that we should 9
expand that task force, and that was done at a later date. We 10 brought in additional people who were neutral and was not aware II of some of the nonconformances identified.
12 O Okay. The force had expansion, it was people who had been 13 involved in resolving nonconforming items?
I4 A In some cases, yes.
15 0 Some of the nonconformances that tha welding inspectors 16
'had concerns about?
I A In some cases, yes.
3 18 G Help me understand, the second force ultimately had five I9 members to it?
20 A I am not sure of the ntmbers, sir.
21
, G Who were you thinking of or referring to here when you I
had reference to individuals who had been involved in NCI 21 resolutions?
24 A The gentleman I am thin):ing of, to come to mind quickly, 25 was Rovce Williams and Larry Cocains.
EVELvN BERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CheARLOTTE. MONTH CAROUNA
I O What was Mr. Coggins' responsibility for resolution of NCI's that were in question?
3 A Mr. Coggins worked with Wayne Henry's group, and his 4
responsibility is in the area of procedures.
5 4 Had he taken part in either the QA review or review of 6
the resolution of any of the nonconforming items that were 7
in question?
8 A I am not sure if he had directly had taken part; indirectly, 9
yes.
10 0 Tell me what you mean by indirect.
11 A He may have been a consultant on questions asked concerning 12 procedures.
13 a Okay. How about Mr. Williams? What was his role?
14 A Mr. Williams had resolved some nonconformances.
15 4 He had performed?
16 A Disposition portion.
17 G Disposition. And what did Mr. Williams do at the time?
18 A Mr. Williams is a design engineer in the mechanical; engine er-19 1 ing materials group. \
\
w G Okay. Had Mr. Williams resolved as is or resolved \
~
21 acceptable as is in any instance that you can recall? '\
22 A With design justification, yes.
23 G He as an engineer reached a professional judgment this .\
i 24 '
was acceptablo as is? \
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2 O Okay. And so the second task forc subsequently was 3
expanded to include other individuals, is that right?
4 A Yes, other individuals. I am not sure of the number, 5
but others were brought in.
6 0 Do you know when those others were brought in?
7 A No, sir.
8 S' After the point where you were making the assumption? !
9 A After that point.
10 4 At the bottom there, Duke's commitment to quality, 11 under that heading, the note here is: " Tremendous pressure 12 on crafts to meet schedule. Some foremen not' knowledgeable I3 of procedures, training of craft, provides minimum acceptable I4 skill level. In haste to expedite work, occasional departure ,
15 from procedure." What.was the nature of the scheduling pressures l 16 l
.that existed at the time?
I f A Scheduling pressures are the same as it is now. We have I
our milestones to meet, and we attempt to meet those.
19 G Does a level or has the level of scheduling pressure I
20 varied over time on the project, in your opinion?
91
~
I A No, maintain About the same.
22 G Okay. And does' that term," tremendous pressure," fairly 23 reflect your opinion expressed to Mr. Zwissler?
24 A Yes.
O Some foremen not knowledaeable of crocedures. What was evetm sensen associares. stemones nepoarino senvies. cuantorra. Noarn canouma
I that reference to, Mr. Shropshire?
2 A The conversation was such that we were talking about 3
things,that generated nonconformances, and my comment was at 4
the time that I felt that there were some parts of procedures 5
that the foremen in some cases were not completely familiar 6
with.
7 0 These craft foremen you are speaking of? l 8
A Craft foremen, yes.
i 8
G In welding?
10 A I would say yes, in that particular area.
i 11 G Training of crafts provide minimum acceptable skill level?
12 A The comment there was that I did not feel that anyone was l
I3 not properly trained. They were given the minimum skills I4 required to do their job. With experience they would become 15 better.
I0
~G Okay. Loo.ing over on the next page at the same context, 17 I believe, " Duke will meet minimum quality requirements, I8 sometimes added staff does not produce expected results in I8 quality, i. e., not adequately trained personnel doing job."
I can't read that. "Not adequately trained personnel doing job ,"
- 1
~
A " Hance productivity is dcwn."
22 O "Hence productivity is down." What generally was that 23 comment?
94
~
A That is a very appropriate observation. We always meet 25 the minimum quality standards. We require at times above and EVELYN SERGER ASSOCIATES. STENOTYPE RSPoemMG Semy CE. CMARLOTTE NORTH CAROUNA
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I beyond minimums.
2 G Okay.
A And that we have brought in additional staff to hopefully 4
increase productivity to meet schedules.
O Craft?
6 A Craft personnel, to increase productivity to meet 7
schedules, but our productivity goes down because at times we 8
find that nonconformances slow us down. Due to a nonconformance, 9
this may slow us down, but with experience and with acclimation ,
10 the productivity will pick up. My comment was, that if you I
i' 11 bring in additional people, you don't necessarily notice 12 increased productivity immediately.
13 0 Okay. Let's put this in the context of the present state of 14 affairs at the plant. Is it fair to say that there is the 15 maximum number of craft on site at present, your peak number of craft presently on site?
17 A If there is a maximum number on site, I think we are at 18 peak personnel at the present time.
19 0 Yes. And what effect has the number of craft on site 20 had on levels of productivity now? -
21 A I think productivity at the present time is probably 22 as high as it has ever been. That is reflected to bringing 23 in people from McGuire who have experience.
24 0 Okay. From Cherokee as well?
25 L That's *, um eveLvm annoen assoc Ates. sismorves neront1mo senvece. cuantorra. Nowrw cAnoumA
037-1 G In your opinion, Mr. Shropshire, when on the project would 2 you have had the phenomena you described in your comments to 3 Mr. Zwissler, that is, added significant numbers of new craft 4 without seeing direct increases in productivity because of the 5 learning phenomena that you talked about? When did that ever 6 occur?
7 A Comments would have been made in reference to Duke's peak 8 construction period of time, with Cherokee, McGuire and 9
Catawba.
10 When would that have been?
G 11 A In the year maybe '80, 1980, 1981 and for what period 12 of time, '80, '81, a year's period of time.
13 What period of time would that phenomena have been most 0
14 prevalant?
15 A , The time frame, I couldn't answer that question.
16
-G Okay. Was it a week's period of time? Was it a month's j ? period of time? Was it over a period of a year? Give me some 18 ballpark' understanding of the extent of time.
l -
19 A It may have been over a period of approximately six months 20 to a year.
21 G Okay. In the '80, '81 time frame, approximately?
22 _g (The witness moved his head up and down.)
' E G Okay. Looking further on page 4, it looks like it says,
" " Objective," but I may be just guessing here, "Too many 25
. construction in QA procedures have continually upgraded" EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NOstTM CAROUNA
-,u- ,- ..
I something.
A That's " negative."
3 0 Okay, " negative." "Too many construction QA procedures 4
have continually upgraded until the procedures are becoming 5
complex." How is the term " upgraded" used there?
6 A The term " upgrade" is used there from the standpoint 7
during this period of time we were beginning to put a lot 8
of detail into procedures.
9 0 Why was that, sir?
10 A Due to a need to further clari*y or further describe 11 what was necessary to be done on site or at the job station.
12 G Reduce error through lack of procedure, lack of detail?
A No, to provide inspection personnel and construction I 14 more information with which to work with.
15 0 Reduce the need for judgment and oral instructions?
16 A Reduce the need for oral instructions, hopefully to reduce 17 the need for judgment by a supervisor, what have you, to spell l
18 l
out in the procedure.
I 19
% And what's :the point of the observation?
20 A The observation at that time was that it was a feeling 21
, that with increased information, we were getting a better job, 1
1 22 but we were causing our procedures to be lengthy and complex.
23 0 Okay. And was there a remedy for that if that was 24 identified as a problem?
25 A I think the remedy, we are working towards that means i
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CMARLOTTE. PeOFTH CAROUNA
__.. - _. - . _ . ._.__,____.-,..__..m.
- e .
I now by taking out unnecessary procedure information, 2
unnecessary procedure in procedures. I clarify that by saying 3
that we had a lot of administrative detail in procedures 4
that did not affect the quality function of that procedure at 5
ell. Mr. Henry's group now has an objective to try to clarify 6
and simplify those procedures.
7 0 Won't that result, Mr. Shropshire, in the supervision having to resort once again to oral instructions and judgment?
8 A. But that's part of supervision's responsibility.
10 0 Okay. But I thought that the upgrading of procedures II was intended to eliminate the r.aed for that in the first place?
I A. The upgrading may have attempted to do that but hindsight I3 is sometimes twenty-twenty. We realize that maybe we put too I4 much into the procedure in terms of administrative control 15 that really was the way of doing business and did not affect th<a 16 i quality inspection at all. We are interested in quality inspe ::-
tion, and there may be many ways by which you can do business 18 l on a day-to-day basis which will still get you the same result 19 from a quality standpoint.
90
~
0 Okay. So it's sort of hindsight to understanding perhaps 21 the earlier practice suited the goal better than the practica 22 of upgrading the procedure by putting too much detail on it?
23 A. In some cases it may have done that.
24 0 Okay. And the recent revised procedures, 0-1, M-4, those 25 are avamplan of mimpliflad; clav4 find penenduran?
EVELYN SERGER ASSOCIATES, STENOTYPE REPORTING SERvlCE, CMARLOTTE. NORTH CAROWNA
1 A Yes, we have clarified those some.
i 2 O Okay. And simplified them?
3 A I think so.
4 4 okay. This is sort of a cryptic comment here. It's under 5 8 there, the last statement, "I had nonquality items" --
i 6 something "are in gray areas." What was that referring to?
7 A I really don't recall what the conversation was about.
8 G Okay. Further down there on 9 then, "Do not always do 9 as much research as could be done if more time were available 10 but decisions are good." What kind of research is that?
11 A The comment was made in this context that basically the 12 decisions we make with regard to nonconformances warare talking 13 about here are sound, that we fix the problems we find, and 14 in some cases with engineering judgment and research and furthe:r is analysis, we probably would not have to do that, but we 16 choose to take the conservative approach and fix those 17 particular problems'. (
18 So with time to do more research and calculations, there G
19 would be a higher amount of accepting work as is based on the 20 engineering judgment that the work was acceptable, met standarda?
21 A In some cases that may be true.
\
22 4 Was that the gist of what you are talking about, if you had 23 more time to do research, you might be abic to eliminate the 24 need to actually do corrective work, rework?
25 A That's true. __
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE NORTH CAROUNA
1 C Mr. Shropshire, are you familiar with the provisions of 2
appendix B to 10 CFR, Part 507 .
3 A By and large, yes, I am.
4 0 okay. I want to direct your attention to criterion 16, 5
that is, corrective action. Are you familiar with that?
6 g y,,, .-
7 Q Here is tha text of it. Now, I am interested in the area 8
of - let's take welding as an example. In the area of welding ,
8 I want to understand in your judgment how, when a construction 10 deficiency is identified, let's say in the normal course of 11 a preplanned inspection, how the root cause of that deficiency 12 is first identified; and second, documented; and third, hcw 13 appropriate and effective corrective action is taken.
I4 A You are first interested in how it is identified?
15 0 With reference to criterion 16, the corrective action 16 standard, first, deficiencias in welding. How is that criterion l
17 met with respect to identifying these deficiencies and the 18 root cause of the deficiencies?
I j A And you mentioned the term "proplanned inspection"?
O Yes.
og
~
l A The deficiency, if there is a deficiency identified, in the i
I i
preplanned inspection would be identified on R-2A, which is a 1
93
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corrective action notice. The reason it is identified that way 94
~
l on a proplanned inspection is because the inspect!.on was designed l
l 25 to catch that. The inspection was designed to look for it, EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE. CHARLOTTE NORTH CAROUNA
I and if te find it during the pre >lanned inspection, our progran 2
has worked.
3 G Okay. Therefore not an NCI?
4 A Maybe not an NCI. R-2A's are always evaluated for 5
possibilities of nonconformance.
6 g But if the deficiency is found in the course of a preplanned 7
1 inspection, welding, inspecting a welding, the nonconforming 8
item procedure would not be appropriate, isn't that right?
8 A If it is a preplanned inspection, his first instructions I0 are to take care of the item under the existing procedure, if it has means for corrective action, or to write the R-2A.
I O Let's take the first half of that, take care of the item 13 under the existing procedure.
14 A Existing procedures. Some procedures we have, we will, 15 spell out methods of using process control to correct items 16
(
l that may be deemed efficient at that time.
17 l G Now, let's take that situation. A deficiency is identified 18 in the course of a preplanned inspection by a welding inspector ,
19 and it is taken care of through process control. How is the 20 '
l root cause of that deficiency identified and documented?
21 A If something occurs during the process of welding, as' e
~~
you used an example here, and it is a situation in which occurs 23 and is identified through a normal inspection, there may not 24 be a need to determine root cause but a need to fix the situati 7n 25 as it necurn; and t h a +- ran ha hanA1nA +h&_mh 4=ananea af ava6vn senosa associares. sismorvre narontino senvies. cuantorre. wontw camouma e
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1 additional process control.
2
% The N-4A?
3 A The N-4A or F-9 procedure.
4 G Now, let me construct a hypothetical, and I want you to 5
express your opinion about that, and tell me if I am suggesting 6
a fact that is not reasonable, but the welding inspector in the 7
course of preplantad inspection notes a deficiency in welding, 8
and that deficiency in welding is correctable by the craft, 8
readily correctable by the craft, and is documented only on 10 the process control, and in that I mean the welding inspector II withholds his acceptance, directs the craft to correct the 12 deficiency, the deficiency is corrected, and the weld is re-13 worked, acceptable, and it is checked and signed acceptable I4 That would be the way it would work typically, on the M-4A.
15 wouldn't it?
16 A That could happen, yes.
I7 O All right. Now, let's say, assume hypothetically that I8 the root cause'of the deficiency is inadequate welding by the 19 welder, and that the corrective action should require retraining 20 of that welder. Let's say that welder has repeatedly made the 21 same error in welding, which has repeatedly been identified i 92
~
through process control and fixed. It has always been fixed, l 23 okay, but the welder still is not doing welding properly and l
o4
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needs retraining. Now, in that hypothetical I want to under-stand how, throu(Th process control. or otherwise, is the root t EvELYN SERGEst ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE NORTH CAROLINA
I cause of that repeated deficiency identified and effective 2
corrective action taken.
3 A First,.we need to understand that the QA program has 4
worked. ;7e have identified the deficiency, and the deficiency 5
has been repaired. Then the welders who may in this case be 6
identified with more than one circumstance, that he has brought a cause for deficiency, his management should take appropriate 8
action and should have that person retrained or should have 9
him sent back to the test shack for additional welding work, 10 quality work. QA also holds the right to pull his certifications II if it's identified to QA that this particular individual is or 12 has caused several problems. We also have a surveillance I3 program that looks at process control and work in progress to I4 see that the field weld data sheets are being followed and 15 welders are welding properly and meeting procedures, and some-16 times if things are identified through the surveillance process ,
17 management is notified, and we ask them to respond to these 18 problems.
19 4 Okay. Let's go back now. The surveillance program, that 20 is an auditing function?
og
~
A Basically that's what it is, yes.
O It's selective in nature? It's random in nature?
93
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A It's both. We ask them to do specific surveillances, and 24 then they have a routine that they follow also.
25 a In it a hund-nd parnane and4*?
evatem semaan associares. svamorves aspoarino sanvice. cuantorra.wonte camouma
1 A It is not a hundred percent audit.
2 0 Give me an idea of what percentage of work is audited 3
under the surveillance program.
4 A I could not.
5 G Is it a small sample that is intended to be representative 6
but small?
7 A That's true.
8 G Okay. It's a typical audit in that sense?
9 A True.
10 0 Now, when a QC inspector identifies a recurring deficiency 11 in workmanship -- this is a hypothetical -- a welder who is 12 not doing appropriate welding, is there a documentation required 13 by procedures of that recurring deficiency?
14 i A No documentation is required other than the process I
15 f control, which covers the order.
16 0 But the process control, in this instance the M-4A, i
17 simply has an accept-reject box, and it would be consistent witti l 18 procedure for him simply -- the welding inspector to simply 19 withhold acceptance and get the rework done and then accept?
20 A That's correct.
21 G And in that instance the deficiency wouldn't be documented 22 at all?
23 A That's true.
94
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G Now, is there a documentation of the number of reworks 25 required of each welder naintained? Let's say, as I iust stated, EVELYN EERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROWNA
I the welding inspector notes the deficiency, tells the craft 2
he is not going to accept the work, the craft reworks, and 3
it is finally acceptable. Does the welder or the welder 4
supervisor document the fact that he has flunked the weld the 5
first time around?
6 A Yes, they do. It is considered a management function and 7
the welding supervision keeps track of reject rates of various 8
welding. Also welding tech support has files of reject rates 9
and nonconformances on various welders in order to identify 10 those people who may need retraining.
II G Help me to understand that part. That's what I want to 12 focus on. How would that doccmentation take place? How would I3 a welding supervision, welding craft management, document the 14 rejection of the welder's work in the hypothetical I stated?
15 A I am sorry, I do not know how they do it.
O Do they do it? l 17 I A They do do it. I have seen some wolds that are radio-18 I graphed, they do keep records on the amount of rejectable ;
length of weld per total length of weld, welding by welders.
20 G Give me that again, it's the measure --
21 A It's the percentage of rejectable length of weld compared to the total length of weld welded.
93
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G Okay. Well, in that instance we are talking about taking 24 that information off of a documented inspection, an inspection 25 1 documnnt? (
l EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTH CAROUNA
l .. ..
j 1
A That's right.
2 A radiographic record?
G 3 A That's correct, sir.
4 0 And that radiograph;would be pedigreed to the specific 5
welder that did the work?
6 A That's right.
l l 7 G So you can go back to the paperwork and find out this 8
specific measure, right, percentage of rejectable length?
9 A That's true.
10 G Take the situation where I am talking about, where it is 11 a visual inspection of welds and so you are using an M-4 process 12 control, how would --
13 A I am not aware of how they document such.
I4 0 Is it possible that there is no documentation of that?
15 A I can't answer that.
16 4 You don't know of the documentation?
I A That's right.
I8 G Well, let's focus on this other point then. You said 19 that the QA has the authority to pull the certification of 90 the welder if the welder is not doing work and require that the 21 welder be racertified, retrained. How would that be done?
02
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How would the welding inspector do that?
23 A We would remove the welder from the welders printout.
24 G okay. That's how you would pull a certification?
95
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A That's correct.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NOW CAROUNA
.- s 1
4 How would the welding inspector -- take it from the 2 point where my hypothetical leaves off.
3 A If the welder inspector has concerns about the welder's 4 ability, he expresses those through his supervision, and 5 then his supervision, if they deem those concerns to be severe, 6 they would bring those to QA's attention. They also would go 7 back through welding supervision, cra?t supervision, and point 8 those problems out to them.
9 G Okay. So the welding inspector would bring it tu -
10 attention of his supervision in QA, and then QA would bring it 11 over to craft?
12 A Yes.
13 0 Would it come through you?
14 A It may.
15 g Well, typically would it? Would you be in the chain of 16 supervision over the welding inspector, where it would come to II you?
18 A At the present time, no, i
l 19 Q Why not?
20
! A Why not? Because I am not in the line of the foreman or j 21 the welding inspectod s forer:.an's line of communication. It I
22
! would go through the technical supervisor to the QC inspection 1
23 superintendent, to the project aenior QA engineer, Mr. Davison.
24 0 Formerly, would it come thrcugh you?
25 EVELYN EERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE CHARLOTTE. NORTM CAROUNA I
l
\
l l
1 A I have been in the line, yes.
2 O When were you in that line?
3 A Several years ago.
4 Q Before the reorganization of the QC inspectors under QA7 5
A No. )
6 0 February '827 7
A During the early stages of the reorganization.
8 G February '817 9
A Whenever.
l 10 0 Okay. You got out of that chain during the early stages 11 of that reorganization, is that what you are saying?
I 12 j A No, I was in the chain during the early stages of re-
~
13 organization. The technical supervisor would have brought 14 those concerns directly to me.
15 0 Okay. Are you aware of any instances where a welding in-16 spector did this?
II A I am aware of instances in which welding inspectors pointed 18 out problems with welders, with specific welders, in which they I9 had been called back on several occasions for reinspection.
0 Yes.
2I A And at that time we pointed those out to craft management no
~~
and asked them to take a look at that particular situation to 23 see what the man's problems were.
94
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G Okay. Did you document that? Do you recall?
25 A No.
EVELYN BERGER ASSOCIATES. STENOTYPE peSPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
, _ _ , _ _ _ _ . ~ -. - - - . . --
1 S Okay. Those have been in all of the situations that would 2
have come up under the hypothetical example that I used? Would 3
all of the situations where a welding inspector identified 4 repeated problems with a specific welder have been reflected 5
in the instances that you know of?
6 A I can't answer for all of those situations. I can say 7
that we have done that on occasion, yes.
8 0 Okay. Now, what I am concerned about in this hypothetical )
9 is how, as a matter of quality assurance procedure, the 10 corrective action criterion of appendix B is complied witn, II how, as a matter of procedure, you assure that the root cause 12 of this hypothetical problem in this instance would be 13 identified and effective and appropriate action would be taken.
14 Is there anything further that you can add to what you have l I6 told me to respond to that concern? 1 I6 A Nothing further at this time.
II O Okay.
I8 (Thereupon, a short recess was taken from 9:55 to 10:10 19 a.m.) ,
20 0 Mr. Shropshire, in your opinion is trending an important 21 l device for identifying chronic or repetitive or generic problems?
oo
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A I think trending is a lot of help in doing that, yes.
23 4 In order to do that, you trend nonconforming items?
94
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A Nonconforming items are trended by Mr. Henry's group.
B Okay. Do you review the NCI trend, trend analyses?
avutvu ennoen associatus srsworype naponrino senvice. cuantorra, wonrH camouna ;
.- .. l 1
A That's really the responsibility of my management.
2 Occasionally I see those.
3 0 Would you see them in the normal course of your work?
4 A Yes.
5 0 And when would you see them or how would you use the trend 6
analyses?
7 A The trending report would be routed for review, and you 8
would look to see the types of problems that had been identified 8
so that if you saw those problems again, you would be able to 10 know that that was part of the trend.
II G Okay. And how is that report organized so that you can I
do that? How do they identify trends?
I3 A I think you need to understand how we place the trend on the NCI to begin witn.
15 g Yes.
A We trend the NCI at the time of origination, so when I see it the first time, tho trend code goes on at that time.
18 G Okay.
19 A And then, of course, the trend analysis is presented in 20 terms of those codes back in the report from Wayne Henry's 21 group.
O What are the trend codes that are used? How could you 23 code them?
24 A You code them by activity, by item affected and by 25 violation and by the rampnnalbla pm *y - T&'a a fnisr-la+*ar code.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING EInveCE, CHARLOTTE. NORTH CAROUNA
1 ThedepositionofJoeCaineShropshirewastake6nonthe 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 For Duke Power Company -
Ronald L. Gibson, Esq.
6 951 South Independence Blvd.
Charlotte, North Carolina 7
For Palmetto Alliance -
Robert Guild, Esq.
( 8 2135 1/2 Devine Street Columbia, South Carolina 29205 9
(The deposition commenced at 8:20 a.m.)
10 JOE CAINE SHROPSHIRE, 11 having been first duly sworn, was examined and deposed as 12 folio,,,
13 BY MR. GUILD:
14 i CL Mr. Shropshire, would you state your full name and your 15 business address for the record, please?
16 A My full name is Joe Caine Shropshire. My business address II is Catawba project, of course with Duke Power Company.
18 MR. GIBSON: Mr. Guilds I presume we are proceeding under 19 the same stipulations, and the persons present are Mr. Henry 20 l
and Mr. Bell with Duke Power Companyi
! 2I A
My name is Bob Guild, I am counsel for Palmetto Alliance, 22 intervenor in the Catawba operating licensing proceeding, and 23 with me is Phillip Jos and Betsy Levitas with Carolina Environ-24 mental Study Group, running the machine. As you may be aware, i
25 Palmetto Alliance has raised questions about quality assurance EVELYN SERGER ASSOCsATES, STENOTYPE REPORTING SERVICE. CHAMLOTTE. NONTH CARoundA
1 S Okay. Where does the code appear? Let me show you the Q-1A 2 and let you tell me.
3 A The trend code appears in the lower left-hand corner.
4 S Under the box that says " trend information"?
3 A Yes.
6 G Okay. And who is responsible for determining the trend 7 code and completing that portion of the NCI form?
g A T 4 individual who signs the QA review space under the 9 description of nonconformance places a trend code at that time.
10 0 Okay. Now, what's the activity? Tell me about the activity 11 code. What does that mean and what are the various codes 12 that are used?
13 A. The code is a four-letter code.
14 % " Focus on the activity. Activity item affected violation 15 and responsible party."
16 A The activity would be what was going on at that time.
17 Were you welding pipe, valve, electrical, civil, concrete, so is forth.
19 G Give me the choices. What are the choices under activity?
20 A Sir, I can't, without seeing the sheet, I can't give all 21 those to you.
22 G Then give me the examples that occur to you.
23 A The examples I think of as far as activity is pipe, valve, 24 equipment, welding, hangers and so forth.
25 G All right. And is there a letter or number assigned for EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
I sach activity?
2 A There is a letter assigned.
3 A through something?
S ,
4 A c.
5 g Okay. And for welding?
6 g g, 7 D would be welding, W7 0
8 A Yes.
9 G Okay. Then the item affected?
10 A The sequence is as follows, for the four-letter code.
11 The first letter is the agency or the organization identified, 12 be it canstruction, QA, nuclear production, whoever.
13 g That's the responsible party?
14 A Responsible party. That's the first letter.
15 g Okay. The responsible party is the party that is responsible 16 for corrective action or for the nonconformance?
17 A Nonconformance.
18 I am being facetious, G The guilty party, so to speak.
19
, but the organization to whom responsibility is attributed for 20 having committed the deficiency.
21 A That's correct.
22 0 Give me the choices there.
23 A Hem again, I can give you only examplas. Examples would 24 bo QA, construction, design. Those are three examples.
25 0 And there are others?
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SEPv'CE. CH4RLOTTE. NORTH CAROUNA
1 A Yes.
2 g okay.
3 A The second letter is the activity or the time frame in which 4
it occurred, fabrication, erection, installation, storage.
5 g rabrication, erection, installation?
6 A Storage.
O Okay.
8 A Et cetera.
9 0 And the others?
10 A y,,,
II O Let me interrupt back for one second. The agency -- what 12 is the designation for QA, if you know?
I3 A Q.
14 0 Q. And how about for construction?
15 A g, !
16 0 And design?
A D.
18 0 Okay. No% for activity - I am sorry, what did you call '
I*
the second? What is the second item in the code? I 20 A The second would have been the time frame or I use the 21 term " activity" at which this item could have occurred, such as installation, erection, fabrication, storage, so forth.
23 g Is that referred to as a time frame, activity?
24 A Well, it's really the activity that was going at the time, fabrication of the i& men ; fne i n m& a n t'a :
EVELYN BERGER ASSOCIATES STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
I And do you know any of the codes -
O Okay, I have got you.
2 what's fabrication?
A I think that's an F code. Erection is E, and likewise.
4 4 Installation, I?
5 A I don't recall right offhand.
6 4 What would it be for a weld?
A Now, that you could have welding during the fabrication 8
process so that comes in a later stage of the game. You are 8
at the second digit. The third digit is the violation, what I
was violated.
S Uh-huh.
12 A And those descriptions are specifications, work not in 13 accordance with procedure, work not in accordance with drawing, 14 i
field weld data sheet violation, and so forth. That's your third letter.
l 1G G Okay. And what are the choices there?
17 A Numerous.
18
% Okay. What's a specification?
19 A I don't remember the chart right offhand.
20 g Okay.
l A And then the fourth is the item that was effective on 22 the activity, such as welding, pipe, equipment, so forth.
23 l
g Are those letter codes as well?
24 A Yes.
i 25 (1 walaing, w?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA i
1 A Yes. Pipe, P; equipment, E.
2 O Okay. So if you were or someone in your organization who 3 was performing the QA review, you at some point wonld assign 4 this code to the NCI?
5 A That's correct, sir.
6 O And then when would you see the results of the analysis, 7 the trend analysis?
8 A When Mr. Henry does his trend analysis, 9 G And it is circulated to you in the course of distribution?
10 A That's right, it's routed.
11 0 Okay. And how often are those trend analyses routed to 12 you?
13 A They are being done once per month.
14 G Okay. Have they always been done once per month?
15 A Not always once per month.
16 4 Were they more or less frequent in the past?
17 A Yes, they have been done on a quarterly basis, and most 18 recently once per month.
19 0 When did they begin once per month?
20 A I don't recall.
l 21 g 3.long time ago?
22 A Within the last year, year and a half.
23 4 Okay. And from the beginning of the project until that 24 point, quarterly?
25 A I really can't answer that from the beginning of the proje :t.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE. CHARLOTTE. NORTM CAROUNA m ., .- , - - ~ . , - - - - - , _ , . _ - - - - . - - - - - - . - - - _ . . . . , . . . - . , - - - - - - - - - . . . . _ - - - --. - - - - .
1 Before that time it was quarterly. What period of time, I am 2 not sure.
3 g Do you recall it being more than quarterly before that?
4 A No, I don't.
5 0 What is the format-of the trend analysis?
6 A Would you explain the question?
7 O Sure. How is the report organized that you see?
8 A The report I see is in a letter form.
9 I am sorry?
5 10 A. Letter form with the codes, designated codes and the number 11 of occurrences.
12 It's a narrative description?
O 13 A Basically, yes.
14 It's an analysis of the trends?
0 15 A Yes.
16 4 By Whom?
17 A By QA technical services.
18 Who is the author of the report? Who writes the report?
G 19 A. W. O. Henry signs the letter. I assume someone works 20 for him.
21 Is there a data attached to it, a chart, graph, compila-0 22 tion of the trend?
23 3, y,,,
24 0 okay. What. format is that in?
25 It's both in numerical data and has been in graph' cal forrr .
A EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE CHARLOTTE. NORTM CAROUNA
1 Q Okay. The numerical data is just a tabulation of the 2 numbers in each of these categories, is that right?
3 A That's correct.
4 0 For the current period?
5 A I don't recall whether it was for the current period.
6 G And the graph, what is the graph of?
'7 A In the past Wayne has used a paragraph.
8 G Number of NCI's in a particular area or total?
9 A In a particular area.
10 0 Okay. Compared over time?
11 A Yes.
12 0 And is that the format that is being used now?
13 A I think so.
14 G Okay. Is any other information in the trend analysis?
15 A I think you have it.
16 0 Okay. In the narrative, what kind of analysis is reflected 17 there?
18 A Generally the narrative, if there are any trends that 19 appear, these are described, and there may be at times response s 20 requested to such trends.
21 O Responses from the responsible organization?
l J
22 A Responsible party.
l l 23 G Okay. Have you been responsible? Has QA been the 24 responsible party for responding?
l l 25 A Not that I am aware of, sir.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
I G Okay. Now, are trend analyses performed with respect 2
to any other procedure for identifying construction deficiencies?
3 A Trend analyses are required by the R-2 procedure.
4 G Okay. How long has that been required?
5 A Probably within the last six to eight months, procedure 6
required that is. l G And before that?
8 A QA has always, since I have been associated with QA, five 9
years now, has always had procedure 304, which directs and calls 10 for trend analyses at the direction of tice appropriate party.
11 G And with respect to R-2A's, has QA trended R-2A's all 12 along?
13 A We have trended R-2A's, yes.
14 0 Who has done that?
! 15 l
A Before Mr. Henry, or before the last procedure revision, 16 which construction now trends them, QA has done that at the 17 Site.
18~
G And who would the responsibile party have been?
19 A R. A. Morgan.
20 4 At the site?
21 A That's correct.
G And what kind of format were those analyses performed?
( 23 A
In the format required by procedure 304, which is basically
, 24 l a blank sheet tabulation-type form.
25 l a unm% T. nr n_n e , <- 3 particular 3re37 EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. PeORTH CAROWNA
I A R-2A's identified by particular areas and numbers generated.
2 G Are the R-2A's coded in a manner comparable to the NCI's?
3 A They are now, sir.
4 4 Since the procedure change 87 5
A Yes, sinco procedure change.
6 G And same format?
' 7 A Basically the same format. Construction has their own 8
procedure for doing this, but it is modeled after the QA format .
9 4 What is the construction procedure for trending?
10 A I am sorry, sir, I can't tell you that.
I 4 How about before constr ction took over trending R-2A's, I
was there a coding by QA7 I3 A The trending was done not by coding but by actually reading I4 and reviewing R-2A's and then sorting out of problems.
1 I
G Okay. And was there a report of the trend analysis R-2A's 16 made by QA?
17 A Yes.
18 G And ho'1 often was that made?
I A It was made whenever the trend was conducted.
20 0 Was that on a regular basis?
21 A Not on a regular basis.
~~
l 0 What range of time? Once a month, once a year?
23 A Done more often than once a year. I can't say it was 24 once a month.
25 0 Quarterly?
EVELYN SERGER ASSOCIATES, STENOTYPE REPOfrTING SERVICE. CHARLOTTE. NORTM CAROUNA 8
1 A Trends were generally conducted daring that period of 2 time on a need basis.
3 0 And what would represent the need?
4 A The necessity to do a trend analysis would be generated 5 by the number of R-2A's seen in a particular area or a need to 6 look at how a particular program was going in a particular 7 area, a matter of doing surveillance.
8 G Okay. And are those reports still available?
9 A Those trend reports should be in the file.
10 0 Mr. Morgan's file?
11 A In the QA vault file, 12 G At the site?
13 A Yes.
14 g Were those trend reports circulated beyond QA at the site, 15 the R-QA trend analyses?
16 A I think they were.
17 0 Were they distributed to Mr. Henry?
18 A They were basically distributed to the responsible party.
19 If it was construction, it went to construction. It may have 20 gone to Mr. Henry but I am not sure of that.
I 21 O Okay. Were those anaylses distributed to the NRC?
22 A No, not that I am aware of.
23 O Okay. Were them any other procedures for identifying de-24 ficiencies that were trended, to your knowledge?
25 A I am sure there were other procedures that were trended, EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA
.. s 1 and they would have been trended under the trending program, 2 the QA 304. To identify such, I really can't.
3 g Tell me what could have been or likely was, if you are not 4 sure --
5 A Okay. For trending purposes I have seen trends in the past 6 done on process control. I have seen trends in the past done on 7 R-2A's. Of course we have done trends on NCI's.
8 0 Okay.
9 A There have been trends done on variation notices.
to G What's a variation notice?
11 A It's under procedure R-3, which is a design variation.
12 S Explain that to me. What does that mean ?
13 A Okay. If identified that there is a mistake on a drawing ,
14 which needs to be clarified or additional information placed 15 on a drawing, then construction, the party who identifes that is item, will contact design, and they concur that the change needs 17 to be made, and they write an R-3A, which is a variation to 18 , a design document. It could be a drawirg or a specification.
19 And then it goes through the approval route of the appropriate 20 Parties.
21 0 What if an item is erected improperly but accepted by 22 engineering as meeting design standards, would the R-3 reflect 23 a design variation?
24 A It could possibly reflect that.
25 g Okay. Hypothetically let's say a hanger is placed improperly, EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERWCE. CHARLOTTE. NORTH CAROUNA
I the wrong place, several inches away from where it should be, 2 and it doesn't -- it's not properly reflected in the drawing, 3 the drawing is going'to be changed to reflect the actual i
4 as built installation, would an R-3 be the appropriate document l
5 for documenting the design variation?
6 A Yes.
I 7 0 Okay. How about, another hypothetical, a seismic 8 restraint installed backwards, it's in place, a design review 9 takes place, determines that it's proper, it's acceptable, 10 it can go backwards, would~the R-3 be used to document the i
11 design variation?
12 A It may happen that way but an R-3A will result in a design 13 drawing revision.
14 O Right, to reflect the appropriateness that it was installed 15 as built?
16 A Correct.
17 0 If a nonconforming item were documented reflecting a is deficiency and the deficiency required a design variation, 19 would the R-3 procedure also be used to document that design 20 variation?
21 A No.
22 O No?
23 A If you have a nonconforming item.
24 0 Yes.
25 A The answer is no.
t EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE CMARLOTTE. NORTH CAROLINA
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'*e s a 1 g^ Why is that? Why not?
A i ,12 A' Because you have reached the inspection stage. Variation
, \
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. notices apply prior to the inspection stage.
, g ', 3 4 g They are instituted by construction, by craft?
^
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'That's correct, sir. CA does not institute variation
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t li th, Okay. Now, I was asking you to identify other deficiency
- }[d . .Q- i documents that are trended. Anything else that you knew of?
s , ,
e 1 5 A That's all I can recall.
j , f , 19 , j g Now, in the area of process control, what process control r {
' I have you seen trended?
// 1: '.
.' l q 11 '4 A, ,
we have trended process control, of course, in the welding I
That's one I can think of.
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g 11 n What was trended then, what process control was trended?
j' ;
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15 ., The types of errors that show up in the process control.
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- 16 O And what would tne document be that was the source?
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'a Where did you get the information that was the basis for
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?
19 'tne trend?
N,, ' ;20 A During our file review process.
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, i ' 21 4, Okay. Using the example of the M-4, what information did
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il j ( , 22 you take off of the M-4 that would be used to trend?
23 A We do a complete file review on all M-4A's. We do both 26 a logic check for the sequence of events. We check the 25 technical adequacy of the M-4A. We check the entries by the
+ EVELYN BERGER ASSOCIATES. STENCTYPE REPORTING SERysCE. CHARLOTTE. NORTM CAROUNA
\
t ,_.
I appropriate parties, craft, et cetera, and at the final review 2
stage we do find some errors, and we trend those errors to see 3
what types of errors have~ occurred and if there is a problem 4
that we can solve.
5 There is an error in completion of the M-4A form?
O 6 A It could be an error in entering a simple thing as a 7 date, writing down 12-7-82 instead of 7-12-82.
8 How about errors in workmanship?
G 9 A On the M-4A?
10 C Yes. Would you trend those?
11 A The M-4A itself, errors in workmanship would not lend 12 itself to that type of trending.
13 0 Okay. There is not enough information on the form.
14 A That's true.
15 g so you are trending the effectiveness of the use of the i
4 16 process control document?
17 A That's correct.
18 % How well it is completed?
- 19. A That's correct, sir.
20 0 And not trending the workmanship deficiency that the M-4A 21 was used for?
22 A That's correct, sir.
23 0 And the same thing is true of the F-97 24 A That's right.
25 0 Now, how long has QA performed a review of the M-4A and EVELYN EERGER ASSOCIATES. STENOfrPE REPORTING SERvtCE. CHARLOTTE. NORTH CAROUNA
l 1 F-97 2 A Since its inception, I guess.
3 0 Okay. Now, Mr. Shropshire, you are aware that in late '81 4 and '82, a number of welding inspectors expressed what have been 5 characterized as technical and nontechnical concerns at 6 Catawba?
7 A Yes, sir.
8 0 Okay. Now, did you observe that those concerns came from 9 one crew of welding inspectors more than another crew, than to other crews?
11 A Sir, I am not able to make that observation. I did not 12 have access to those, the total amount of concerns expressed.
13 0 Well, do you have an understanding of generally that 14 those concerns came from one crew more than another crew?
15 I am trying to gather really your judgment about, on the basis 16 of your involvement in performing QA reviews of work in welding ,
17 would you accept the characterization that most of those concerns 18 came from Beau.Ross's crew?
19 A I don't believe I could do that.
20 0 You don't know?
21 A I just really don't have a feel for the total number of 22 concerns.
23 g Okay. What I am interested in your opinion on is whether 24 or not the concerns expressed by the welding inspectors, 25 in any particular format, the specific handwritten concerns --
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
1 I am not referring to a particular set of documents but the 2 general concerns about lack of management support, disputes as 3 to resolution of nonconforming items, accept approval of work 4 that in the judgment of the welding inspectcrs did not meet 5 procedures, and concerns about the reclassification of the welder 6 inspection position, in your judgment were those concerns held 7 generally among the welding inspectors or did they come only 8 from a limited number, say, Mr. Ross's crew?
9 A I car.'t say that they came frcm a limited number. I know to that there were some people who voiccd their opinion more than 11 others. ,
12 g Okay. Is it your view that the opinions, as I kind of 13 characterize them, were general amongst the welding inspectors, 14 whether they were voiced or not, were they generally-held opinions?
15 L I really can't answer that. I just don't know.
16 4 Okay. Can we agree that you would have understood that the 17 voicing of those opinions by welding inspectors was concentrated is in welding inspectors who were in Mr. Ross's crew?
19 A I can make this observation. Several of the welding 20 inspectors who dLd voice their opinions were from Mr. Ross's 21 crew. Whether they were the total number who did, I can't say.
22 O All right. I am going to show you an index, so to speak.
23 It's transcribed from an index that was provided by the company 24 to me in discovery, and the title from the company was as 25 follows: " Handwritten notes from QC and CA inspectors which EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVtCE. CHARLOTTE. NORTH CAROWNA
I set forth their specific problems and concerns."
2 There is a list of named persons A through T, and some of 3 the names are misspelled, I should note. If you know who they 4 refer to, I think you will understand. Looking at that list, 5 I will represent to you that those are the lists of persons 6 who submitted written concerns in January of 1982. Those are 7 not all of the concerns that were expressed. There are other 8 documents as well, but that is one collection of them. Can you 9 identify those individuals? First, you recognize the names -
10 generally that you see in front of you?
11 A Yes, I do.
12 0 And they are generally welding inspectors at Catawba?
13 A That's true.
14 g A couple of supervisors?
15 A Yes.
16 g And Mr. Deaton is down there?
17 A Yes.
18 0 He is a supervisor?
19 A That's correct.
20 0 And Mr. Ross is down there, he is a supervisor?
21 A That's correct.
22 O And the rest are welding inspectors?
23 A Yes.
24 4 okay. Can you tell me, of the welding inspectors, can 25 you tell me what crew the welding inspectors are on?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROLINA
1 A No, sir, I can't.
2 g You just don't know?
3 A I recognize some names and others I don't know which 4 supervisor they are assigned to or were assigned to at that 5 time.
6 O Let's look at the list here and tell me which ones you rec ag-7 nize and ot.hers 'you don't recognize. Dean Bentley. Do you know 8 Mr. Bentley?
9 A Yes, I do.
10 0 What crew is he frem?
11 A I am not sure.
12 g How about T'. A. Gardner, Bumgarner?
13 A Yes, I believe he worked for teatonet the time.
14 G Okay. Mr. Burr?
15 A Bill Burr?
16 g Yes.
17 A I think he was assigned to Deaton at the time.
18 G Boyce Coffin?
19 A I am not sure who Heavy worked for.
m C Heavy?
21 A Right, about 5 foot 4 and 135 pounds at best.
22 G Crisp, Mr. Crisp?
23 A Charlie Crisp, I am not sure who he works for, sir.
24 G Mr. Deaton we have talked about?
25 A Yes.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTN CAROLINA
l 1
1 Q Mr. Deaton was a technician, supervisor technician? '
I 2 g y,,,
1 3
0 Is a supervisor technician?
1 4
A He is currently a supervisor, and he was at that time. j 5 g Harold Eubanks? l 6
A I don't know who Harold worked for even. ,
I 7 A. S. Gantt?
O i
8 L Scott Gantt, no, sir.
9 0 Okay. V. C. Godfrey?
10 A Vern Godfrey, probably Ross at the time.
11 0 Okay. Mr. Godfrey is not an inspector any more, is that l
12 right?
l 13 A That's correct, sir.
14 % He is a welder?
15 A That's right.
16 0 Larry Jackson?
17 A I believe he worked for Beau Ross.
18 0 Okay. Richard Jones?
19 A I am not sure, sir.
20 g Ken Carriker?
21 A Buddy Carriker, possibly Bill Deaton.
22 O Okay., Ronald Kirkland?
23 A I am not sure.
24 O John McCoy?
25 A John McCoy, I,am not sure.
EVELYN SEPOER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
_ _ . , _ _ _ _ . . .~__._,r - -._--
. .m . _ _ .
1 Q John RockholtV 2 A He worked for; Dr+.u Ross.
3 g Ransome Sims?
l 4 A I am sorry.
5 g Mickey Stanridge?
l 6 A Bill Deaton, I believe.
7 g Does he have a brother on the job?
8 A I don't know whether Jerry is his brother or not. I am j 9 not sure.
10 0 Is there a Jerry?
11 A There is a Jerry Stanridge, yes.
12 0 Is he a welding inspector as well?
13 A I think so.
14 % Do you know whose crew he is on?
15 A No, sir.
16 g Lindsay I think it is Harris?
17 A Lindsay Harris, that's correct. At that time I am not sure 18 who Lindsay worked for.
19 0 Okay. And John Bryant?
20 A He worked for Beau Ross.
21 O Okay. At the time Mr. Ross and Mr. Deaton were both 22 supervisors, what other supervisors were ovt welding inspectors?
i 23 A They were the only two supervisors at the time. Their 24 technical supervisor at the time, I believe, was Charles 25 Baldwin. ;
EVELYN B&MGER ASSOctATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
1 g Deaton and Ross were the only two first-level supervisors 2 at the time?
3 A That's correct.
4 0 Mr. Shropshire, what is your opinion about the reclassific a-5 tion of welding inspector position?
6 A If I gave you an opinion, it would be just that. You can 7 have an opinion on any subject.
8 g Yes, sir. I am interested . yours.
9 A I would have to say that I am really not aware, enough 10 aware of the evaluation that was made on the salary and pay 11 scale at the time. For that reason I am not in a position to 12 second guess what management did.
13 0 I understand it's a decision made -- essentially something 14 you have to take as a decision of management. What I am 15 interested in, I guess, is the substance of the -- your opinion is as of the substance of the decision that was made. Do you 17 agree with the evaluation, the qualification of welding 18 inspector was reduced?
19 A The qualification of welding inspectom were not reduced 20 at all.
21 g Okay. Do you agree that the requirement for prior craft 22 experience as a welder was eliminated?
23 A I can't answer that.
24 0 You just don't know?
3 A I don't know.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CARQUNA
I G You do know that subsequently persons have been trained, 2
of course, and certified in testing and worked as welding inspectors who formerly had no welding experience?
4 A That is true.
5 g And before the reclassification, all welding inspectors 6
had welding experience?
l 7 That's not true, l l A 8
g All right, sir. That's what I want to understand the 9
exceptions to. There were exceptions to persons who did not 10 have welding experience who did welding inspection?
11 A There~were people, certified inspectors at that time, who 12 had not been welders before.
I 13 g There were a few of those, many? l 14 At the time I would say there were a few of those.
A 15 g Would you agree that the vast majority of welding 16 inspectors had previous experience as welders? This was the 17 rule?
18 A I think that is a general statement.
19 0 Okay. And who would have been an exception? Can you 20 name -- at the time now, before the reclassification.
l 21 A I can't name names. I know of situations that do not t
l 22 involve parties.
23 g Describe the situation, if you can, if that will help i
24 me understand what the exception rather than the rule would 25 represent.
l iv u~ ...... ...ociar... m uom. .rino . avice. c~ =om. ~enr~ canou~.
1 A We had hired during a period of expansion, we had hired people 2 to become welding inspectors who had not had welding experience 3 and' were trained.
4 At Catarba?
R 5 A I don't believe that occurred at Catawba. I think it 6 occurred at Cherokee.
7 O Okay. Are we communicating correctly, at the Catawba 8 now, focusing at Catawba, including the reclassification, 9 all welding inspectors had prior experience as welders, is that 10 true?
11 A I can't say that. I don't know.
12 g Are you aware of anyone who worked as a welding inspector 13 at Catawba prior to reclassification who had not worked as a 14 welder?
15 A I am not aware of anyone.
16 0 Your knowledge of that exception is really at Cherokee?
17 A That's true.
18 0 Okay. And after the reclassification at Catawba, persons 19 who had not previously worked as welders have been certified i
20 and are now serving.as welding inspectors?
21 A That may be true.
22 O Well, for example, persons who are now working as welding 23 inspectors who previously worked in the NDE area, is that
,. 24 true?
25 A That's true.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAROUMA
w g I And they have been trained to certify as visual inspection G
2 of welds?
3 A That's correct, also people who have transferred from Cherokee 4
are currently employed at Catawba.
5 O Persons who fit the category of the exception, they were a<:
6 Cherokee, they had been trained and certified at Cherokee, 7
and they hadn't prior work experience as welding craft, they 8 have transferred to Catawba?
9 A That's true.
10 Now, I want to focus on that one aspect of it. Can we agree 0
11 that -- we can agree that the pay grade of welding inspector 12 has been. reduced as a result of reclassification?
13 A No.
14 Well, the entry-level pay classification for welding 0
15 inspector is lower than it was before, isn't that right?
16 A I assume so. Again I am not -- I would only in passing --
17 I don't deal with those salaries. That's not my responsibility ,
18 If I remember correctly, the entry may be lower than what it 19 was at that time.
20 g Okay. And the top level for a welding inspector is lower 21 than it was at that time, presently?
22 A That would be true.
23 0 Okay. You pay a starting welding inspector, inflation 24 held equal and all of the rest, generally increases held equal, s less today c.than you did before, because the position -- the EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROWNA
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I pay grade is lower than it was before?
2 A Would you clarify that as being a starting?
3 0 Yes, starting.
4 A Less than prior to?
5 g The reclassification.
6 A Yes, that would be true.
7 Q And that is in part because you are not requiring as a 8 qualification that they have prior welding experience, and you 9 are not paying a premium for that experience, it's no longer 10 required?
11 A I can't answer that question.
12 0 Okay. Well, what I want to understand is whether or not - -
13 I want your opinion actually on the question whether or not 14 on the propriety and effectiveness of having eliminated the 15 requirement to have prior welding experience for welding in-16 spectors.
17 A Restate your question.
18 G I want your opinion on the propriety and effectiveness 19 of having eliminated the requirement to have prior welding 20 experience.
21 A I do not believe that our welding inspection program has 22 decreased in its quality at all. Even if that eliminated --
23 I am not sure that that has been eliminated, I don't have that 24 information at hand -- I think we have the same quality, if s not a better quality, welding inspection program than we did EVELYN EEftGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CARouMA
j
- a 1
previously.
2 g Because of that factor? You think the welding program 3 has improved because you reduced the prior craft experience 4 requirement'of welding inspectors?
5 A I think our standards for the ability for a person to 6 become a welding inspector and to inspect welds have not 7 changed either before or after the change in pay grade. Our 8 qualification program is the same.
9 0 okay. Is it your opinion that there has been no effect 10 whatsoever on the abilities of welding inspector from the change i
11 in qualifications?
12 A It is my opinion that they are the same quality that they 13 were before and are now due to our certification program.
14 S And that the certification and qualification, training and 15 certification, replaces any prior -- any qualifications that 16 flow from prior welding experience?
i 17 A I think it does, sir.
18 0 Okay. Do you agree that having experience as a welder 19 contributes to the ability to be a competent inspector, welding 20 inspector?
21 A I think that that would help.
22 g Do you agree that all other things held equal, a welding 23 inspector who has prior experience as a welder is more qualifie d 24 than one who doesn't?
a o A No, sir.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE. CHARLOTTE. NORTH CAROWNA
1 0 Why not?
2 A I think that there are ways to gain experience, and it 3 doesn't have to be by burning rods.
4 0 How?. .
5 A By on-the-job training, by being trained carefully by 6 qualified people, by being made aware of the welding processes ,
7 and then by being put on the job-with senior inspectors to 8 see wl.at is going on, and that is our practice, close 9 observation by-their supervision, to determine if they are 10 ready to be inspectors.
11 0 Mr. Shropshire, if the choice were yours to make, would ye a 12 have changed the classification of welding inspector?
13 A I am not qualified to answer that, sir.
l 14 0 You just don't know?
15 A Well, I just don't know the information that went into 16 making that decision.
17 g All right. If the choice were yours to make, Mr. Shropshire, 18 would you have changed the qualification of welding inspector?
19 A I would not have changed the qualification of welding 20 inspectors.
21 0 hty not?
22 A I would have seen no reason to change the qualification 23 of welding inspectors. I think we are confusing economics with 24 qualifications.
25 g Well, help me to understand. I want to be clear.
EVELYN SERGER ASSOCIATES. STSNOTYPS RSPORTih3 SERVICE. CHARLOTTE. NORTH CAROUNA
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i 1
A Qualifications do not improve with dollars. A person 2 is no more qualified -- if they are being properly trained, 3 properly certified and have the ability, they are no more 4 qualified. You can pay them $10 an hour versus $15 an hour.
5 You do not buy integrity and qualifications.
6 Okay. Would you, if it were your decision to make, G
7 choose to employ experienced welders as welding inspectors, 8 other things equal, over persons who had no welding experience?
9 A I think the experience of being a welder would be a 10 consideration that, yes, you would make. I think the individual's 11 ability is also a consideration that you would take too, and 12 ability to learn what the inspector needs to know.
13 g Okay. Do you believe, Mr. Shropshire, that there have 14 been significant improvements in the nonvisual inspection 15 techniques?
16 A Would you please clarify that?
17 g Sure. The NDE techniques. Do you believe there have 18 been significant improvements in NDE inspection techniques?
19 A That is a subject that is debatable. I think that NDE,
(
20 because of code requirements becoming more stringent, and 21 they have, I think that our techniques of performing inspection s 22 are as capable now as they have been. I think that the criteri a 23 that we use in performing those inspections have changed.
24 G How have they changed?
25 A The code actually placed,due to code additions, have EVELYN SERGER ASSOCIATES. STENOTYPE REPONTING SENICE. CHARLOTTE. NONTH CAROUNA
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~ ..
I placed more stringent criteria in the past years.
2 G Less stringent now and more stringent -- I am sorry.
3 A The things we inspect today are possibly more stringent 4 than they were in the pcst.
5 G More stringent today than in the past?
6 A Yes.
7 G How does that relate to the improvement or change or lack 8 of improvement in the NDE techniquas?
9 A The techniques that we use to find indications and to 10 evaluate criteria are basically the same as they were four, five, 11 six years ago. The equipment is basically the same as it was 12 then. The code has placed more criteria for inspection on the 13 inspector. Therefore, he may identify things today that may 14 or may not be acceptable per today's criteria. The criteria may is not have existed at that period of time or it may have been is slightly different than it is today. A code is a living 17 document. It changes.
18 G Now, these code criteria, we are talking about criteria 19 that are employed in NDE inspection techniques?
20 A Yes.
21 Q Okay. Mr. Shropshire, in your opinion, can NDE techniques 22 substitute for visual inspection of welds?
23 A NDE techniques and visual inspection techniques are ,
24 complementary. As a matter of fact, the code says it. '
25 G Does that exclude replacing visual with NDE? That's what EVELYM BERGER ASSOCIATES. STENOT' E REPORTING SERvtCE CHARLOTTE. NORTH CAROUNA
1 I don't understand, I guess.
2 A How do you mean, sir?
3 0 Can you replace visual inspection by use of NDE techniques?
4 A In some instances you can due to not being accessible.
5 Visual inspections are those things that are accessible 6 NDE techniques may detect something below or on the surface.
7 In that case, NDE stands on its own.
the surface.
8 g Okay. So you can't perform a visual if you can't 9 see it?
I 10 A That's correct. l I
11 4 And so the only thing you have available to check is an NDE i l
12 technique, and you use it?
l 13 A That's correct, sir.
14 0 ' Where you can perform a visual and an NDE -- it is !
l 15 appropriate in your judgment to replace a visual inspection 16 with NDE technique?
17 A Define as possible conflict.
18 0 Not even necessarily that. In your judgment, can you j 19 get the same effectiveness in inspection by replacing 20 visual with an NDE technique?
l 21 A Indications which may be volumetric in nature, then the 22 NDE inspection is definitely the governing inqpection. A 23 visual inspection will not be able to see that. tide is a very 24 fine method for supplerenting visual inspection for in the 25 case where an inspector may see something, he thinks he sees EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CMARLOTTE. NOWTH CAROLINA
I something, he has questkxs about it, he can call for an NDE 2
inspection, and in that case the visual is the acceptance 3
method. The NDE is the supplement to that acceptance. But 4
the person making the visual calls is the person who makes 5
the acceptance or rejection.
6 g And is that the appropriate way to achieve inspections, 7
in your opinion?
8 A Yes, I think so.
9 Would it be appropriate and effective in your opinion to 0
10 replace entirely a visual inspection by an NDE technique?
11 A Entirely a visual?
12 O Yes.
13 A I do not think that would be appropriate. I think that 14 they both would be complementary. I think that if we found 15 something rejectable by one method or the other, it should be 16 repaired, if it is rejected.
17 MR. GUILD: Thank you, Mr. Shropshire, I appreciate your 18 coming up.
19 BY MR. GIBSON:
20 0 I have two questions. One, Mr. Shropshire, Mr. Guild 21 asked you some questions earlier about scheduling pressure and 22 milestone dates. In your opinion is quality or has quality 23 been compromised any time because of these pressures to meet -
24 these milestone dates?
5 A The answer to that is definitely no. QA is always accusect EVELYN BERGER ASSOCIATES. STENOTYPE REPOfrTING SERVICE. CHARLOTTE. NORTM CARouMA
1 of holding up schedule, and I guess it is because we are doing 2 the job.
3 0 And, finally, are you aware of anything that would cause 4 you to question whether the Catawba Nuclear Station is safely 5 built? ,
1 6 A No, sir.
7 MR. GIBSON: Anything further, Mr. Guild? l 8 MR. GUILD: Not at this time.
9 (Thereupon, the deposition was concluded at 11:06 a.m.)
10 11 12 13 14 15 I
l 16 17 18 19 20 21 22 l
r i
23 24 25 l
EVELYN SERGER ASSOCIATES STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTH CAROUNA L
1 l
I I, JOE CAINE SHROPSHIRE, hereby certify that I have read 2
and understand the foregoing transcript and believe it to be 3
a true, accurate and complete transcript of my testimony.
4 JOE CAINE SHROPSHIRE 5
This deposition was signed in my presence by Joe Caine Shropshire on the day of __
1983.
8 NOTARY PUBLIC 9
10 CERTIFICATE 11 I, Ann P. Harris, court reporter and notary public, do 12 hereby certify that the foregoing 83 pages are a true, 13 accurate and complete transcript of the proceedings during the 14 deposition of Joe Caine Shropshire; that Mr. Shropshire was 15 duly sworn prior to the taking of his deposition, and that the 16 parties were present as stated.
17 I also certify that I am not of counsel for nor in the 18 employment of any of the parties, and that I am not interested, 19 either directly or indirectly, in the outcome of the lawsuit.
20 This ll-/ day of July 1983.
21 b[M ANN P. HARRIS-NOTARY PUBLIC 22 State of North Carolina County of Mecklenburg.
23 My commission expires:
24 June 30, 1986 25 EVELYN EERGER ASSOCIATES. STENOTYPE REPORTING SERVICF, CHARLOTTE. NORTM CAROUNA
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