ML20082C124

Transcript of Lr Davison Deposition in Charlotte,Nc Re Contention 6 on Qa.Pp 1-14

ML20082C124
Person / Time
Site:	Catawba
Issue date:	06/30/1983
From:	Davison L DUKE POWER CO.
To:
Shared Package
ML20082C119	List: ML20082C124 ML20082C127 ML20082C134 ML20082C139 ML20082C142 ML20082C147 ML20082C154 ML20082C163 ML20082C166
References
FOIA-83-434 NUDOCS 8311210470
Download: ML20082C124 (14)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COtD11SSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: ) Docket Nos.

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DUKE POWER COMPANY, et al ) 50-413 (Catawba Nuclear Station ) 50-414 Units 1 & 2) )

cC?Y I, Barbara V. Haas, Commissioner and Notary Pu blic, proceeded to take the deposition of Larry R. Davison on the thirtieth day of June, 1983, beginning at 4:45 o' clock p.m.

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in the offices of Duke Power Company, South Church Street, Charlotte, North Carolina.

DEPOSITION OF LARRY R. DAVISON 44oi Colwick Rd ASSOCidtCC p.o. Box uoei o Charlotte NC. zatu

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( 1 LARRY R. DAVISON, being first duly sworn, testified as 2 follows:

3 EXN4INATION: (:By Mr. Guild) 4 Q. Mr. Davison, would you state your full name and your 5 work address for the record, please.

6 A. My name is Larry R. Davison. My work address is P. O.

7 Box 223, Clover , South Carolina.

8 Q. Is that at the Catawba Nuclear Station?

9 A. Yes.

10 Q. You are employed by Duke Power Company?

11 A. Yes.

12 Q. In what capacity, sir?

13 A. I'm Project QA Manager at Catawba Nuclear Station.

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14 Q. My name is Robert Guild, and I'm counsel for Palmetto is Alliance, intervenor in the operating licensing proceeding-16 for Catawba Station, and you are generally aware that my 17 Clients have filed a contention that has been adm ited by 18 the Board questioning the adequacy of the quality assurance 19 program and. construction at Catawba?

20 A. Yes, I am. ,

21 Q. The others inlthe room with me for Palmetto Alliance is 22 Micha'el Lowe and Betsy Levitas, and Ms. Billie Garde from 23 the Government Accountability Project. Perhaps if others 24 could identify themselves.

25 MR. JOHNSON: I'm George ' Johnson, counsel far the NRC 2

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2 MR. BELL: Glen Bell, Duke QA Department.

Wayne Henry, Quality Assurance Depart-3 MR. HENRY:

4 ment.

5 MR. GIBSON: I'm Ron Gibson, counsel for Duke. Mr.

6 Guild, I wanted to mention at the beginning of the deposition 7 particularly given the lateness in the day, that we are going - -

8 I expect you are going to ask Mr. Davison about documents 9 during the course of the deposition, so let me go ahead and 10 identify the documents he has brought with him and give you 11 copies of those, and you can review them over the night and 12 may save us some time tomorrow.

13 Q. That would be fine.

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14 MR. GIBSON: We have a recourse procedure filed --

15 documents related to a recourse procedure filed by Beau Ross, 16 G. E. Ross, I believe are his correct initials that became 17 final within the Duke recourse procedure on June 15, -1983.

18 Let me point out that a couple of the attachments are pencil 19 or copies of pencil ~ writings that are illegible on the copy.

20 We have the originals of the attachments here -- we will have 21 here tomorrow, but you won't be able to read some of the copies 22 and we are unable to get a better xerox copy than that. .Anothe r 23 set of documents involve the harrassment charge filed by 24 welding inspector, Stuart Reep, that.is still open in the 25 Duke procedure. We are turning over the documents relating i

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( 1 to that. The other documents are a little more difficult 2 to describe but involve John Rockholt, the memorandum written 3 by Mr. Rockholt that expresses some concerns that arguably 4 f all within the scope of the items requested during the dis-5 covery. I think there has been some discussion or an earlier 6 request for a document posted on the bulletin boards at 7 the site. I have several items that are posted that I will 8 turn over and we can see if that satisfies the list of items 9 you had requested earlier. Also, I might mention as I under-10 stand, we are proceeding under the same set of rules, the 11 stipulations regarding objections. That's all questions are 12 deemed objected to except as to form.

13 Q. Yes, that's fine.

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14 MR. GIBSON: So, I will hand you. copies of these 15 as soon as I collate them.

16 Q. What I would like to do, counsel, in the ' f ew remaining 17 moments is try to get _ some background on Mr. Davison, and 18 we'll see how fast we can move through some of. the more formal 19 questions and then we will begin again in _ the morning at 20 eight. Mr. Davison when-did you come to work for Duke Power 21 Company?

22 A. In July of 1971.

23 Q. In what capacity then?

24 A. :I was an Assistant Field. Engineer.

25 Q. _Can you run _through tue positions you held since then with .

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1 Duke and when you came to those positions?

2 A. In 1972 or 3, I'm not too sure, I was promoted to 3 Associate Field Engineer , and then in 1974, I was promoted 4 to Senior QA Engineer or excuse me, Senior QC Engineer at the 5 Catawba Nuclear Station. .

6 Q. Where were you located in the two previous jobs?

7 A. At Oconee Nuclear Station. i 8 Q. All right, sir.

9 A. I was Senior QC Engineer until February of 1981, when 10 I became QA Manager Projects located here in Charlotte.

11 Q. Right.

12 A. T hen , in September of 1982, I went back to Catawba as 13 I an now, Project QA Manager'.

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14 Q. Mr. Davison, I'm going to show you a document dated 15 March 25, 1903, and it's Duke Power Company's response to 16 Palmetto Alliance follow-up interrogatories regarding contenti on l'7 six and others. I believe you had a hand-in preparing some is of those answer s. Nbuld you identify the document and then

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19 I will direct your attention to page twenty?

20 A. Yes. ,

21 Q. You will have to say yes or no to the questions so the 22 answers will be reflected.on the tape. Can you identify-that 23 document?

• 24 A. Yes, this is the copy of the applicant's. response to 25 Palmetto Alliance's follow-up interrogatories - and request l

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1 to produce regarding contention 6, 7, 8, 16, 27 and 43.

2 Q. Have you seen that before?

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3 A. Yes, I have seen a copy of it before.

4 Q. Did you participate in responding to the answers to 5 the contention six?

6 A. Yes, I participated in a limited way.

7 Q. Why don't you tell me what that way was.

8 A. The interrogatories were, I assume, served by you on Duke 9 Power?

10 Q. Yes.

11 A. Our Legal Department then communicated those with QA 12 Department. I was a member of the QA Department and was 13 involved in at least one meeting that I recall talking about

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14 the interrogatories and the esponse to them. I did not 15 prepare any of the res pnses.

16 Q. Did you participate in the preparation of those responses?

17 A. As I said, I was in one meeting with Legal and the other is managers in QA where the interrogatories were discu ssed to make assignments as to basically who would ansker what,- who

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19 20 would gather what information and I did aid in the gathering 21 of some of the information.

22 Q. Did you take an assignment as a result of that meeting or 23 any other instructions with respect to responding to those 24 requests?

25 A. Not an assignment to respond directly to one of the 6

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( 1 interrogatories, no.

2 Q. How about to any of the requests? Did you have any re-3 sponsibility with respect to responding to those requests?

4 A. As I sa id , I was present at a meeting where the inter-5 rogatories were discussed, assignments were made to gather 6 information. I did not have a specific assignment to gather 7 information although I did aid in gathering information on 8 some of them.

9 Q. What did you do in so far as aiding and gathering informa-10 tion on some of them?

11 A. The one I recall had to deal with the names, addresses

< 12 and telephone numbers of all the QA employees at Catawba and 13 compiling that list, the QA Manager of Administrative Services

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14 compiled that list and-I looked over that list to try 15 to be sure it was complete and indicate which people worked 16 in QA and maybe had been terminated to be sure it was a com-l'7 plete list.

18 Q. What else did you do?

19 A. T hat is the extent of what I recall.

20 Q. I got a little, ahead of myself. What I wanted to direct 21 your attention to, I think, is page twenty -of that. Does that 22 have your name on the list of those people?

I 23 A. Yes, it'does.

I 2d O. I'm trying to clarify your responsibilities to the earlier l

25 question. that position did that show you holding at Catawba l

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1 Nuclear Station with respect to quality assurance work?

2 A. It indicates Senior QC Engineer and QA Manager Projects.

3 Q.' What are the dates it has by that?

4 A. Senior QC Engineer has 2/1/81 to 3/1/81.

5 Q. Is that correct?

6 A. I was Senior QC Engineer from 1974 until 2/1/81.

7 Q. That 's incorrect?

8 A. Yes.

i 9 Q. Then, what is the significance of -- what is the second to position they have you dokn for?

11 A. QA Manager Projects.

12 Q. What is the date of that?

13 A. 3/1/81 to present.

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4 14 Q. Is that accurate?

15 A. No, I became QA Manager Projects 2/1/81, was assigned in 1

16 Charlotte and went back to Catawba September,1982 as Project 17 QA Manager.

18 Q. So, those dates are incorrect?

19 A. Yes.

20 Q. Mr. Davison, relate to me briefly, sir, your professional 21 training and background and work experience prior to coming 22 to Duke Power Company.

23 A. I attended Georgia Institute of Technology in 1963 to '67, 24 and received a Mechanical Engineering degree in '67.

25 Q. Bachelor 's degree?

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1 A. Yes.

2 Q. What --

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3 A. Bachelor of Mechanical Engineering.

4 Q. All right, sir.

5 -A. I went into the Navy, was in the Navy for four years until 6 1971 and went to their Nuclear Power School which was a six 7 month school and spent six months at a nuclear prototype, 8 six months at submarine school and the remainder of my time 9 assigned to a submarine in the Navy, nuclear su ynarine. r 10 Q. What were your duties?

11 A. On the submarine, I was assigned, I had the duties of 12 Auxilliary Division Officer, Damage Control Assistant and 13 Communications Officer.

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14 Q. At different times?

15 A. Yes, at times'when I was first there, I was Auxilliary 16 Division Officer and also Damage Control Assistant both.for 17 a period of time, and then became Commulcations Of ficer later 18 on.

19 Q. What rank did you hold in. the Navy?

20 A. Lieutenant. ,

21 Q. Af ter the Navy?

22 A. InL1971, I got out of the Navy, I came to work with Duke 23 at Oconee.

24 Q. What was .the nature of your' work as. Assistant Field 25 Eng heer, the first. position you held :at Oconee?

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( 1 A. worked in the Construction Department, the technical 2 support group for the Construction Department there at Oconee 3 in't'he welding area. I worked with welding procedures, 4 writing, developing welding procedures and also with weld 5 inspection to some extent at that time.

6 Q. To what extent, sir?

7 A. The welding inspectors were part of that group, and I 8 reported to that same group so in the development of the pro-9 cedures that type of thing, we would work with the inspectors 10 as the need might arise. If there was a question that came 11 up about a procedure or whatever I might get involved in that.

12 Q. Did you provide technical review of welding inspection 13 work?

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14 A. Not at that time.

15 Q. In that position subsequently?

16 A. Yes, when I got promoted to Associate Field Engineer, I 17 did have the responsibility for welding inspection.

18 Q. For technical review of welding inspection?

19 A. For the welding inspection.

20 Q. In what manner,were you responsLble?

21 A. The inspection requirements were assigned to me to be 22 carried out. I had supervisors and inspectors that reported 23 to me that did that work.

24 Q. You were a second level supervision to welding inspectors?

25 A. Yes.

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! 1 MR. GIBSON: I believe it is five. Do you think 2 you could finish with his background in a few moments?

,' 3 Q.Yes,'we can. Are you a welder?

4 A. No, I'm not. .

5 Q. Have you ever had any training in welding?

l 6 A. Yes.

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7 Q. Would you describe that, please?

8 A. In school there were at least one course involving

! 9 training in welding.

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10 Q. Undergraduate course at Georgia Tech?

11 A. Yes.

12 Q. How did it involve training in welding?

13 A. It was a study of welding, of how a weld is made, the-

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14 theory behind welding, the metallurgy and also included some i

15 actual hands - on welding. ,

16 Q. What was the name of the course?

17 A. I don't recall.

! 18 Q. Was it classioom course?

19 A. Yes, but it also had a lab part.

20 Q. Did you ever do any welding work after that?

l 21 A. No.

22 Q. You are not a certified welder, are you?

l 23 A. No._ .

You are not qualified to perform code welding on nuclear

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25 power plants?

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( 1 A. o, I am not.

2 Q. You are not qualified to be certified as a code welder 3 on a nuclear power plant, are you?

d A. Qualified to be certified?

5 Q. Yes.

6 A. What do you mean. I'm not a qualified welder.

7 Q. I want to understand if you consider yourself qualified 8 if you took a test?

9 A. No. Well, I do not consider myself as able to go out 10 and make a weld, 11 Q. That would be necessary for you to be certified as a 12 welder, wouldn't it?

13 A. Yes.

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1d Q. Mr. Davison, do you have any other relevant professional 15 training or experience that you consider to be significant witt 16 respect to the performance of your job?

17 A. My experience in the Navy, of course, was on nuclear pro-18 pulsion systems with them and during that period of time, we 19 did undergo an overhaul on the submarine that I was on which 20 involved a lot of work that is very similar to construction 21 work I'm involved in now, and I was a member of the Engineering 22 Department an'd stood watch with the Engineering Department 23 during.that' period of time. I have been to several seminars 24 and schools af ter being with Duke that dealt with welding or 25 welding inspection.

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( What were the seminars and schools on welding first?

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2 A. I don't know that I can recall all of them. Tennessee 3 Ind'ustries, we had one week school or seminar that they 4 put on annually that covers welding. I have been to that.

5 Magniflux.

6 Q. How long ago was that if you recall?

7 A. That was while I was at Oconee, probably '72 or somewhere 8 around there.

9 Q. All rig ht, sir.

10 A. Then, to a forty hour instructional class in radiographic 11 interpretation with the Magniflux Corporation.

12 Q. Yes, s ir .

And, as far as schools, that's the only two I can recall.

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14 Q. How a bout in welding inspection area, that cover it?

15 A. Yes ba sically.

1 16 Q. Does that complete your answer to that earlier question.

17 I want to understand if there is anything else you have in 18 understanding your background and experience and qualifications 19 for your job.

20 A. I think that answers that.

21 Q. Thank you., It looks like five o' clock, and let'r try 22 to resume tomorrow at eight.

23 EVENING RECESS

. 24 25 LARRY R. DAVISON 13

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, STATE OF NORTH CAROLINA )

) CERTIFICATE 2

COUNTY OF MECKLENBURG )

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I, the undersigned Commissioner and Notary Public, in and for the State of North Carolina, do hereby certify 6

7 that Larry R. Davison was duly sworn prior to the taking g of his deposition.

9 I do further certify that the foregoing thirteen pages 10 constitute a true and accurate transcript of the evidence n given by the said witness as taken down and transcribed by 12 me.

13 This the twentieth day of July,1983.

g 14 15 d' 'A BARBARA V. HAAS 16 Commissioner and Notary Public 17 My Commission Expires:

is April 23, 1987 19 20

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