ML20082C127
| ML20082C127 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/01/1983 |
| From: | Davison L DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20082C119 | List: |
| References | |
| FOIA-83-434 NUDOCS 8311210471 | |
| Download: ML20082C127 (154) | |
Text
U NIT ED STATES OF A M ERIC A NUCLEAR REGULATORY C O M MISSIO N BEFORE THE A T O MIC SAFETY AND LIC E N SIN G COARD In the Matter of: )
)
DUKE P O V! E R CO M PA N Y, et al.) Docket Nos. 50-413 l ) 50-414
! (C a t a w b a Nuclear S t a tio n,
! )
U nit s 1 and 2) )
l l
l t
l l
JULY 1, 1983 8 : 10 A . M .
l D E P O SITION OF:
LARRY R. D A VIS ON 8311210471 830825 b $f[ERS83-434 PDR Evelyn llerger Assuolates ,
STENOTYPE REPORTING SERVICE P. O. 80X 19444 NMMM
2 ROSERT GUILD, ESC.
C olum bia, S. C.
3 C oun s el on Behalf of Intervenor, Palmetto 4 A llia n c e C o rpo r ation 5 RONALD L. GIBSON, ESQ.
C ha rlot te, N. C.
6 C oun s el on B e h alf of A p plic a nt, Duke Powe r 7 Company 8 Also Pr e s ent:
9 George W. Grier Duke Power Company
, 10 Roger O u e ll e t t e 11 Duke Power Company 12 G le nn H. Bell Duke Power Company 13 Michael F. Lowe 14 Pcimetto Allia nc e 15 P hil Jos Palmetto A llia n c e 16 Betcy L evit a s 17 C a r olin a E n vir o n m e nt al S tu dy Group 18
- B ill y e Garde 19 G ov e r nme nt A c c oun ta bility Project 20 21 I N D E X 22 % IT NESS DIR E C T- CRCSS '
23 Larry R. D avi s o n 3 --
24 25 EVELTN BERGER ASSOCIATES, STENOTYPE REPORTING SemytCE CHARLOTTE, NOsrTM CaesOLINA
2A 1- E X HI B I T S I 2 h* C M B E R DESCRIPTION PAGE 3 D avis on Exhibit Typewritten notes. 30 One Pages One and Two 4
D avis o n Exhibit Memo to G. E. Ross 46
. 5 T wo dated 5/26/83 6 D avis on Exhibit Inve s ti ga tion into 47 Three recourse cubmitted
- 7 to Catawba QA M gr.
by G. E. Rors 8
D a vi s o n Exhibit Memo to file f rom 50 l
9 Four Grier dated 4/27/83 ,
l 10 D avic on Exhibit W eld Proce s s Control 143 Five Sheet 11 12 13 14 I
i 15 16 17 16 19 4
20 21 a 22 /
23 24 25 o Evf Lvm MERGER ASSOCIATES. STENOTYPE #EPORTING SERVICE. CF AELOTTE. MostTM CAROL
- - - - we,.- i -
-e y / e -1
Davison - D-i r e c t . 3 i
1 The r e s umed D e po sitio n of Larry R.
2 D avis on is'taken at the corporate o ffic e s of Duke 3 13 ower C o m p a n y, C ha rlot t e, North C a rolin a, on this a the first dny of J uly, 1983, in the presence of 5 Robert G uild , Attorney for the Intervenor; tnd 6 Ronald L. Gibson, Attorney for the A p pli c a nt.
7 All f o r m alitie s as to c ap tion, ce rtifica te s and tr an s mis s ion are waived. It is agreed that 9 Lynn 3 Gillia.m. Nota ry P u b li c in and for the State 10 of North C a r olina, may take enid Deposition in 11 m a c hi ne shorthand and transcribe the same to type.
12 w ritin g.
i la Said D e po sition is taken subj ect alone to 14 te s timony for competency, r ele va nc y and mate riality; 15 and all objections, save as to the form of que s tion s
- 16 nsked, are reserved u n til the H e a rin g.
17 18 LARRY R. D A VIS ON, 19 having been p r e vi o u s ly sworn to t e ll t h e tr u t h , was 20 examined and te s ti fi e d as f ollo w s :
21 22 .DIR E C T E X A .NI I N A T I O N 23 BY MR. GUILD:
I 24 0 M r. D avis on, good mo rni n g. .
l 25 A Good mo r nin g. N
)/
./
EVELYN SERGER ASSOCIATES. STENCTYPE REPORTING SERvtCE. CHARLOTTE. NORTM CAsso.
L . , .
Davison - Direct 4 1 C A number of doc um e n t s were id e n tifi e d yer -
2 tcrday by your Councel and made a va ilt ble to me at 3 the conclusion of yesterday's D e po c itio n.
4 I wonder if you could help me underetand 5 your knowledge about thcee documents end their pro-6 du c tio n. Have you seen the s e ?
7 A T hi s fir s t document is a memo to file con- -
S cerning Mr. R oc kholt, a V elding Inspector; and a 9
note of a c o nve r s ation he had with the Catawba CA 10 Division.
11 It is a fil e from E m plo ye e R ela tio n s As-12 sictant, Barbara Horne.
i 13 O A ll of that fir s t stack relates to M r.
14 R oc kholt ?
15 A No, just this fir s t. The second document 16 is a document concerning a ha ra s s m ent charge b y.
17 Vi e l di n g In s pe c to r Phillip R ee p, R-E-E.P.
18 C Is tha t _f rom your file, Mr. D avi s o n ?
19 A A couple of them are f rom my file. The 20 other tre from darbara Horne's E m plo y e e R ela tion 21 file and al s o. a document from C o nt t r u c t i o n Employee U R ela tion s.
i 23 Q H ow ~did tha t c o me to be id en tifie d ?
'24 A T hi e is a hara s s ment charge by a Welding 1
- 2a.
In s p e c to r made to our- E m ploye e. R ela tion e A s sis tant.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVfCE. CMARLOTTE. NORTH CAROUNA
D a vis on - Darect 5
1 It wac inve s tigate d by us, and both C o n u t r u c tion Em-4 2 ployee Il e l a t i o n e : cnd har b e. e n ongoing.
3 It came about a couple months ago.
4 O How did tho s e documents come to be iden-5 tified ? .,
e 6 A How do you mean that?
7 Q il o w did they co me to be i d e n ti fi e d and get 8 to us yesterday af ternoon ?
9 A Ve talked with the L e g al Department about 10 this and said we will keep those documenta to getner, 11 and Le g al cuid how about getting there together and 12 g ettin g th e m to us.
1 13 O How did they get to Legal?
14 S. Yesterday was when I gave it to them. As 15 far as I know they may have gotten it e a rli e r ; but I 16 gave it to them yeeterday.
17 O W ha t else do you have?
18 /.
The third set of documents is a recourse 19 procedure from Beau Bos= concerning an evaluation 20 of his.
21 C % he re did those doc um ent s come f rom ?
22 A From the r e c o u r t. c file that Employee Re-23 la tio n c keepc.
l 24 0 'From your file ?-
25 f, ,c o m e . of 't h e do c um ent s would be in my fil e .
I EVELYN BERGER ASSOCIATES STENOTYPE REPORTING SERylCE. CHARLOTTS. feOENTH CAROUNA l
D avi r on -- Direct 6 1 They would all be in the E ra p l o y e e T, e l c. t i o n filec 2 aluo.
3 C So the source of those documents was not 4 from your file but the E m plo y e e R ela tion s file ?
5 A Yes, some of them; but I may have copies 6 also.
< 7 O But that would be coincidental; those docu-8 ments came f r om the Employee R ela tion c file s ; is 9 that right?
10 -A ye,,
11 O Let'c start with tha t eet fi r e t . Did you 12 cearch your files for documents that we re related to 13 the s u bj e c t of Mr. Roes' recourse?
14 a Yes, I did.
15 Q Are there any other documents in_your 16 file 7 17 A yo, 18 O Any notes of yours?
19 A N o.
20 C M r. D a vic on, le t's- talk about fi r s t - th e.
21 e valu a tion that appears in thic s e't of ' do cume nt s that oo have been ide ntifie d a s related to M r. R o s s ' .re c our s e.
. 23 There in an excmpt employec cycluation o4 that appears attached to tho s e -docu me nt s that reinte 25 to id r . Roos: is tha t' right?
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHAMLOTTE. NORTH CAROUNA
Davison - Direct
_ , 7 1 A Yes.
2 C VJ h a t I we nt to u n d e. r e t t a d it some of the 3 procedures and form s and process that is r e fic c t e d 4
in this cet of do cu m ent s that I have here.
5 First of all with respect to Mr. Roco' 6 e s alua tion that appears here, how was it conduc ted ?
7 V. hat process does it relate to and who was involve d 8 in that process?
9 MR. G UIL D : C oun s el, I guess the 10 last one of the last things you said was 11 confirming that the c o pie s, that come of 12 the documents we have herein are in hand-13 w ritin g and are ill e gible .
14 Do you have the originals ?
15 MR. GIDSON: I have the originals 16 that are a little better copies. This is 17 the one that is legible (indic a tin g).
18 That is in p e n c il, and here is one 19 that may not be a lot better in terms of 20 the copy.
21 These are not the s a me document s.
22 '
V. h y d o n ' t you continue with your qu e stion-23 ing, and it will be cicar what the document s 24 are.
25 THE % IT NE SS: The exempt e m plo y e e.
EVELYN BERGER ASSOCIATES. ETENOTYPE REPORTING SE RvlCE. CMARLOTTE. f. ORTH rJROUNA
D avis on - Direct a l
i 1
in October of thic year we imple me n t e d n r.
2 E mplo ye e .V a n a g e m e n t P l c. n .
3 4 EY MR. GUILD:
5 O V/ hen did that happen?
6 A October of t hi s year.
7 Q October of '827 l 8 A Yes, '82.
9 O Say it a gain.
10 A In October of '82, we implemented a Per-11 formance Management Plan which has .t h e forms t h e. t 12 you cre looking at now, the Pe r r onnel Perfo rmance.
.13 P la n worksheet as part of it, and also this A cc ount-14 a bilit y Fu mm a r y and A pp r ai s al.
15 O W hi c h was attached to the stack ma de a v ail -
16 able yesterday of M r. Ross' recource?
17 ye,,
3 18 O And we have a Personnel Performance Plan 19 worksheet a n d - a. n o t h e r form goec r. l o n g with that c all .
20 ed an A c c ount a bilit y Summ ar y. an d A p p r aic al ?.
21 A Yee.
22
- e Atg.right, sir; go aherd.
23
! A Under this program the P e r s o n n'e l Pc: form -
l 24 ance Plan wo rkehe et is developed for each exempt 25 e mplo ye e with the supervisor a nd em ployee d evelo pin g EWELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTH CAROLINA
D avis on - Direct ,
9 1 that.
2 A nd that is cred to ret the c t :. n d a r d r and 3 o b j e c t i v e r, for esch e m plo y e e during the evaluation.
4 period; and at the end of tht.t period, the A c count-5 a bilit y s. n d A pprai s al f orm is fill e d out and thr.t 6 serves as the employ e e 's e va lu atio n.
7 Q A.n d who conducts the evaluation ?
8 A The e mplo ye e 's supervisor conducts that.
9 C The same supervisor that produced the 10 P e r s onn c1 P erf ormance Plan ?
11 A Yes.
12 O When was this e va lu a tio n s y s te m im ple ment ed?
13 A In October of 1982.
14 Q What existed prior to the Performance 15 Management Plan wit h regard to e v alua t io n of an I
16 exempt employee ?
17 A B a s ic a lly once a year the e m pl o y e e 's supe m-4 18 vis o r would conduct an e v alu a ti o n of that e m plo y e e !
19 and put it on a form used for that purpose and sub-20 mit that.
21 O W ha t wac that system c a lle d, if it had a
.n name?
23 A I do n' t r e call a cpecific name: I don't 24 r e c a ll a s p e cific n r me -- Pe rf o r manc e E valua tion. wou1 1 25 be ba sic ally w h t. t it was. .
EVELYN BERGER ASSOCIAfES. STENOTYPE REPORTING SERysCE CHARLOTTE. NORTM CAROLINA
Dtvison - Direct 10 1 C What are the d i f'f e r e n c e s between the 2 c a r li e r Pe rf or ma nc e E valu t ti on syetem and the Per.
3 fo rma nc e Ma na ge me nt Plt n ?
4 !. I3 a r i c a ll y it involves the P e r s o nn el Per.
5 formance Plcn worksheet where the e u p e r vi r o r and th e 6 e mploye e fill that out at th e beginning of the r e view 7 period and set forth some obj e c tive s an i standards t o 8 be met during that e valua ti on period.
9 Then periodic r e vi c w s are held betwe en the 10 s u p e r vis o r and the employee to go over the progress 11 on tho c e o bj ec tive s ; and just before the e v a lu a tio n i
12 ir c omple t e d, that plan worksheet is gone over again 13 with the e m plo ye e.
14 Q /> n d previously under the e a r li e r s ys tem ?
15 A P re viou sly there was an evaluation com-16 pleted once a year which would be gone over with the 17 e mplo ye e.
18 Q Would there be objec tive s and standards 19 previou sly ?
20 A T he re may beS yes; it would r eally be 21 ependent on the s up e r vis o r what o bj e c tiv e s he m igh t 22 cet and tell the employee.
23 _Q How would those etendarde and o bj e c tiv c e 4
24 have been e c ta blis h ed e t rlie r ?
5 A T h r o u gh the s upe r vic or_ cnd e rn pl o y e e l EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERylCE. CHARLOTTE. NOstfee CAROUNA
D a vi s on - D_i r e c t . 11 i
I discuseing t h e m.
2 O Viculd that be documente d ?
3 r. Ace previous form did have a place to 4 d c c um e nt obj e c tive s for th e nc :t year; but of course 5 t h :. t might not be th e o nly objective thct migh t occur, 6 That was the obj ec tive s t h at were there 7
l during that period in time which the objective was 8 done.
9 You need to be working on the obj e c tive s 10 of the next year.
11 Q W ha t do c ume nt would that appect on?
12 A The Performance Appraisal.
13 C That is the evalua tio n ?
14 es Yes.
15 O What objective measure of performance for 16 e xe mp t em ploye e s was e m plo y ed prior to the ad o p tio n 17 of this recent plan ?
18 A The measures would be e s t a b li s h e d by th e 19 s u p e r vi s o r . There were no set measures.
20 Q Was there a numerical r a ting ?
. 21 j, yes, 22 Q Would you d e c e rJ b e that, please?
23 A
[ The e m plo ye e was evaluated into one of l
24 fi v e categorieo; a n d t h'a t wa s 't ra nslat ed into a nu-25- mericci value.
l .v.tva .... a ...oci t... .v.aom monia ..avice. caaaton.. o= ca='aa e
Davison - Dire-t 12 1 Q ' ha t were the five c a te gorie s ?
2 a t.; t r gi n n i, fait, c o n.p e t e n t, c o m m e r d s. b l e 3 a n '. dis tin g ui r h e d.
4 Q M .- g i n t.1, fair, c o m pe t e it, c om m e nda bl e 5 and distinguic he d ?
l l
6 A Yes.
7 Q And those were assigned numbe r s one 8 through five ?
9 A V. ell, they r e ally we re not assigned number s. i l
(
10 They would c o r re s p on d, ro u g hly to the numbers under i i
i 11 this p r o gr am, three, f ou r, one, two, '
fi v,e ; one being l'
12 m a r ginal a.n d fi v e being di s tin gui c h e d.
t s ,:
13 Q In wh at ~ way wouldn't they c o r r e s po nd; you 14 said rou ghly ? -
15 A Under the p r e viou s s ys te m, we didn't have '
16 a n um e ric al' c c ale. You had tho c e categories.
l ,'
O
- s. .
One o f t h o's'c 'dif f e r e n t ca te go rie s 'w a s th e e
18 r e s ult of an annual evalu atigo ? -j 3
19 A yeg, '
to Q What was the s i g nk fi c a. n c e of each o f -thdc e
,.. i ~. } )1 21 '
C a te go rie s ,p r eviou sly ?
s, N 22 A Thef were categories t h a t' ' y o u 'w o u l d e.v a l u - )O.
23 ate. E mplo ye e evaluations put the einployee in one
~
24
,~ h-
,f those c a t s g cVi e c..'. marginal, f air, co mme n dable, i n .
9c 23
,,my,t,,, ,, 3 3 g i , 71, g gi,3,3, , q g%' ..
.c <--
swatvm senaan associares. stanovves napowiwo sisics.cuantoris. wown camouma f.'>
]
m .
% .-,t -u
D avis on - Direct 13 1 C V. E t t was the e i g n i f i e r. n c e of thos e catc.
2 gories with r e ga r d to paf and o r 't i n g c o n d i t i o r. s .
3 p r o mo tion t e demotions, r e t e ntion ?
4 /. T he y wo uld be z. factor in pay.
5 C Y.~ h a t i t. c t o r , how v/ o u l d they be s i g ni fi c ant ?
6 A Thct is one of the factors that when the I
evaluation wac done and the rating that the employee 8
was rated in one of those ca te go rie s was a f actor 9
that was used to d e t e r mine the amount of increase.
10 O I w r. n t to und e r s tand with some deErce of 11 s pecificity how would one's pay be ef f e cte d by th e 12 evaluation under the e a rli e r sy rte m ?
13 A T ha t would be a factor that you would 14 take the e va lu a tio n and the category that the e m ploy e e 15 came out, one of tho s e five c ate gorie s; you would go 16 to a chart end that chart wec e s t a bli s h e d for the 17 various cat e g o rie s what the increase wo uld b e, taking 18 into account other factors also.
19 C There is a s tandar d that e s tabli s he s the oo r ela ti on s hip between the evaluation category and pay?
ol
!. 3 :. s i c a ll y , yec; but there was c till room oo within that ctanda rd fo r judgment of the supervisor.
oa There might be a range, for e xa mple, thic category o4 for this rating for an individual might be a r r. n g e .
95
~
O VT r. t. there 1. rtnce?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING St 4TICE. CHARLOTTE. NORTM CAROLINA
.s
- - _ -. =__ _ . - - - - . . - _ _ - _ - .
D a vir on - Direct 14 j 1 1. As I r e c all.
l
! 2 O Whe re w t. c that r e l t. t i o n r h i p e c t abli r h e d :
4 4
3 was there a do cu m e nt, procedure, p olic y, memorandu m?
4 W he re would that r eir tion c hip have been es tabli s hed ?
I 5 A Yes, there is a document that describes 6 and shows for the rating c at e go ri e s and the pay that
. 7 a persen is, p e r s o nally, at what range of increase 4
8 might be availabic.
- 9 O I would like to unde r e tand what that docu-i 10 mentary cource is, what it w r. s before the new syste m
) 11 and what it is now.
i 12 A That document thr.t has that information on 13 it is b r. s i c a ll y the same that has been used for some 14 tim e.
.l 15 Q It is the same ?
16 A W ell, it is updated each year; but as far i
17 as j -
18 O The number s may change?
! 19 A Yes, but the basic do cum ent s --
i
' 20 O The r ela ti on s hip between th e e valuatio n 21 r e s ult s and the pay, j ust the numbers z. r e r evie we d ?
j 22 A Right.
23 C What is that document called ?
24 A I don't know tha t' I k no w the title of that
'5
.d oc um ent.
'EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAmouMA
.- - e e-, .,4 4 s.- y
- D a vi s on - Dir e c t 15 1 Q Give me your bect u nd e r s tandin g; how 2 would you refe r to it ?
3 A It is a pay computttion chett, increase 4 c o m pu t a ti o n sheet based on the evaluction of the 5 em ploye e.
6 Q Do you have a copy of that?
7 A Yes, I do.
8 O In your file ?
9 A Yes.
10 Q A ll ri ght, sir; now then, what is the a t g.
11 nifi ca nc e of the reading system, the evaluation cate-12 gories before and af ter, if they have c hang e d with 13 re s pect to promotions ?
14 A There is no set rule for evaluations .w i t h 15 respect to promotion that I am aware of. I would 16 cxpect that no rmally a very lo w evalua tion would 17 p r o ba bly be a f actor in a decision for a p r o m o tion, o r
( 18 a very high one.
19 O Whe t is very low ?
20 A The lowest one wo ul d be a one or m a r gin al 21 ac de s c ribed in the e arli e r s y s te m. ,
i 22 Q And a very hi gh ?
l 23 A uould be five or dis tin guis he d. l 24 O So af ter an e valua tio n in c ate go rie s one or 25 fi v e , wo ul d be s i g nific a n t with re s pect to p r o m o ti o n s ?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE. CHARLOTTE. NORTH CAROUNA
Davison . Direct 16 1 1. It would one of the f a c to r c. I feel s u r e; 2 not only if it w r. e one or fi v e , but w h r. t e v e r it might 3 be.
4 Q I wa nt to understand e p e cific ally to the 5 extent that you can t ell m e, s p e cifi c all y, M r. D avis o r ,
6 what the r ela ti o n s hip is of each of these evaluation 7 categories en the subject of pro motion.
8 A There is no set r elati on s hip between 9 e v a lu a ti o n and p ro mo ti o n. I am cure previous evalu-10 ations would be one f actor taken into account in a 11 p r o mo tio n.
12 Q So it would be up to the dis c r e tion of whom ?-
13 j, T he s up e r vi s o r and ma na ge ment.
14 Q Is there a written policy or procedure now 15 before the change that effects the relationship betwee n 16
. p r o mo tion and th e e v alua tion ?
17 A Not that I am aware of, no.
18 Q V. o u l d you know?
19 A I would expe ct I would know.
20 Q How about demotions ?
I A There le no written polic y o r procedure on 22 that that I am aware o f, eithe r.-
23 Q Wha t is the t i g nific a n c e of the e valua tio n 24 with respect to this de mo tion ?.
25 A -The 's i g nific an c e o bviou sly - a person who-EVELYN DERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE. CHARLOTTE. PeORTH CAAOUNA
l D avis on - Direct 17 1
cannot c ontinu e to receive cay a ma r ginct r atin g, 1 2 i m t. g i n e would be in for c o un c e li n g r_ b o u t perfo:mance 3 of his job and im p r o vin g that perfo: m anc e.
4 It p o c ribly could Icad to d e mo tio n; t e rmi-4 5 nation, probably not.
6 C A ll right, cir; how r. b o u t te r mina tion ?
7 A Vi h a t is the que stion ?
8 C Eame li n e of questions, Mr. Da vi s o n: Wha .
9 is the r ela tion s hip or what is the s i g nifi c a n c e with 10 respect to t e r mina tion of the c valuation and the evalu -
11
- r. t i o n r e cult s you have d e s c ribe d before and after the 12 change in the polic y ?
13 A Here ag ain, the percon's performance in a 14 job could be a factor in a t e r m i n t. t i o n .
15 g 1, gg a ga c go , 7 16 A It could be, yes.
II C Is there an objective ctandard that estab-18 li c h e s the r el a tion s hip between e valuation and 19 te rmina tion ?
ao
/. Not that I a m awar e of, no.
'l G Is there a written policy or procedure or oo document that r e fi c e t c the relation s hip between resuli s 23 of evaluationc and te r minationc ?
94 A There is a document regarding the oper atic n 25 of the PMP Program, whic h I said went into eff ect i EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
D avi s en - Direct 18 1 CA in October, 2 I cen't re c all e r. a c t l y that pince at that 3 point in time. There may be come gui delin e s on it.
4 C You don't know if it doer o r no t ?
5 A I can't re c all cecing the m there; I can't 6 say if there are or not.
7 O How about before the PMP P ro gr a m ?
8 A I am not awar e.
9 O How a bo ut the document that de s c ribe s the 10 o pe ra tio n of the PMP Prog ram ?
11 A It it a do cument entitled, " Performance 12 Management Plan," and how that is operated.
13 C Do you have a copy of that?
14 A Yes, I do.
15 C Now the documents that have been made 16 available to us with recpect to M r. Ross' recourse 17 include documents r efl ec tin g the Performance Manage. .
18 ment Plan that you have just described.
19 A Yes.
20 O Is this the fi r s t time that this plan has 21 been implement ed with respect to M r. Ross?
22 A yee, 23 Q Would this be th e fi r c t tim e that thic plan s
- 24 has been impicmented with respect to a ll e ne mp t f,
- o5
~
. e m olo ye e s ?
g EVELYN BERGER ASSOCIATES STENOTTPE REPORTING SE RVICE. CHARLOTTE. NORTM CAROUNA .
a
D avir on - Direct , 19 1 A In CA, yee.
2 C Eov :. b o u t in o th er d e p r. r t m e n t s of the 3 c ompany ?
4 A I don't know as I understand--this it in 5 effect througheut the company. I don't know what 6 other d e p t. r t m e n t s mty have imple m ent ed.
7 Q Do you understand they implemented it at 8 diff erent tim e s than CA?
9 A They may have; I am not aware whe th e r 10 other departments did it at the came time we did or 11 not.
12 I just don't know.
13 C All righ t, sir; now let's shif t to the im-14 pleme n:ation o f thic program both before and after 15 the adoption of the PMP with respect to the s p e cific s 16 of Mr. F.oes' cace.
17 How would you characterize the r e s ult s of 18 M r. Ross' fir et annual e v t. l u a t i o n under this program, 19 M r. Davis on ?
20 A Eow would I characterize the r e s ults of 21 that c v r. l u r.t i o n ?
22 g ycc, 23 /> Y.c11, the r e s ult s arc characterized best 24 by that numerical c cor e thr.t is c.rrived at through 25 vecighing the factorc r. n d the evaluation in each factor .
EVELYN SERGER ASSOCIATES, STEh0 TYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
D a vi r on - Direct 20 1
O H ova would you cha ra cte rize it?
l 2 .. I world characterize it ar a fair c valu atio n .
3 It shor r come room fo r i mp r o v e m e nt.
4 O Is im pro veme nt required in Mr. Roes?
5 A No. I would not say improvement ic 6 required.
7 Q Whr t per s onnel action s w o ul d r e s ult if 8 im p ro ve me nt wce not f o r th c omin g on Mr. Roes' part?
9 A With that e v alu a tio n at fair, if no improve -
10 ment occure then I would a c cume his next e valu ation 11 would be fair, too.
12 Q W ould that have any effect on Mr. Rocc' 13 pay?
14 A Yes, it wo ul d be one of the factors that le 15 taken into account in d e t e r minin g his pa).
16 O How would it eff ect his pay?
17 A All othe r things being equal, the hi gh e r the 18 e valua ti on, g e n e r a ll y cpeaking, the higher the 19 increase.
20 Q S p e cific ally with recpect to Mr. Rose?
21 A If h e _ we re to receive a-lower r atin g than 22 othero then hic increase would not be as grect, other 23 factors bein g equal.
24 G W e ll, le t' r have 'e pe cific r ef e rence to the 25 e valuatio n that it before ue. How would th at 'evalu -
EVELYN SERGER ASSOctATES. STENOTYPE REPORTING SERVICE. CHARLOTTE, NORTH CAROLINA
D a vir on - Direc9 21 1 ation effect fi r s t .V r . Rosc' pay?
2 1. Okty, that e valu ation, nr 1 said before, it 3 one o f the factors that rating thr_t you come out v. i t h ,
4 one, two, three, four, fi v e , it one of the factort 5 t h r. t goec into the chart that d e t e r m i r. e n wh at the 6 increase will be for an employee.
7 O How will it effect Mr. Ross' pay?
8 A Depending on what the number is; the lowe m 9 the nu mb e r, g en e r ally sp ea kin g, the lowe r the increas e.
10 The higher n umb e r , the higher the increase.
11 O I want to un de r e ta nd s pe cific ally how that 12 would eff e ct Mr. Ross?
13 A If the evaluation is lowe r that could, again ,
14 that is not the o nly f a c t o r that goes into the amount 15 of increase; but other factors b e in g equal, that would 16 mean he would get a s m a ll e r increase than he would 17 get if he were rated higher.
18 O A ll ri gh t, sir; I want thic in as concrete 19 terms as po c rible. We have in f ront of us a s p e cific 20 r a tin g.
21 I understand the abstract about how thio 22 works. I w t. n t to know the s pe cific s of Mr. Ross. '
23 W hat ehould Mr. Rose ur.deretand f rom the re sults 24 of the e va lu a tio n s that appear r e fic c t e d in the docu-25 rn e n t s given me about the s i g nific an c e of the s e EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE. CHARLOTTE. NOerTN CAmouseA a
Javison - Dir e ct 22 1 e valu c tion r with rerpect to hit pay?
2 /. -: e r. h o u l t: u n d e r c t a r. d that ic cnc of the 3 factors thr.t goes into the amount of i n c r c r. c c he will 4 get each ye.r.
5 O Sheuld he expect to get a high increa se ?
6 A I can't answer that, thould he cxpect to ,
7 g et a high Icvel of incrocsc.
8 C Is this a rational cyctem with predictable 9 r e c ult e, Mr. D avis on ?
10 A Yer, the y cre.
11 Q ilaving said that, help me understand what 12 o bj e c tive r elc tion c hip Mr. Roca chould understr.nd 13 there is f rom the two points, whatever that r ating ic ?
14 A The r ela tio n c hip he should understand; 15 ngain, if this overall r t. t i n g is a high rating, in the 16 fi ve levci, th e n hi s increase is p robably highe r than 17 it would be if it were a three or ~ a two-or a one.
18 O Mr. D a vi s on, you have the document in 19 front of you; you know what it is. Is it hi gh, low 20 in r ela tio n c hip to his increase?
21 There it a s p e cific r r. t i n g .
90 -
A Wha t I c a n t ell _ yo u ic his increase would 23 be lowe r with this e v ale tti e n than it would be if he 24 had g ott en c five a n d h i g h e r - t h r. n it would bc if he.
25 had gotten a ene.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
__ _ m____m_____.___._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _
3 c v i s o r. - Direct ,
23 1 Q !s it higher than other e mploye e r ? Give me 2 c. standard. Is it hi rh e r than tverage, below tverage ?
3 /. I don't h r.o w what the average it. I would 4 just have to guess on that.
5 O I don't want you to guess. I want you to 6 tell me to the best of your k no wl e d g e and und e r st and< -
7 ing. You cre th e Second Level Supervicor over Mr.
8 Ros e; are you not?
9 A No.
10 Q Third Level ?
11 /. Yes.
12 O A ll ri g ht, T hi r d Level S u p e r vi s o r over Mr ,
13 Ros s; and your n am e is me ntio n e d prominently in 14 these documents.
15 A Yes.
16 Q You reviewed his recourse r e s ultin g from 17 his di c s atis f ac tion with his e v a l u a t i o n '?
18 A _Yes.
19 O You are not c. s tran ger to Mr. Ross?
20 A No.
21 O Nor are you a s tran ge r f ro m his recourse 22 or hic e vcluation ?
- l 23 A No.
24 O H avin g s om e knowledge of Mr. Ross' cir-25- cum s t an ce s, I want to talk in as much s p e cifie s .a s j EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING $ERvtCE. CHARLOTTE. NORTH CAROUNA
1 Da vic on - Direct 24 l 1 you can, 2 V. hat I don't want to have happen. I don't 3 vrant the ri c a r i n g in this case to co me and have you 4 then Itter remember things tht.t you now d o n ' t, or 5 remember more d e t a il s or more s p e cific a.
6 I want you to tell me in as e xh au s tiv e 7 d e t ail as you can, under oath, fully an d t ruthfully, 8 as much inf o r ma tion as you can tell me with respect 9 to the s ub je ct we are talking ab o ut -- M r. Ross and 10 his evalua tion and what he should expect.
11 A Y ou want me to t e ll you what Mr. Ross 12 chould expect in terms of thie evaluation in terms of 13 pay?
14 O Yes, fir s t.
15 A The amount of increas e that he got fo r the 16 period of time over which the evaluation covered was 17 p ro ba bly lower than it would have been if he had gotte n 18 a higher rating.
19 O A nd higher than it would have be en if he 8 had gotten a lower ratin g ?
21 A T ha t 's right, he should unde rs tand f rom U thin there are come areas in the ctandards in the 23 c u p e r vis o r 's judgment which were not me t, c. n d there 24 is room for imp ro ve me nt s.
25 Q Vihat would r e s ult if there is-no i m p r o v e mc at?
EWELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE, CHARLOTTE. NORTM CAROUNA
D avis on - Direct .
25 1 A He will be evaluated again, and if hic fi r e .
2 p e r f o r m an c e gets higher or lower, it v,ill chow up on 3 his evaluction.
4 Q And what else will happen?
5 A It would depend on the eituction.
6 Q %onld hi r . Rocs lose his c up e r vi s o ry 7 p o sition ?
8 A 1 would not, this doc e n't indicate to me 9 that there is a problem there.
10 Q Anything else that you think indicates there 11 is . p ro blem ther e ?
12 A I believe his evaluation for the period of 13 time before this was implemented indicated there neede d 14 to be improvement.
15 Q In order for him to remain s up e r vis o r, 16 yes.
17 A 3ut there had been improvement noted in 18 that p e r f o r manc e also.
19 Q Taken together then what is your o pini o n 20 on thtt e ubj e c t ?
21 A Taken together, the evcluntio n of -f air is 22 proper. There is s till room for improvement, but 23 if hic performance stays exa c tly as it is now, he is 24 not in any- pro bl em or t r ou bl e over that.
25 Q Can you ide ntif y this d oc um e nt (indicating) ?
EWELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAmouNA
D avis on . Direct 26 1 A Yes.
(
2 C Vihat in it, cir ?
3 A T hi s w e. s a document completed by Mr.
4 A rt A llu m as an inte rim e valu a ti on on Mr. Ross. <
5 Q When was that done, sir ?
6 A It was done in the period of time of 7 O c tob er, D e c ember, 1982. I' m n ot exac tly s ure what 8 date.
9 Q Was it before or af ter the implementation 10 of the new p er connel s ys tem ?
11 A P e rf o r mance M a n t. g e m e n t Plan; this was 12 worked on before the i mple m e n ta tio n; but I think it 13 c ar ried on through af ter the i mple m e n t a tion.
14 It wa s n' t completed and gone over with hi m 15 until after the i mple m en tation. ,
16 Q How about when that d o c u m e n i. w a s produced ;
17 do you know ?
18 A Again, it was b ein g developed by his super -
19 vis o r, Is r t A ll u m, in the period of time October, 20 November, D e c e mb e r .
21 Is m :not -axac tly cure.
22 O was the document produced in December to 23 the beat of your und er s tandin g ? ;
24 A To the best of my und e r s ta ndin g, _yes.
'5 Q VJhcre d'id this document come from ?
! - ev.o .aana . sociar... su~orne -oarme saavice. cwaatorrs. aoara caaouaa
D Lvic on - Direct 27 i
1 A That c r. m e out of the--Art A llu m gave me 2 that document when I wcs doing the reeccrch on Mr.
3 Roec' c v a lu a ti o n .
4 Q On his recourse?
5 A On his recourse, yes.
6 Q What is your unde r s tandin g of this state-7 m ent by Mr. A llu m contained in thi s document without 8 improvements in those a r e r. s . " S e a u 's c o ntinu a n c e as 9 a s up e r vi s o r will not be appropriate " ?
10 A My unde r s ta nding of that was A rt was 11 c o mmunic a tin g to Beau that some of the p roblem s he 12 vi a s having could eff ect his a s signment as a super-13 visor.
14 G He was c o mmuni c a tin g that to Beau?
15 A Yes.
16 Q Was this d o c u m e nt given to Mr. Ross?
17 A No, that d o c um e nt to my kno wled g e was no 18 given to him.
19 Q Then how do you know that was c o mmuni-20 cnted to Mr. Ross?
21 A T hi s was dated 1/26/83, by Mr. Ross. Th e 22 c opy that we.have did not put that on there. In my 23 dis cu c cion s with Mr. Rost, he informed me he w e nt 24 over this.
l 25 Mr. A llu m went over this with Mr. Ross.
EVELYN BERGER ASSOCIATES. STEh0 TYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
Davis on - Direct 28 1 C That note attached it Mr. Rocc' handwrit-2 ing?
3 A N o. excuse me; that is Mr. Allum.
4 C T i2 e 1/26/63, h a n d ve r i t i n g on that document 5 ic f rom Mr. Allum ?
6 A Yes.
7 MR. G UI L D : C oun s el, do you have th a 8 original of that?
9 MR. G I :3 S O N : That is a copy we had. ,
10 The p ro ble m is an ali g nm e n t of the docu-11 mented copy.
12 T hi s one is probably better, you can 13 see the date but it is not totally legible 14 (indicating).
15 16 SY MR. GUILD:
17 Q Mr. D a vi c on, can you h e l p rn e by reading 18 that note that appears on a better copy of the 19 1/26/83?
20 A "I told him that I felt significant improve-21 ment had been made, z. n d tht.t my main cencern was 22 his i n v o l v e m e n t vei t h :he C r a f t. " '
23 C And that was r e f e r r i r. g to i rn p r o v e m e n t s .
24 durin g_ what period, if you know ?
r
- 25 4 This would cover the e va lu a ti o n of M r. Roc c EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. edORTH CAmoumA
D a vic o n - Direct ,
29 1 by Ni r . /.11 u m fro . his p r e vien e e valuc tio n up until 2 the impicmentation of the ??"P P ro g r a m.
3 And w h c. t he w a r. i n d i c t. t i n g there wac rince 4 th a t time, since th e im ple m e nta ti on he hcc scen im-5 p ro ve me nt.
6 Q Octween that point and the 2 8th of January 7 when he made that note ?
8 A Yes, I b e li e ve he cnys that he ha s seen 9 imp ro ve me nt s.
10 MR. GI SS O N: Excuse me, Mr. Guild.
11 Do you w a nt to swap pcges since this one 12 has the date ?
13 MR. GUILD: Sure.
1 14 15 BY MR. GUILD:
16 O Mr. D avi c on, you don't know whe the r or 17 not Mr. R os s has seen thir document, the typewritten 18 document that Mr. A llu m prepared?
19 is During the course of my inve s tiga tion into 20 th e recourse, I did go over that do cument with Mr.
21 go33, 22 O Did you. s how it to him ?
23 A I had it out, I did not give him a copy of 24 it.
25 You didn't read it to him ?
Q EVELYN BER3ER A$$OCIATES. STENOTYPE RCPORTING SERVICE. CHARLOTTE. NORTH CAROLINA
1 Devicen - O i r e. c t *0 3
1 /. I don't reccIl v. b e t h e r J re ad the entire !
2 thing. I re d po rt t of it. !
3 C Did you read the sentence r e a ding, " V.' i t h -
4 out improvement in thie aret, hetu's c o n ti nu e d 5 c c cignment ar a rupervitor wocid not be appropriate" ?
6 .
I don't r e ca ll whethe r I did. I don't thinh 7 I did.
8 C L e t 's m t. r k t h i s as the fi r s t Exhibit to Mr.
9 D avir on ' t D e po sition, pleasc.
10 ( W h e r e u p on, the d ocume nt re-11 f erred to es typewritten noter, Pages 12 One and Two, were marked an d re-13 ceived by the Court R e porter te j 14 D a vi r o n Exhibit One e. n d entered into 15 the R e co rd. )
16 17 '
.3 Y MR. G UI LD :
18 Q W h :. t had Vr. Roer' previous e vnlu a ti o n 19 been prior to th e documents that a p p e r. r before us, 20 M r. D avic on ?
21 A Hi c- e vtluc tion immediately previous to -thi,r 22 wee fair, 1:. i s evaluation before that vi a s . - I a m -r elyi rig 23 on rn y memo ry here, competent.
24 A nd as I r e c c il, the oner I looked at pre-25 viou s'_ t o that, they were c om pe te n t.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERylCE, CHARLOTTE. 9eORTM CAROLateA
Deviron - Direct 31 1 O Y. h a t cate;ory ic f air ?
2 A T' c i r on a numericcl r c z. l e one to five ic 3 c two, :t indicatec there is come improvement neede d.
4 O And when wac that, the f e. i r evaluation, 5 pc rformed ?
6 A V.hich one t. r e you ref e r ring to; the one 7 before this one ?
l l
l 8 Q Yes, the fir s t , if I remember ?
9 A l T h t. t would have been in A p ril of, let's 10 ree, let me make sure I get my datos right, this 11 w ou ld h r.v e b e en in A p r il of '03; so A p ril of '82. I t
12 1 O Now I'v e seen s o me references to a p e rio di c j 13 f r e- e valu atio n more f r a que ntly than a year. H elp me 14 underett.nd, :t r. D avic on, what those refer to and 15 how they c ome about.
16 A Chay, under the P hip P ro gra m ther e are 17 periodic reviews scheduled. Vi e conduct them eve ry 18 four monthe, ts I r e c t 11, but with the im ple m en ta tio n 19 in October there were reheduled review periods set oo because we were in the middle of an evaluation pe riod .
al C I m i s c e d t h :. t i t- s t point. They were r. o t oo cvery four m o r.t h s ?
23 A V/ ell, when y o u ' i m p i c m r. n t the prog ram you "4
cay we will hcve p e rio dic r e vi ew s every four months.
25 If you c. r e within f our er five months, you may do the EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTM CAmouMA
? avis on - Direct 32 I e vcluution ra;her tht.n htving periodic re view in i
o o e t w e e. r. t ,.t c. t .
3 You have to acjust thtt schedule.
4 Q .i o w w c u l d t h t. t effect :u r . Rots?
5 A I would have to look ut my sheet thrt says 6
if you i n.ple m e n t here you conduct the e v n l u s. t i o n .
7 To my kn owle d g e he did not have a periodic review 8
in October from the implementation of P hi ? until 9
his evtluation in O c tob e r.
10 Q That would have been his annual r c view ?
11 A His c. n n u a l r evie w.
12 g yn j, p r i l of '83?
13 3 ye,,
I4 Q So wh a t p eriodic r evie ws has Mr. Rocs had ,
r 15 t if you know ?
l 16 s ., c h r. s h c. d t h e r e vie w that hi r . /> 11 u m held i
7
)! with him on that note.where he indicated it. 1/26/S3; 18 and ths.t is the only one that I' m aware of that is 13 d o c umen t e d.
20 Id r . 1.11 u m has certainly discussed Mr.
- 1
~
noss' performance with him thr ou ghout t h e ' y e a. r .
oo
~~
Q TEct p e rio dic review s wea that purcuent 93
~
to the PMP?
94 af t er. the P M P.
N o, A that wa s il e w s. s 25 s ta r te d before the PMP wcut into effect, evatv'n manoen associares. sismorves aeronimo sanvice. cuantorm. nonen canotma
Dtvicon - Direct 33 1 Q Mco .: r . r o t r. had a p eriodic r e v i e w c i r.c o 2 hic mo r t recent c. n n u s.1 c valu a ti c a ?
3 A I! o , not to my kno wle d g e.
4 Q 'i. h e n is the next one due?
5 A It would be July, I b eli e v e, four monthe 6 pact the e valu a tio n.
7 Q New help me, if you can, hr. D a vi s o n ,
8 put come of these obj e c tiv e measures in rome per-9 s pe c tive.
10 Within your k nowle d g e , let': say within the 11 Cuality accurance D epa rt me n t, what is the s i g nific a n c e 12 of a competent r e. t i n g for a percon that is at M r.
13 Roes' s up e r vi s o r I cvel ?
14 A Si g nific a n c e of competent would mean that 15 th e employce is p e rf o r min g s ati e f ac to rily in that 16 p o s ition.
17 Q Eow, in sf o u r u n d e r s t a n di n g , would that 18 compare to the evaluation p e rf o r ma nc e of others at 19 L: r . Ross' c up e r vi s o r level?
20 7,m not cure I understand your qu e s tion.
3 91 Q Let me see if I can s.c h it simply. Would 00 ~
others in hic s u p e rvi s o ry level have higher o r lower 93 r a tin g c t h :.n c ompetent ?
04 A Thcy c o u l d h e, v e , yet.
o.5 Q Do they in your - exp e rien c e ; that is w h a't I a v a tvu . . ...ociar... .r ~orv,. .ri . ...vic.. ca.. ton.. c .ou .
D avis on - Direct 34 1 want to understand?
2 A Do they have higher and lov e r r a t i r. g s than 3 com pe te nt; yer.
4 O Help me understand ve h o har s. higher ratin g 5 than competent in supervisory po c itio n s in the Qu alit /
6 A s s uranc e Department.
7 A Here again, this is done each year and the 8
rating may change f rom year to year.
9 Q Yes, sir.
10 MR. GIBSON: Excuse me, Mr. Guild.
11 A re you asking about s pe cific name s of 12 individuals and their s p e cific r a. t i n g s ?
13 IA R . G UIL D : Yes.
14 MR. GIBSON: I vrill instruct him not 15 to give a name and anybody's individual 16 r atin g.
17 Those r a tin g s are c o nfi d e n t. If you 18 give an example, perhaps we can . work out 19 some sort of reference ccheme so that if 20 you later determine you want the names we 23 can ti e it back to some f ormat to day.
22 But I think the s p e cific, John Doe wa s 1
23 rated "X", was confident, and we will l 24 in s truct him not to re veal th a t information . l 25 EVELVN SERGER ASSOCIATES STENOTYPE REPORTING SE RytCE. CHARLOTTE h0RTH CAROLINA
D a vis on - Direct 35 1 BY MR. G UI L D :
2 O VJhat is Mr. A rt Allu m 's rating ?
3 MR. GI5 EON: I will in c t ruct him not 4 to give you people's o p e c ific ratings; but 5 in terms of tr yin g to get the inf o rmatio n 6 in the Record, if you want to have us keep 7 track among ourselves of who he was re-8 f e rrin g to if he uses an initini o r le tter.
9 MR. GUILD: C ouns el, for consistenc y's 10 sake wit h Mr. A llu m we went through the 11 e nti r e list of Welding In s pe c to r e under M r.
12 Ross' e up e r vi c io n; and he at least appeared 13 to be responcive to that que s tion to the be at 14 of his kno wl e d g e , I a s sume.
15 MR. GIBSON: It is my understanding 16 Mr. Allum gave a certain rating o r opinior.
17 about a person's performance; and I have 18 no p r oble m with your asking about that.
19 Sut I'm t al ki n g about the s p e c ifi c 20 rating given in their written pe rf ormance 21 appraisal.
22 MR. GUILD: Counccl. I think juct 23 for clarity, my qu e r tio n to Mr. A llu m was 24 fi r s t of a ll, yes, what was his opinion; 25 secondly, what was the -ratin g af ter having EVELYN BERCER ASSOCIATES. STENOTYP, REPORTING SERVICE, CMARLOTTE. NORTH CAROLINA
36 1 c c t a bli s h e d that the rating ccale included 2 c ompe tent.
3 And juct for the Record. I b eli e v e he 4 told me all of the Vc c i d i n g Ins p ec to r s of 5 who m I asked were rated competent until 6 he got to Mr. Ross.
7 And we talked about his r a tin g. The S intention and my understanding of his 9 response was directed at the evaluation and to produced the r atin g competent in all cases ,
11 or ma r gin al was the answer with respect 12 to Mr. Ross.
13 MR. GIBSON: You are talking about 14 a diff er ent system in your D e p o s iti o n of 15 Mr. Allum.
16 You are talking about the system for 17 non-exempt e mployee s; and we diff e r and I 18 guess the R e c o r d u 111 re fle c t what he said.
19 Sut in terms of wheth e r he was talkir g 20 ab o ut t h' e s p e cifi c r a ti n g to the e xt e nt you 2I want to ack Mr. D a vis on ebout tho s e state-22 ~
mente, non-exempt e mplo yc e s , we will givt 23 hic opinion and r e c olle c tio n of the rating.
24
! But talking about exempt s up e rvis or y 25 e mployce s and their specific r ating. in the eveom .....a .ssociares. sva ones ..o tmo su=vica. ewa cons. ~onts ca ou~a
37 1 PMF P ro g ra m, we t'ill not have him give 2 you th at inf orm tion durinE the D e p o c itio n.
3 MR. G UI L D : There were supervisory 4 c mploye e s , one, at least, Mr. R o s o; and 5 Mr. A llu m did state what Mr. Rocs' r a tin g 6 was.
7 Counsel, the point of this is the 8 c r e dibility of a nu m b e r of the people we 9 were talking about are likely to be Wit.
10 nesser le this proceeding is m at e rial; m. n d 11 that c r e di bilit y qu e c tio n, which the Board 12 ears le one issue it in te n d s to address, is 13 s om ethin g we b e li e v e we are o bli g a t e d to 14 pursue in Diccovery in order to understand 15 our claim m or e - fully and your defense.
16 I don't know how we can proceed, I 17 c e r t ainly want to respect the privacy of 18 employe e s, but I think it has to be elicite d.
19 MR. GIDSON: W e wo uld be willi n g to 20 work out some key system co if the Board 21 determines yer, you are entitled to those 22 name c, then it would be a matter of giving 23 you the k e y.
24 If yo u want to give.us the list of 25 names you want to use, we will develop a EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE. CHARLOTTE. NORTH CAROUNA
- , 35 1 hey cystem and go through it; but absent 2 that, we will not give you the r p e cifi c 3 rating for s u p e r vi s o r e durin g the D e p o s itio n.
4 I am propocing t h r. t for g e ttin g the 5 in f o rm a ti o n in the Record, a nd you c c. n 6 apply the key system to what he said.
7 MR. GUILD: T ha t would be our 8 request. I won't p ull it out of hi r . D avic o's 9 if there is a better way to do it.
I 10 If you want to gather that info rma tion )
l 11 and key it, that would be u c ciul.
12 MR. GISSON: Arc you s a yi n g we .
13 could ju s t have that or I am trying to 14 determine how it will impact your qu c e tio n s l 15
- e. t this point.
I 16 MR. GUILD: What I intend to do over 17 the face of your instructions to Mr. D r. vi s on 18 not to answer e p ecific qu e s tion s about the 19 r a ti n g of e m plo ye e s. I will ~n o t e my positio n 20 to the contrary; but I would intond to ask 21 Mr. Davicon q ue s tio n s about the work per-22 '
formance of va riou s e mplo ye e s and then on 23 th e point of th e c p e cific e valu a tio n s of 24 various Duke p e rsonnel who are likely to b e 25 Witne e s e r, I w o uld ask that you, 'you know ,
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SE RVICE. CNARLOTTE. NOENTH CAROUNA
D a vi s on - Direct 39 1 find that inf o rma tion and propoec a syctem 2 cf coding that ettemptn to recerve your 3 pocition on their c o n fi d e nc e s .
4 -
UR. GISSON: So you nre c omf o rtablo 5 with proceeding with r e s e r vin g the right
- 6- - to request that inf o r ma tion at some later 7 tim e ?
8 MR. GUILD: Yes, to the extent that 9
I am unabic to examine this Witne s s on
. 10 that s p e cific point, I would reserve any 11 .
rirhts wit h respect to pursuing those lines 12 vii t h hi r . D avi s on.
13 MR. GIBSON: Let's go ahead and see 14 if we run into a problem with s ome thing -
15 s pe cific ally.
16 MR. GUILD: Okay.
17 18 BY M R. GUILD:
19 O M r. D avis on, who holds the positions that 20 are at the ~ c am e su pe rvic ory level with M r. Ross in 21 Quality 'A s s u r a nc e De partm ent at Catawba ?
22 A There are a bou t 12. o r 13 Su pe r vi t o ry 23 T e c hnician s._
24 O Who 'a re they, sir?
25 A Do you want them by name ?
EVELYM SERGER ASSOCIATES. STENOTYPE REPORT;NG SERylCE. CHARLOTTE. NORTH CAROUNA T -
1
Davison -
Direct , ,
40 t )
1 Q Yee, sir. Name and thei r d ep a) e nt or 2 their title to the e s:t e r t tNet their titler would come.
3 into their d epartm ent s.
4 A 3 enu R o c a, of cour c e, in Welding. ' Bob 1
5 H a r ri e, W elding; S ta nley L e dfo rd --
6 Q Slow down; I'm trying to write the s e. down.
7 Bob H a r ri s ,in Welding ?
8 A Yes.
9 Q S t a n l e y L e d f o r d', Welding ?
10 A Hap. H-A-?, tha t is his nickname; I think 11 it is W. S. Eif f or d.
12 O' S-I-F-F-O-R-D?
13 A (Yes. i t
14 Q s Vkat area is Mr. Siff o rd ? s
(
1 1
15 A ,
W e l di n'g ; E f 11., D e s t o n . W eldin g; Ray P ettit, o
16 Q t! o w do you spell his Icet name?
- l 1
17 A p E -T - T -I- T ; N ond e s t ru ctive Exa mina tion, !
18 NDE. Dougla s Cabe--
I N. s 19 Q C;A-B-E? '
20 A Yes No nd e s truc tiv e Examination. Ray
>. -\
i.
, y .
21 n c ... U n g , 23 a O - W - L - I - N - G , 'E l e c t ric ai: Jnch C a d d e ll','
~1 22 Elcetrical. '
23 '
nichard Payne-- 3+
24 o sh e'll that. -
7.A.y_N_g, p.y, p. .,
25 .A :h t yij ,] Si m T u r n e r . ' hi e c h a n i c al; EVELYN SERGER ASSOCIATES. STENOfvPE REPORTING SERytCE CHARLO . ONM CAROUNA
D a vis o n - Direct 41 1 C. F. . Ecr. don, D-E-A-R-D-O-N.
m~
oI i 2 O '!r that "C" or "D"?
3 A "C". Joe C ole man, U. c c h t. n i c s 1.
I 4 Q 3er.rdon vt a n Mechanical?
- s. 5 A Yes, I b elieve thr.t ic all there is.
7 4
6 Q W ho cic e holda the po s ition at the equiva.
7-- lent rupervisory Icvel to Mr. Allum under Mr. A 11 u r.9 's 8 precent p o r i t i o n r. s o f ye s t e r da y, I gue s c. in the QA
.1 9 Department ct Catawba, sir ?
10 A Okay, C ha rl e s Deldwin until t o da y.
11 O He just changed joba today ?
12 A Yes.
1 13 Q A nd his job as of yesterday wcs what?
14 - A He worked in the W e lding N onde c t ru ctive 15 E xa mi n a ti o n area.
I
~1N Q W elding cnd N o n d c. c t r u c t i v e E ::a min a ti o n IP area?
18 A y 'c c ,
19 .O V/hc.t war Mr. A 11u m ' e titl e .a c of yecter.
20 ' day?
21 s . A T echnic:1 Supe rvis o r, -a n dL he'. r emain s 'a t p 1 22 that r ame . titl e. '
. 23 C. And the p c'o p l e , - U r . Ross and .th e ct her
' .24 names t ha t yo u-!ju s t- g a v e , . t h e y En r e S u p e r vi cin g 25
, Technicianc; i a ' t h r. t right?
EVELVN SERGER ASSOCaATES. STENOTYPE REPORTING SE RvlCE. CHARLOTTE. h0RTM CAROLINA
,l n - '.
.,e..
D avis on - DArocB 47 1- A Yec.
2 O Who elc e helde the pocition T e c h n i c t.1 l 3 S up e r vi s o r, or whatever cice vas of equivalent 4 r e s po n s ibili ty to M r. Allu m ?
5 A Tred Eulgin. E - U - L - G -I- N . He will be 6 in the W eldin g NDE area.
7 O W ill b e or is?
8 A W ell, he ic; he transf e rred f rom M c G ui r e 9 a couple weeks ago.
10 Q Others?
11 A Cha rle s Bridwin.
12 O W e l di n g. NDE area?
13 A Yes, John W a r re n.
14 O What area is he in ?
15 A Electrical and Civil. .
16 2 Just thoac four ?
17 A Yes.
18 MR. GI DS O N: Excuse me, did you 19 include Allum in the four?
20 MR. G UI L D : 'I have Allum, Bulgin, 21 W a. r r e n 'a n d - - r i g h t .
22 '
23 GUILD:
EY MR.
24 O Mr. 11al d wi n is in th e W elding an d- NDE 25 area?
evetvu senosa associares. svanorrea aero=ri== suavies. c morra.aom caaou=4 l
D avi c on - Direct 43 1 / Ycr.
2 G Mr. D t v i c c. n . what it your o p i r. i o n of the 3 work pe rf ormcnc e by .\; r . Art A llu rn ?
4 A I think it la c atis f ac to r y.
5 C Is that r e fle c tin g a competent job 6 performance ?
7 MR. GIBSON: 1ir. Guild, we are de-8 f e a tin g the purpoce of my in c t ruc tion c 9 c a rli e r if you vzill ack tha t que stion of 10 e ach one.
11 You can ach if hit opinion directly 12 corresponds to one of th e r a tin g e . I will 13 ask him not to answer the second or third 14 que c tion.
15 He can give his opinion about c ati e-16 fcetory if the Board co rulee to give you 17 that.
18 Without g oin g through the Bo a rd, we 19 will not give you those ratingc; but ~ now I 20 will not let him answer that e p e cific 21 que s tion with respect to th e c e ' Individuals .
22 '
If yo u want to note- you r po r itio n and 23 r ave tim e, we c e. n :n o v e f o rwn r d.
24 i
25 BY.MR. GUILD:
aveovu eamean associAres. sta=Orves naroarino saavice. cMaaLOTTE. NORTH CAROLINA
Dr_viron - Direct 44 1 C How c'. o you mean s a ti cit e to ry ?
2 A That their performance is e r. t i e f a c t o r y ;
3 there m ay be room for improvement in one r p e c ifi c 4 area, b ut everril they cre r ati e f c e to ry.
5 Q Io there room for im pr ovem e nt ?
6 is U su ally mo s t people have room for improve -
7 m e nt.
8 O How about M r. A ll u m ; in what area?
9 /s I think perhaps in the t.rea of c o m mu ni-10 cations.
11 Q What does that mean ?
12 is That means his c o mmu ni c at! o n s with the 13 p e o ple that work for him.
14 O How about M r. Ross?
15 A O v e r a ll, s atis f a cto ry.
16 O I will get to t h r_ t , but Mr. A 11u m 's 17 communication with Mr. Ross?
18 A Yec. I think t h t. t is the r e sult of my 19 inve stig ation in the recource was there was room for 20 improvement there.
21 C Y'Ith Mr. Allu m' c c o m muni c a ti o n s with Mr.
22 Ross? ,
23 -A Yes.
24 O Hein me underrtand where that o pinio n is 25 r eflec te d in the re sult s of your inve s ti gation of the l l
EVELYN SERCER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROLINA 1
Davicon - Direct 45 1 recourcc, if you w o uld, ple t c e.
2 1. In the :. n t ve c r c I supplied to :<. r . Rose.
3 MR. GIDSON: I had it by date; I had 4 the document.
5 THE V/ I T N E S S : T hi s was a le tt e r 6 'from me to G. E. Rocs dated May 26, 7 19S3.
8 I s cy in th e r e that I think your feel-9 ings about thic r. p p r ai s c i s tem lar gely 10 from two items; the fi r s t item in the fact 11 that our exp e c ta tio n s from you in your 12 po r f tion were not communic cted to you 13 c l e r. r l y .
14 It la a 1cck of c o m m u n i c t. ti o n c I 15 ccccpt r e c p on sibilit y for. And I a.s k e d him 16 if he was c o m mu ni c h tin ;; c l e r- rl y with his 17 c up e r vis o r.
18 I think c o mmu nic ction s was n good 19 pcrt of that.
20 Q Tha t _ r efle ct: your f e e l i r- g e ohMr. 1.11u m ' s 21 need for c c mmunic atio n in reference t o . 2.t r . Looc?
22 A yeg, 23 IR. GUILD: - L e t 's m e.h c thic docu-24 '
ment r. c the t. c c o n d E :: hi b i t ' t o Mr. D t vi r o n 's 25 D c po sitio n.
EVELYN gEnGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROLINA
Lnvicon - Direct 46 1 MR. GIBSON: Ircuee :n e , Tob; why 2 don't I give you a r e; n rate act. VJ e may 3 run into the same p r obic m with thtt date.
4 I think th e copy the hac ic the only 5 one with the date. R e m e mbe r th e document 6 we dis cu s s e d e a rli e r, I think it ic Exhibit 7 One.
8 MR. GUILD: Yec.
9 MR. GIBSON: So I will- give you a 10 ccparate set, and you can ma rk that.- The 11 vi h o l e fi r r t li n e of that note I b e li e v e le 12 chopped off, so'you can get it f rom h e r.
' 13 As I unders tand it the Court Reporter 14 will keep any copy you hand to her now; ic 15 that correct?-
16 MR. G UILD : Yes.
17 ( W h e r eu p o n, the document .refe rr .
18 ed to as memo to G. E. Ross dated 19 Ma y 26, 1983, was ma rked and _ r ec eive d 20 by the Court R e po rt e r a s D a vi s o n i
21 E r. h i b i t Two c. n d entered int o the 22 Record.)
23 24 BY MR. GUILD:
25 G Mr. Orviron, I will show you_a document:
EVELTN SERGER ASSOCIATES, STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA 1
i D a vis on - Direct 47 l I
I can you id en ti fy tF ut one ( i n d i c t. t i n g ) ?
2 A Yer.
4 3 C Y hct le that, tir?
4 A T hi c ic a document that I produced ns an i
5 outline of the steps t h :. t I toch in inve s tiga ting Mr.
6 Ross' recource over hic evaluation.
7 ~Q Vihen did you prepare that outlin e ?
8 A **here 2 is a date on the back of it. I think.
9 5/26/83, it may be a couple days in the process.
10 Q Is that current as of the time of the letter 11 that you cent to h: r . Ross?
12 A Yco.
i 13 MR. GUILD: L e t 's mark that as the 14 third Exhibit.
15 (Whereupon, the document r e f e'r r ed 16 to as inv e c tig a tio n into recourse cub.
17 mitted to the Catawba _ Proj ect QA 18 Manage r by G. E. Ross tv a s marked 19 cnd received by the Court R eporte r 20 at D avi c o n Exhibit Three and entered 21 into th e Rccord.)
22 23 BY MR. GUILD:
24 O A ll right, air: there d ocume nt s that have 25 been id e nti fie d a c E x'ai bi t e Two and Three, your lette r.
EVELYN BERGER ASSOCIATEfs. STENOTYPE REPORTIMO SERvlCE. CHARLOTTE. NOsrTee CAROUNA 4
~
v
D avi r on - DArec9 43 I to Mr. Rore and the n o tc c, the o ut lin e , they r e fl e c te :!
2 your ccnduct of re vie w of
.r. Rons' recouroc undc 3 the E mplo y e e Recourre Procedure?
4 A Yec.
5 O What ctep in the recourse. procedure did 6 this r efle c t ?
7 A T hi s would b e in the CA D e p a. r t m e n t 8 recourse procedure, the cecond etcp. The fi r s t etcp 9 would be to, well, the fi r c t etcp would be discuscing 10 with the i m m e di c. t e c up e r vi c o r ; and the cecond step 11 wculd b e o r ally or in writin g with the Second Level 12 S u p e r vi s io n.
13 Then the Third Level Supervicion.
14 Q A ll right, this - wt c w h e. t step now?
15 A T hi c would be b a s ic all y the second step.
U 16 Q With the Second Level Super vicion ?
17 A W e ll, th e fi r s t step, which ic r e c.11 y 18 inf o r m al, is just the dis cus sion with the supervisor.
19 Q Thct wo uld be Mr. Allu m ?
! 20 A Yec, and th e r e c o n d ~ s t e. p in that rescrd 21 would be diccuccion or in .t r i t i n g to th e Second Level 22 S upe r vis c r, who would be Mr. Willic r. t thie point.
23 Q Did that occur i n -thi s ' c e. c e ?
24 g yc,,
25 r. n y written rocourcc to Mr.
C Y. a t there l
avrtvu menoan associavas. svamorves maeontmo senvice. cuantorra. Nonra camouma q I
I
i Davicon - Dircc8 49
=
l 1 v. Elli s ?
2 A Y( r.
3 Q Y tc there a v, r i t t e n responac by Mr. %illi 2?
4 A Ycc, 5 G Does that appear ?
6 A Yeg, 7
MR. GIESON: Excuse me, Mr. G uild, 8
if you need c. bout fi v e minutes, there is a 9 phone call I can return.
10 MR. G UIL D : Not unicas you want to 11 tche c break. L e t's move on and take it 12 in a hLlf hour or t. o .
13 14 SY MR. GUILD:
15 Q M r. Vi illi s, t h e n you; and what was the next 16 step in the Em ploy e e Recourse P rocedure ' f or Mr.
17 Rocs?
18 A Tha t w o uld be to the D e p t. r t m e n t Ficad;'in 19 this care Mr. Gricr.
20 '
Q Did M r. Rocc go to Mr. G ricr ?
23 a No, he h r_ c not.
22 Q W ell, hcip me u r.d c r a t c n d then what this 23 document r e fle c t c. Will you id e ntif y t hr.t -J o c um e nt
-94 (indic atin g) ?
25 ~
A T hit is c . r.s e m o t o file dated A pril 27 196 3.
5VELYN DERGER ASSOCIATES. STENOTYPE REPORTING SERWICE. CHARLOTTE. NORTN CAROUNA J
-l
D a vi c on - Direct .
50 i
i l
I rigned by ? r. G. Y. u r 2. c r .
2 C Ocec it refic:t a ec. c t t i :. i; on this subject i 3 v ith Mr. Ro e s ?
4 A Yer, thic ic c memo of the me etin g with 5
Seau Roce that la r . Cricr had.
6 L' R . GUILD: L o t 's mar k that one as 7
w e ll, please.
8
( w he r eupon, the document referr ed 9
to as memo to file from M r. Grier 10 dated I. p r i l 27, 1953, was marked and 11 received by the Court Reporter as 12 Dr.vlaan Exhibit Four and entered into 13 the R e c o rd. )
14 15 SY MR. GUILD:
16 O Help me understi-nd how this me e tin g betwe en II M r. Ross and Mr. G rie r, who is the supervisor level 18 above you azid to whom Mr. Ross would address the I9 n e:ct level of his r ecour r e; how doe s it fit into the 20 pureuit of Mr. Roca' recourse?
ol A M r. Rocc cubmitted the recourse to Joe no -
Willis in writing. Joe, of c o u r e,<. , inf o r me d me and 93 I inf ormed G eo r ge G rio r.
- 4 When Joc d e v elo p e d his answer to hi r . Ross ,
25 he went over that a n s w e :- with' 4 r . G r i e r ,- and id r .
EVELYN SERGER ASSOCIATE S. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
Davison - Direct 51 1 Grier scid, "If Beau would like to talk with me about 2 it, I would be glad to talk wit h hi m about it."
3 C is that consistent with the recource pro-4 cedure?
5 A I don't cee any incontistency there. The 6 recourse procedure do e s n't address that.
7 'C But Mr. Grier is th e one who would de cide 8 the next level of the recourse beyond you?~
9 A Yes.
10 C 3ut Mr. Grier is th e one who wo.uld de cid e '
11 the next level of the recourse beyond you?
12 A Yes.
13 C But he was involved in the fir s t step of 14 the recourse?
15 A He was made aware of it and w h e. t Mr.
16 Willi c ' cnewer would be; and he indicated if Beau 17 would like to talk with him a b o u t i t , he .would be glad 18 to do so.
19 Q And he did before you got the second level 20 recourse?
j 21 A Right.
l 22 Q So Mr. G rie r not only was i n volve d i n -
l 23 r e vie win g and being informec of the firct level l
24 r e s olu ti on, but he met with th e man who was pursuin g.
25 the recource between the fir s t and cecond stepc?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
D avi s on - Direct , 52 1 A YC6.
2 O And thet was consistent w i '. h the recourse 3 procedure in your o pinio n ?
4 A In m y o pinio n there is no inconsictency.
5 C 3eyond you where would Mr. Rose go?
6 A Beyond me he could recourse to Mr. G rie r .
7 C Eut he has already been to Mr. G rie r.
8 A He has had a di s c u s sio n with Mr. G rie r.
9 G What is the status of Mr. Ross' recourse 10 at this ti me ?
11 A It ic s e t tle d, as I underettnd it. Mr. Ror s 12 has not to my kno wl e d g e gone to Mr. G rie r in 13 recourse over this.
14 O A ll right, and does your letter to Mr.. Ros a 15 r e fl e c t f u ll y the terms of the c e ttle m e nt of his 16 recourse?
17 A It r e fle c t s my answer to his recourse; tha t 18 ir my l ett e r. If he were' not to accept that or not 19 be a n ti s fie d with that, he has the 'o p t i o n to go to Mr, 20 Grier.
21 O Does it reficct fully the terms of the 22 s ettle ment of Mr. Ross' re cou r ne ? '
23 A To my u nd e r e tan ding, yes.
24 O A ll ri g h t,- sir; let's return back to Mr.
25 A llu m . VJhen did you decide to transfer Mr. A llu m EWELYN BERGE R ASSOCIATES. STENOTYPE seEPORTING SERveCE. CHARLOTTE. NORTM CAROLINA
D avis on - Direct 53 1
to the Mechanical area, Mr. D avic on ?
2 A That would have bren about a month ago.
3 O A bout the fi r e t of June?
4 A S om e whe re in that ti n e frame, yes.
5 C D e t e rib e th e cir cu m s ta nc e s.
6 A Mr. W illi s , who was Ins pe ction Superin-7 tendent, was reassigned to the O pe r a ti on s D i vi s io n 8 of QA, which lef t a vacancy there.
9 Mr. Goodman, Jerry Goodman, who had bee n 10 the Second Level S u p e r vi sion of the M e chanical 11 Ir r p e ction area, was p ro mo te d to In s pe ction Superin-12 tendent, which left a vacancy there.
13 M r. A llu m was changed a s signme nt s to tako 14 the va cancy by Mr. Goodman when he moved in; and 15 ba s i c a ll y, Mr. Bulgin being transferred in from 16 I.! c G u i r e .
17 Q Yes?
18 A Mr. B ul gin being transferred in from 19 McGuire filled the o p e ni n g lef t by Mr. A llu m .
20 Q Does Mr. Ross now report to Mr. Bulgin ?
21 /- Yec.
22 C Was Mr. Rocs' recource and the circum- -
23 ctancer reflecte d in that recourse of-any ci g nifi c a nc e
( 24 in the t re n tf e r of Mr. A llum ?
l 15 - A No.
I tvrLyN manoan AssociATrs sTENOTYPE ntPontiNo SEpviCE. CHARLOTTE. NoRTM CAmoLINA l
D a vir o n - Direct ,
54 1 O # s r. Mr. A llu m 's _c o mm u nic a tio n s problem 2 of any s i g ni fic a n c e in his tra ns f e r ?
3 A No.
4 O /.11 right, cir; now let's go back through 5 the list now of the p e o ple at Mr. A llu m ' c 1cvel of 6 supervision.
7 We come to M r. Fred Bulgin; what is your 8 o pinio n as to Mr. Sulgin'c work?
9 A M r. Bulgin just tran sf e rred in to Catawba 10 June 13th, I believe. But my opinion of his pe rfor-11 mance is ca tis f a ctor y alto.
12 O What work did he do at M c Guir e ?
13 A Mc was a T e chnical Supervisor at M c Guir e 14 in the In s p e c tio n area also.
15 Q What part of the Ins pec tion area?
16 A He was primarily W eldin g and NDE. I 17 think as M cGuir e wound down he may have gotten 18 in to some other areas also.
19 Q What other arear?
20 A I wouldn't know for sure, as a number of 21 p e o pl e at Mc G ui r e, b e c a.u r, e of the c o m ple ti o n of the 22 plant go t c m alle r and s malle r, so as I remember the '
23 Technient Supervisors, as people got transferred out, 24 may involve-an area more t h a ri a s pe cific di s ciplin e .
25 Q Did he move o ut of Con s truction OA and EVELYN BERGER ASSOCIATE $. STENOTYPE REPORTING SERVICE CHARLOTTE. NORTM CAROUNA
D a vis on - Direct 55 1 into Opera tions ?
2 1. No.
3 Q D i c. his re s pon si bilit y expand into 4 C on c t r u c tion to include other c pecialtie s ?
5 1. M r. Eulgin it not in C o n s t ru ctio n. He is 6 in QA, but he is in the D e pa rtme nt of GA.
7 Q Con e t ruction ?
8 A Yes, it would have expanded; for e r. a m p l e ,
9 if he took over the Civil In s pe ction area also.
10 Q Hic work hi c to rically has been in the 11 Vi e l di n g and NDE area?
12 A Yes, 13 G Had ?d r . Sulgin supervised Welding 14 Inspectors prior to the r ecla s sifica tion of the W el dinj; 15 Inspector p o r,i t i o n s ?
16 A Now I'm just speaking from my rn e m o r y 17 here. I don't know Mr. 13 u l g i n ' t . e n tir e history. But 18 as I recall, he at one time superviced 'N e l d i n g 19 Inspectors, and as a S u p e r vi c in g T e c h n i c i r. n ; cnd as 20 a T e c h n i c t.1 Supervisor s u p e r vi s in g the Technical 21 Inspectors.
22
- e. u p e r v i c e d et nac C He would have - i . e .'
23 inspectore who performed welding s upervision ?
24 yeg, 3
25 Q Have you ever been awa r c -of c om pla ints EVELYN BE RGE R ASSOCIATES. STENOTYPE rep )RTING SE RvlCE. CHARLCFTTE. NORTM CAROUNA a
D a vis on - Direct ,,
56 1 of lack of qualific ation s on br. 1. l l u m ' s p.rt to 2 c u pe r vi c e Welding I n c p e c t o r t. ?
3 A Mr. R o c kh olt, I'm ri o t sure, I don't r e c all .
4 ." 11 that ic in his memo that 'f o u have a document 5 there.
6 That may have been something he said, I 7 don't r e membe r.
8 O It would be helpful if there are documents 9 that r efle ct that, Mr. Davison.
10 A W ell, we gave you a copy.
11 O Yes, but what I want to underrtand is what 12 you know, the stuff I have aircady or I can find out 13 because I have z. d o cume nt, I can dig for and will; 14 but what I want to understand is what you know and 15 are you aware of complaints regarding M r. A 11t m 's 16 tl u a lif i c a t i o n to supervise V. e l d i n g In s pe c tor s ?
17 A Mr. R o c kholt may have said s o m e t hin g 18 alon g those line s. I don't r e c all whether it is in 19 the memo or he said it v e r b ally; but I do n ' t r e c all 20 anything in writing.
21 T hr.t is not what I'm aching.
O Do you have 22 r. n y awarenece of anything written or oral, any 23 c om plaint e on t h e. t cubject?
24 A
- Other than if Mr. Ross m e n t i'o n e d in his 25 that would recourse and Mr. B ockholt in t h s. t le tt e r, EVELYN SERGER ASSOCIATES. STENOTTPE REPORTING SERVICE CHARLOTTE. NORTH CAROUNA
Daviron - Direct 57 1 be the only thing.
2 O A re you c. w a r e of any co mple int by Mr. Ro ss 3 concerning Mr. A 11u m 's qu alifi c a tio n s an W eldin g 4 Inepector? <
5 A It mcy have been part of his writt e n recou ese.
6 C If that would help to refresh your recol-7 le c tio n , pleace let's take a moment and look at those 8 r e c o u r e e ri .
9 MR. GIESON: This ia r. .s e t ( indicating).
10 MR. GUILD: Eure; if you want to sho w 11 it to the Witnec o thet would be great.
12 THE WITNESS: Not I d on't see any-13 thing in M r. Rost' recourse that would 14 ctate that.
15 C /.11 r i g h t , cir; does that help you remembe r 16 whe the r or not there is in tht.t document or in any 17 o the r form c:: p r e s s e d a c o m p l :. i n t or concern regard-18 ing Mr. A llum 's q u e. li fi c a t i o n s to supervise Welding 19 In e p e cto r c ?
20 A I can't re membe r clearly that but it seem s 21 li k e Mr. R o ckholt may h a v_e raid that or that may be 22 in his memo or hc c :: p r e s c e d t h r. t ' o p i n i o n . '
23 I'm not po sitive on that point.
24 Q Do you r e c a.11 ever looking into that- cu bje c t, 25 ever in v e s ti ga tin g concerns r e g r. r di n g Mr. t. l l u m ' c EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTH CAROLINA
l i
D a s ia an - Direct 58 l 1 qu alific a tion c ? ,
2 l- No.
3 C You never did ?
4 A No.
5 - f. l l right, cir; let me chow you a do cu m en t 6 that h e. s been identified ac, this is Exhibit 12, le t 's 7 see,~I don't r e c all whose De po citio n it goce to, to 8 t e ll you the truth.
9 Sir, do you recognize that ha n dw ritin g, 10 fi r s t (indic a tin g ) ?
11 A N ot for cure, no.
12 C A ll right, sir; it has been previourly.
13 id e nti fi e d by other Vl i t n e c c e s as the h a n d w r i tin g of 14 John B r ya nt.
15 Is .M r . Bryant a Welding In s pe cto r at 16 Catcwbc?
17 A Yes.
18 O Do you know Mr. Bryant ?
19 A YeE.
20 Q Have you ever o 'e c n that document bef or e ?
21 A I've not seen thir; I. b elie v e I might c o uld 22 recognize come of this perhrps cc.being pa rt of the l 23 Tack Force r e vi e w, i
24 G Yes, they r eview e d that subject in previous
(
25 t e c timony.
j It ic the handwritten notco of Mr. Bryant l
l EVELYN SERGER ASSOCIATES. STENOTYPE REPORTareo SERvlCE. CHARLOTTE. PeORTM CAROUNA l
l
D a vi s on - Direct ,,
59 1 concernin; some of hie concerne.
t 2 There z. r e othcro as well. I w :. . t to direc t 3 your attention a pe cifically to the third p a ;; c . Look 4 t. t it, it is k i r. d of below, there is a li n c .nd it is 5 w ri tt e n b elo w.
6 There is a paragraph, and would you read 7 for th e Record the several qu e s tion s that appear unde r 8 that?
9 A Below the line ?
10 Q Yec, eir.
11 A " V' h y w r. s C ha rle s E s. l d w i n removed as QC 12 V.elding Super vis or ? Ic A rt /.11 u m q u:. li f i e d to ef-13 f c c tiv ely oversee the OC In s p e ctio n P ro g r am ? "
l 14 " Y. h y w a s !2 eau Ross o ve rlooked for this 15 job po sition ? Should not Larry D a v i s o n t. n d Jim W e ll s le also be removed from their po sition s ? " -
17 " Y/ h y i s C on s t ru c tion involved in resolving l 18 the CC In a p e c to r s ' con ce rns ? C o n s t r uc tion caused 19 many of the con ce rn s. t hy do we have CA procedure s 20 and design d r a win g r e qui r e me nt s if C on s t ru ction and 21 OA upper management feel they can v e r bally override 22 them ? " '
23 " Vc h a t is the s i g ni fi c a n c e of a GC Vi e l d i n g 24 Inspector's jo b with Duke Power? W hy is it that 25 L eldin g and M echanical T e chnicians nre found to:have EVELYN BERGER ASSOctATES. STENOTYPE REPORTING SERvlCE CMARLOTTE. NORTM CAROUNA
D avis on - Direct 60 1 mor e re r pon cibility e. n d their c e r vic e n more v al u a bl e 2 to Duke than the W eld In s p e c to r e ? "
3 " Upper s u pe r vi sio n wants QC In s p e c to r s to 4 perform their jobe f rom truct for them and dis re gard 5 the QA procedures and s pe cific design re quir e me nt s. '
6 Q A ll right, sir; have you ever heard those 7 concerns expressed before in sub stance ?
8 A Parts of them may have shown up in the 9 Task Force report that I looked at.
10 Q M r. Davison, we have that document; but 11 have you ever heard those concerns other than throug h 12 r e a din g the Task Force r epo rt ?
13 A Maybe verbal di s cu s sio n s wit h these people 14 during this period of tim e. But othe r than that, no.
15 Q A ll right, let's see if we can address the m 16 in sequence. " Ve h y w a s C h a rle s B a ld wi n removed as 17 QC W eldin g Su pe rvis or ? "
18 A Because we felt like that Charles was havi ag 19 dif ficulty co mmu nica tin g with the people he super.
20 vised and was r e s po n sible for; and those people saw 21 C ha rle s as a block to c o mmuni c a tio n s .
22 V, e felt li k e if we. could remove that block '
23 then that wo uld be a good thing to do.
24 _ W ho are you referring to, who. f elt that Q
25 way?
EWELTN SERCER ASSOCIATF9. STEacOTTPE REPORTING SERytCE. CMARLOTTE. NORTH CAROLINA
Davison - Direct 61 l
l l
1 A I felt that way and I made th-t recommen- i 2 d a ti o n.
3 Q To whom ?
4 A To my bors at the time, Mr. W c ils .
5 O V. hen was he removed as QC %elding 6 Supervis or ? W ha t job was he a s s i gn e d ?
7 A He was still involved in Welding Non-8 d e s truc tive E x a min a tio n area.
9 O Took him out of supervising vi s u al inspec-10 tion and put him ove r in NDE?
11 A Yes.
12 O W hat was the source of the dis s atisf action 13 that you understood r e g a r di n g Mr. B aldwin ?
14 A W ell, as I perceived the situation the n, the 15 inspectors and people who had the concerns felt lik e 16 that Mr. Baldwin wa s s ome how blocking c o mmunic a tio ns 17 up and saw him as a block there; and I felt like to 18 make th a t change would do a great deal to open those 19 li ne s of c o mmunic a tio n .
20 Q To you?
21 A Or up the c h ai n .
22 O Was it to you? Is that shat you are referr -
23 ing to in part?
24 A Just in general, improve c o mmu nic ation s, M but up the chain, to o.
EVE LYN DE RGER ASSOCIATES, STENOTYPt REPORTING SERVICE. CHARLOTTE, NORTH CAROUNA
D avi s on - Direct 63 1 Q C om nunic ation s f rom \"elding Inspectors to 2 you, Larry Davis on ?
3 A In part; and to Bob Morgan and other p e o pl e, 4 C In a s pe cifi c, can you give me a s pe cific 5 of where those communications were, where you unde: -
6 stood them to be blocked ?
7 A N o, as s o me of the concerne r ef e r enc e d.
8 there v a. s a concern with C h a r le s . Some of the 9 concerne m e ntio ne d him by name and indicated they 10 did not think C h a rle s wa s lic te nin g to them.
11 C Was that change made as a r e s ult of the 12 expression of the V. c i d i n g Inspector concerns?
13 A B a s i c ally, yes.
14 Q A pp roxim a t ely wha t ' time was that made, if 15 you r e c all ?
16 A I don't r e c a ll; I b e li e v e it was in late 17 January.of 1982.
18 O One of the e a rli e r responses to the W eld-19 ing In c p ec to r concerns?
I 20 A yee, -
21 Q Before Mr. W e ll s lef t ?
22 A As I r e call it wrc c ha rtly befo re he le f t.
23 Q Before the Task Force issue that was filect 24 in the report?
M A Yes.
EWELYN BERGER ASSOCaATES STENOTYPE REPORTING SERVICE. CNARLOTTE NORTM CAROLsNA
Davison - Direct
, 63 1
Q A ll right, sir: "Is Art Allum q u alifi e d to 2 e f f e c tiv ely overece the GC In c pe c tion P r o g r e- m ? "
3 That is th e s u bj ec t progr am ?
4 A Yes, it is.
5 O You weren't aware of that que s tion ?
6 A I may have seen that in rome of the con-7 cerns and part of the Task Force.
8 Q W er e you aware of that concern on th e. pa r t 9 of M r. Er yant ?
10 A If it was expressed and I saw it as part 11 of the Tack ForceE I would have been aware of it.
12 C I appreciate that, but does that refresh 13 your r e c olle ction ?
14 A I don't r e c a ll Mr. Bryant ever speaking 15 that f a c tu ally to me.
16 C A re you aware that he held thht opinion or 17 others held that o pinio n ?
~
18 A Not other than seeing it in the Task Force .
19 O Is that in the Task Force report?
20 A I b e li e v e those concerns are part of what 21 the Task Force looked'into.
~
. 1 22 O H elp me understand where that is. I 23 fi n a ll y found m y. c opy of the EEV 3 of the W eldin g 94 In s pec to r Task Force report so that is what this is, i 25 T hi s is under a cover le tt e r of June 22nd, EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SE RVICE. CNARLOTTE. NORTH CAJ= OUNA
Davison - Dir ec t 64 i 1 and th e r e is rome correspondence that followc the 2 fi r e t couple pagen.
3 And then I think you get into the f i n t.1 4 revisions or the mo rt rec e nt r e vleio n of the Task 5 Force r e por t; and if you would take a look at that 6 report and help me find where it addresses concern 7 about Mr. A 11 u m ' s q u alifi c a tio n s (indic a tin g) .
8 A T hi s is the report of the Task Force that 9 looked into the technical concernc. There was also 10 a report on the non-technical concerns, and I believe 11 thct is where that would be.
12 R So that concern is not a te chnical c onc e rn 13 about M r. A 11u m 's qua lific a tion s ?
14 A T o my k n o wl e d g e it was not handled in'the 15 T echnic al Tank Force report.
16 C That is what I want to und e r s ta nd. Is you r 17 understanding that was not a technical concern?
18 A What was the concern a g ain ?
19 C Sure, it is the s econd qu es tion I think is 20 what we've got.
21 A The concern, "Is A rt Allum qu alifi e d to C. C In r p e c tio n P ro gr a m ? "
22 e f f e c tively oversee the I 23 think that ic.a decieion that has to be made by 24 management as to whether it le -o r no t.
25 It can be cla s sified a s tec hnical or EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE. CN ARLOTTE. NORTH CAROUNA
D a vis on -
D i_r o c t ,, 65 1 n o n - t e c h ni c 1.
2 C Oo you know how it wac cla s sifie d ?
3 A I b e li e v e non-technical.
4 C TJhere are the non-technical concerns?
5 H elp me understand th a t .
6 A Okay, I understand there is a non-technica l 7 concern document that deals with thore.
8 h: R . G UILD : C o u n s el, can you help 9 me; what doce that document look lik e ?
10 v. h a t is the nc n-te chnic al con ce rn ?
11 MR. GIBSON: Are you asking us to 12 find a copy now th at w r. s available during 13 Ditcovery?
14 Are you n a kin g uc to fi n d a copy to 15 make it a v a il s. b i c to the Witnes e ?
16 f.i n . G U I L D : Sure, but fir s t help me 17 find it; that is what I' m trying to do.
18 MR. GI B S O N: I' m not sure I unde r-19 stand what you mean by help you find it.
20 THE VI IT N E S S : I'm not sure that may 21 h e. v e _ b c e n in the t e chnic al or non-technical ;
22 I w o u l d h c. v e to loch at the v olu m e , the 23 c pe cific oner and go thr ou gh all of these 24 to be cure it is not in there.
25 h1 R . GUILD: Let'e d o ~it, hi r . D a vi s o n.
EVELYN SERGER ASSOCIATES. STENOTYPt RSPORTING SERylCE, CHARLOTTE. NORTH CAROLINA I
66 1 L et 's fi n d them.
2 MR. GIBSON: h! r . G uild. I have in 3 front of me th e no n- t e ch ni c a l Welding 4 In s p e c to r concerns whic h inc lu d e t h e h t. n d -
5 w ritt e n documente from the v a r i o u r.
6 inspectors.
7 This mcy be t h e. Inf o rm atio n you are 8 lookin g fo r.
9 MR. GUILD: A ll right, air; I am 10 lo okin g f o r, I guess, the fin din g s and 11 report, if that is what you have there that t
12 would be helpful if yod could show that to 13 the W itn e s s. '
14 MR. BELL: There has never been a 15 revision to this. T hi s is it thou gh, there 16 is no revision.
17 MR. GIBSON: Do you have the docu.
18 m e n t, Mr. G u ild ? -
19 MR. G U I L D. : .I ' m not sure.
20 MR. GIEFON: I have a copy I will .)
21 plac e - in , f ro nt o f t h e. Witn c e s . I b e li e v e 22 Ms. Garde has ~ide ntifi ed t h e c r. m c it e m. '
23 MR. GUILDi Let me just make cure, 24 the In c t thing lookr li k e a tr a nc e ript of l M- nockholt and Owen.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORYING SERVICE, CHARLOTTE. NORTH CAROLassA
67 I
1 That i t, about an inch thick.
s 2 MS, G A R DE: T hi s is the accond T e. c h 3 Force, third Task Force, tenth Task Force --
4 MR. GUILD: That appears to be draf t 5 one of a speech. Is there a cover letter 6 that you have to go with this?
7 MS. GARDE: Look on the next page, 8 that is wh e r e they are s ta rting; but they 9 have a dif f e r ent set.
10 MR. GUILD: L e t 's see, I think I 11 have an in c o m pl e t e set in front of me.
12 THE WITNESS: I don't see it li s t e d la here, this summary here (indicating).
14 MR. GUILD: First, I had what you 15 - have by date and title, and I will see if I 16 have it, too.
17 THE % IT NE SS: Looking at a March 18 24, 1982, le tte r to W. H. Owen f rom C e cil 19 _
Alexander, "In re, Non-technical W eldin g 20 In s p e c to r Con cerns. " and it says, "E nclo s e d 21 is a copy of those concerns."
22 MR. GUILD: What does that look likt ? l 23 THE WIT N E S S: It looks like this I 24 (indicating). It has a li s tin g of-the
'5
- inspectors-and apparently is a cross refere nce i mm . . ... . ...oc..: . .. .re ow.. .. o ri.. .. .vice. c..%one. ~o.m c. u..
D a vi s on - Direct 68 1 of this reference.
2 R. CUILD: O ha y. I think I.sm work -
3 ing do wn to that. It is -horiz ontal cheets 4 and it licts in s p e c to r s by name r. n d j t h e i r 5 concerno?
6 THE WITNESS: Yes.
7 8 BY MR. GUILD: -
9 Q Do you sae J. Brycnt'on that list?
10 A Yes. .
r ,
t !
11 Q And ini t it le d by that is th e code of Mr.
12 B ry a n t's name; what l's that?
13 A "D". ,
14 Q R eid what his;'c onc e rn s , a r e a s li s t e d . .
.' s 15 A Under q ua lifi $a tio n s , ",W b s told that he wan y ,
4, 16 over qualified for his j o b ' b'y J i m _V,l e l l s . " Under 5c.
17 r e s olu tion s,. " Ni s told that r e s olut s hon was not an 18 inspector c on c er n, " a n d- (t was sugge sted that he
~
19 r e s i g n e. n d t r i e d to make inspectore scapegoat to 20 '
NRC." ,a vt, 3
[y,. _ l : ' " :;
21 "Craf t sei.11' achs for di r e c tio n s ; NCIs 22 destroyed ve h e n p r e s e n t e d ' f o r SNs." And under harase -
,, , , n -
23 m en t, "Harasced."1 ,
.'y ,
24 Q Those a'r e a ll no n-t e chnic al concerns
+
4( . , _
25 in your opinion ? '
avetv ......... arms. sr ~orbe =acoarma seavica cwa = otra.=onra caaou * '
%' $ '*g :
D'a vi s on - Direct ,
69 1 A Yee. I think they would be non-technical.
2 I don't see the one here that you referred to; i: mcy 3 be in the Technical Tack Force report.
4 O Let'c look the r e, I wart to understand. Mr ,
5 D avis on, how the Task Force addresses the W elding 6 Inspector concerns, if they do.
7 And let's talk about this concern. "Is Art 8 A llu m qualifie d to ef f e c tiv ely oversee the QC In c p e c ti >n 9 Pro gram ? "
10 A I didn't know. I didn't prepare the s e docu-11 ments. I was not on the TLak Force.
12 O A re you f amiliar with them ?
13 A Yes.
14 Q A re you part responsible for implementing 15 any r ecommenda tions ?
16 A Ae a s signed to me.
17 Q j In your area of re s pon sibilit y ?
18 A Yec, 19 C A nd that includes su pe rvi cing Mr. Allv m ?
20 A yes, 21 Q A nd the W eldin g In s pec t o r s ?
22 A
~
In dire c tly, yes.
23 O If you need the time. -please take the time.
24 M r. D avi s on.
25 A I would like to see a copy of the technical avetvN ermotR AssOCiaTas sTENorvPs RaPORTING stRVICE CHARLOTTE. NORTH CAROWNA l
Davison - Direct 70 1 report.
2 O !. r e you cleer it is not in the non-technical ?
3 A Do you w r. n t me to go throuC hi I don't know .
4 Q Pic a c e take whatever time you need to so 5 we can have the Record clear on the subject. Y. h y 6 don't we do this: VJ h y don't wo take about ten minute ;
7 and perhapc the Witn e s s can uee a little bit of that 8 ti n. e to review the technical documents and r e vi e w the 9 non-technical documente; and perhaps we can id entif y 10 that concern.
11 (Whereupon, the Depocition was 12 adjourned at 10:04 and reconvened at 13 10 : 2 8 a . m. )
14 NR. GIBSON: Mr. G u ild. d u rin g the 15 break Mr. Davicon reviewed the non-techni':a1 16 documente c. n d the technical do cu ment e.
17 It z.ppears that the do cum ent you are 18 s howin g hi:n. whic h has some identification 19 in the Record already, is not a precise 20 document that was d ealt with by the V. e l d i n g; 21 Inspector Task Force, eith e r technical or 22 n on -t e chni c al.
23 It cppears this document or perhaps 24 others that you have to use in thin li n e of 25 qu e s tionin g were produced to you and EVELYN SERGER ASSOCaATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NO8tTH CAROUNA
Davison - Direct 71 1 identified on one of the four attachments 2 by a 1/12, letter.
3 It is my unde r e tending tho s e items 4 identifie d in those letters came f rom % c.1d-5 ing In s pec to r s after th e Task Force had l 6 c omplet ed th eir work, although there was 7 overlap as to which conce rns wer e treated.
8 The precise document that you are 9 looking f or was not available at the time tlie {
)
10 Task Force completed their work.
11 MR. G UILD : Thank you. .
12 13 BY MR. GUILD:
14 C is that your un d e r s ta ndin g, Mr. Davi s on ?
15 A Yes.
16 O A gain, the document that is id e ntifie d as 17 E xhibit 12 was id e n tifi e d by Mr. A llu m as Mr. Bryan t's 18 h a n dw ri tin g.
19 The que s tion I hnd pending. I guess befor e 20 the break, was whether or not that s pe ci fic concern 21 was addressed in eithe r the Technicci or N on- t e ch nic a l 22 Task Force r e po r t; and that is, "Js Art Allum q u c.li -
23 fled to e f f e c ti vely . o ve r s ee the QC In s p e c tio n P r o g r a rr ?"
24 A nd do I understand f rom C oun s el's i
25 in e p e c ti on it is not?
EVELYN BERGER ASSOC &ATES. STENOTYPE REPORTING SERytCE. CHARLOTTE. NORTH CAROLsNA
D a vis on . Direct 72 1 A 1 did not i d e ntif y eit h e r of tho s e document s .
2 C And you in r pe eted both of thoce dc cume nt e 3 during the break?
4 A Yes.
5 O What is your unde r e ta ndin g, sir, of the 6 circum e ttuc e s of when th i s document and the othe r 7 d oc um en t s that Counsel had reference to; that is th e 8 handwritten notes of the W eldin g Inspectors, that is 9 the one he had referred to ae being produced af ter 10 the Tack Force report--
11 W h r. t we re the circums tance s of the prept-12 ration and production of thoto documents ?
13 A As I understand it as part of Discovery.
14 we asked all our em ployce r to tu rn in any records i 15 they had of disputes with their mana gement or other 16 s up e r vi sio n.
17 It is my u n d e r s t s.n di n g thr.t would b e a 18 document produced then.
19 O A ll ' ri g h t , sir; let's see if we enn track it 20 down. Do you know where this document came f rom ?
21 A No, I~ don't. In fact, I have not ceen that 22 document befo re. I think come of the things on the r o-23 I may recognize from parts of the T r. r k F o r c e , 'but 24 I didn't see that d o c u m ent.
25 O H a vin g thought z. b o u t _ i t a. little bit over th e EVELYN WERGER ASSOCIATES. STENOTYPE REPORTING SERytCE. CHARLOTTE. NORTH CAROUNA
D avis on .
D i_r e c t ,,
75 1 break, you r. r e now c onfide nt jou have never socn thic l 2 document befo r e ?
3 A Not in that f o r m.
4 MR. G UIL D: Lo o ki n g through the fi l e ,
l 5 C oun s el, could you tell which r.t t a c h m e n t l
6 that document r e la t e s to?
l 7 MR. GIBSON: I can review the s pe cifi c l
l 8 attachment.
9 MR. GUILD: T ha t is what I'm do in g l
r 10 right now.
11 MR. GIBSON: V. o u l d y o u hand me a 12 copy of those, Mr. B e ll ?
\
13 MR. GUILD: It is my understanding 14 af te r conferring with M r. B ell th at A tta ch-7 15 ment Three has the fir s t of thos e docu-
, 16 mente; and in fact, looking at what is
! 17 attached to our Attachment Three, you 18 could have the same document.
19 MR. GUILD: What le the title on 20 Attachment Th ree ?
21 MR. GIBEON: "De c c rip tive Index of 22 Documente Produced in R es pons e to 23 Int e r ro ga to rie r 23 an.1 25 " parenthetical, J 24 close p a r e n t h e ti e r. l .
25 MR. GUILD: Okay, and thle p a r ticuir r EVELYN SERGER ASSOCIATES. STENOTTPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROUNA
74 1 d o c u :n e n t , do you have a better i d e n t ifi-2 cction of it, Councci?
3 I am jutt trying to find my Attachmen t ,
4 Three.
5 ( W he r eu po n, Mr. Guild found the 6 do cume nt he was s e a r c h i r. [. for at 7 10 : 3 5 a . m . , and the Deposition resum ed 8
as follows:)
9 MR. GUILD: Are these f rom the fil e 10 maintained by John Bryant?
11 MR. GIBSON: I b eli e v e that's correc';,
12 which nu mbe re d item are you r e f e r ring to ?
13 That is probably correct, I just wanted to 14 read it f rom here to if I can be more 15 a s c e r tiv e, Roman Num e r al III be ginning on 16 Page Two of Attr chment Three begins, 17
" Documents ootained from a file maintained 18 by Jack Bryant."
19 And the documente pertain to r e s olu ti ons 20 of QC issues and per s onnel _ matter s ; and it 21 is probably Item Five, Mr. G u il d , whic h 22 c ay e, " H e. n d w r i t t e n notes of Quality Contro: ,
23 iccuce in procent of b ein g r e c olv e d. "
24 MR. G UI LD : ' A ll right, cir.
25
-MR.
C I B S OII: But again, it could bc EVELYN SERGE R AS SOCIATES. STENOTYPE REPORTING BERvtCE. CHARLOTTE. NORTM CAROLINA
D avic os - Direct 75 1 onc of the o the r it e m t li s t e d. %e have to 1
2 go thr ou gh r r. d a c t u r. i l y compare to deter-3 ni i n e .
4 Also it is my undc r e tandin g thi.t that 5 s a me document shows up in hi r . Ross' it e m s 6 that were produced also.
7 8 dY MR. GUILD:
9 D c vi s o n, O My concern, h! r . is whether or 10 not the s e issues have been addreeced and reco1ved by 11 the Task Force, eith e r the T r.s k Force. V.elding 12 Inspector Tack Force that I understood addressed 13 technical concerns; is that correct?
14 A yeg, 15 Q Or by the process that purported to addres a 16 n on-te chnic t] concerns, that was not a process, that 17 was a Duke management te m ?
18 A B s i c all y, yes; I think that may have been 19 c all e d n N o n -t e c hnic al Task Force.
90 0 Or by some other meanc; and what I want 91 to underotc.nd is whether they were concerns that are oo r eficc t e d in documents that have been m r. d c a va ila bl e "3 '
to us th at zre pending or have not been addressed; 94 and is it your te s timony that this _q ue s tion, that 25 a ppa r e ntly c ome s from h r. B ryan t's noter as so EVELYN BERGER A$$0CIATES, $TENOTYPE REPORTING SERvlCE. CMARLOTTE. NORTH CAROUNA
D avi s on - Direct 76 1 id e nti fie d now is not addrected in eithe r of tho s e two 2 pieces of verk?
3 A I c o ul d not find it in either of thos e two 4 pieces of work. I wac not e. m e mbe r of the Task 5 Force.
6 C Right, I understand; how about the next 7 matte r, " V' h y was Beau Rose overlooked for this job 8 p o s ition ? "
9 Do you know whether that matter was 10 addressed?
11 A I do n't know wh e th e r that was addressed er 12 part of the Task Force.
13 C You a re not aware of wh e th e r they took up 14 that 1scue?
15 A Iam not aware of it.
16 Q V/ o u l d that be te chni cal o r non-te chnic a l ?
17 A That would be non-technical in my opinion.
18 C Do you know wh e th e r or not Mr. Ross was 19 considered f o r _ tha t oo zition ?
20 A N o, he w :. s n ' t considered because it was 21 not a. p ro mo tio n of anybody. It was just simply a 22 r e a c cignm e n t. -
23 0 E s s entially Mr. A llu m ind M r. B aldwin -
24 just s wi t c h e d p l e. c e s ; is that right, both w o rkin g in 25 W e l d i n' g and NDE?
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CMARLOTTE. NORTM CAROUNA u
D avi c on - Direct 77 I Would it have been appropriate to have i
2 considered Mr. Roco if t h e r e. vrv a vacancy in the 3 p o s, i t i o n that M r. 2.11um fille d ?
4 A If there wac a vacancy, we would cond der 5 probably a ll of the supervisore who had knowledge anil 6 experience in that area.
7 Q A nd he was one of tho s e ?
8 A Yes.
9 Q So it would have been consistent with Duke 10 p oli c y to consider him if there had been a vacancy?
11 A But th e r e wasn't a vacancy.
12 C And for that reason he wasn't considered?
r 13 A night.
14 O W ere you aware of that concern by W eldin g 15 In s p e c to r c , s a y V. c i d in g Inspectors or others in Mr.
16 R o sd cr ew ?
17 A I can't r e c all; somebody may have said 18 that to me at one time. I just d on 't r e c all s pe cific a lly.
19 O O ka y, "5hould not Larry D avis on and Jim 20 W ells als o be removed f rom their po sitio n s ? " Do yo u 1
21 know whether or not that concern wac addressed in 22 cith or the T ec hnic al or N o n- te chnic al Task Force ?
23 A I am not aware that it was. l l
24 Q Mr. W ells is not in that p o s i ti o n any more ;
25 is he?
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLO1TE. NOstTse CAROLINA
D avis on - Direct 78 1 A No, he le not in the position of Corporate 2 QA Manager.
3 Q He is wo r kin g for Duke Power Com pany ?
4 A Yec, I b e li e v e he is s till w o r kin g for Duke 5 Power C o m p an y.
6 Q What does he do?
7 A He is on temporary a s signment to INPO and 8 has been since February, 1982, to the best of my 9 r e c oll e c ti o n.
10 Q What does he do with INPO?
11 A I am not sure; I und e r s tand he works with 12 the Construction e v alu atio n portion of INPO.
13 Q In Quality Assurance?
14 A I don't know whether it w ould be te rmed 15 Quality Assurance or not.
~
16 Q But in any event he does not wor k -in Qualit y 17 A s s u r e.n c e for Duke Power?
18 A No.
19 O Is he on r el a tiv ely long term leave?
20 A I wouldn't say tha t; I think he is on tempo .
21 rary a s signme nt.
22 "
O In there a plan for him to come back this 23 year?
24 A Not that I' m- a w a r e o f.
25 Q Is there a plan fo r him to come back ac EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE, CMARLOTTE. NORTH CAROUNA I
Dcvison - Direct 79 3
Corporate CA Manager ?
(
2 A Not that I'm aware of.
3 Q He does not hold that po s itio n any more?
4 A No.
5 C B ut you do, you are still in the po sition yo u 6 were in at the tim e these concerns were rais ed ?
7 A B a c i c ally, yes; I have been located to the g C atawba site.
9 O You came to Corporate He a dqua rt e r s fo r 10 awhile and then went back to C atawba ?
11 A Right.
12 O Your po sition has r e main ed the same ?
I 13 A E s s entially, but when I was in Corporate 14 we had M c G uir e under co n s truc tio n, and I had 15 r e s pon s ibility there and Cherokee under very li mi t e d 16 r e s ponsibility the r e.
J 17 Q Chcrokee has been dis con tinued so there is 18 no QA going on there?
i 19 A We have some QA personnel at Cherokee.
20 Q What are they doing ?
21 MR. GIBSON: I don't see how this is 22 related to the scope of the D e p o s ition s at -
23 this point.
24 MR. GUILD: I am t r yin g to under-25 s tand Mr. D avis on 's r e s p on sibilitie s. I EVELYN bERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA
Davison . Direct 80
- want to know v.-h nt he ir doing and why his 2 position changed and if there are external 3 r en co n s or if it r e l t. t e d to his job perfor-4 mance.
5 MR. GI3 SON: Go r. h e a d .
6 THE WITNESS: We have about three 7 p e o ple there continuing with the QA Progra m a for Id en tific a tio n, Shipping and M aintenance 9 of Materials.
10 11 BY MR. G t: I L D :
12 Q To b a s i c a 11,- keep stuff and look after 13 equipment and materials so they can be dis po s e d of 14 at some later point?
15 A B a s i c all y. .
16 O A nd there is nothing going on at M c G uir e ,
17 there is no co n s t r u c tio n. QC?
18 A No, that's correct.
19 O When was th e C o n c t ru c tion QC e s s e nticily 20 c o m pl e t e d at M c Gui r e so I can understand the scope 21 of your dutic s ?
22 A It would have been very r e c e n tly, in the 23 past several month s when Mr. Bulgin and Mr. Sif f o rd
/
24 traneferred down from M cGuire to C a ta wb a.
25 Q Dut it is yo ur -te s timony that your po s ition EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROLINA
D avis on - Direct
_ , 81 1 and your r e sp on sibility tracked to the conciruction of 2 Cuality Centrol in C o n s t ru c tion with the c o mple tio n oj 3 M cGuir e and c an c e lla ti on of Cherokee and the remain .
4 der of focus of work at Catawb a ?
5 A S a c ic all y, yes. Now, of course, the posittor 6 Project QA Manager was a new po sition that did not 7 exist when I was QA Manager-Project.
8 O Okay, but you have main tain e d e c s entially 9 the same re s pon sibilit y that you had before ?
10 A E s s en tially except for C at awba .
11 Q Do you know whe the r or not any analysis 12 was made by either the Task Forces, the No n-t e c h nic t.1 13 or T echnical o r Duke management of the a p p r o p ria t e -
14 ness of maintainin g you in that po sition, Mr. D a vis on ?
15 A No, I do not.
l 16 Q You are act c.wnre of any ?
i 17 A No.
18 Q A ll ri ght, sir; do you know whether o r not 19 there are other concerns that are refle cted in the notes 20 of W elding In ape cto r s and others that were made 21 availabic to us that have not been addressed by eithe m
~
22 of the Tash Forcee?
23 A I believe some o f the docume nt s Mr. Ross i
I 24 tu rne d over in di ca t e d some n ot e s he had made on the 25 calendar; and I do not b e li e v e those were pa rt of the EVELYN SERGER ASSOCIATES STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROUNA
D avis on - D i r e. c t 82 1 Tack Force.
I 2 Q Have they been addrecced?
3 A I am in the procese of going over those 4 with Mr. T.oss in m a ki n g sure that he is e n ti c fi e d an i 5 doe s n't h r. v c an ou t s tan ding concern out of those.
6 C Doeg he have an outstanding concern out 7 of thoae?
8 A The ones we have gone over$ the re is no 9 ou t s t a ndin g concern. I haven't c om ple t e d that yet.
10 Q When did you begin th at ?
11 A Shortly af ter the documents were turned in o 12 come period of tim e, it would have been probably I
13 A pril or May of this year.
14 C Were tho s e concerns made known to the 15 Task Force?
16 A No. the 'i c s k Force vi a s n o n e s:i s t i n g,.
17 Q How about t o tho s e persons in Duke mant ge -
18 ment who were responsible for implementation of the W Task Force recommendations ?
20 A I made George G rie r aware 'o f the m.
21 C What did Mr. Grier do or say in response'i 22 A He in dic a t ed that we needed to go over 23 t h o r, e to see if any were outstanding or had not been 24 r e s olved to his s a tis f a ctio n.-
25 Q T h s. t is wh at you are doin g ?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTfMG SERylCE. CHARLOTTE, NORTM CAROLINA lb
D a vis on - Direct ,
83 1 A That is what I'm doing.
2 C He re"e you b a s ic ally the direction to do 3 what you were doin g ?
4 A Yer.
5 Q How about to Mr. B r adle y ?
6 A Did I make .'.i r . Eradley aware?
7 Q Yes.
8 A Not s p e cific ally th a t I re call; I may have 9 mentioned that to hi m, but I don't r e c all .
10 O Do you kn o w whether M r. B r adle y has been 11 made aware of those?
12 A I don't know.
13 Q Mr. B ra dley, you und e r s ta nd, is responsibl e 14 for imple m e nt a tio n of the Tack Force r e c om m en da tion s?
15 A Yca. responsible for the c oo rdin a tion.
IG Q A rc the re any other concerna that were l
17 ' i d e n ti fi e d in the a d d i ti o n t.1 documents that we re-18 id en tifie d in Dis cove ry ?
19 A Not that I'm awa re of.
20 Q Juct those reflected on Mr. Ross' calendar ?~
21 A Yec, and th e r e was one othe r item that I'm 22 aware of that was turned in by an Electrical '
13 Inepector, E rnie C ole.
24 Q How do you s p ell his'last name?
25 A- C-O-L.E.
' EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SSRvlCE. CHARLOTTE. NORTH CAROUNA '
D a vis on - Direct 64 1 Q Eave those been i d e n ti fi e d in Diccovery ano 2 ra n d e c. v a i l a bi c to your knowledge ?
3 A To my under s tan ding they have.
4 Q Do you know where thore do cum ent e are 5 id e ntifie d in the Dicc.overy Responses?
6 A Do I know if the y were?
7 Q Yes.
t
- 8 A No, I did not tu rn thore d e cuments over.
t 9 I turned tho se in when we asked all of our people to 10 turn in any documentation of conc erns that they had.
11 MR. GUILD: Just so we c a. n be clear ,
12 if Counsel could help me--is there a s
13 ref e r e nc e to Mr. Cole's concern?
14 MR. GISSON: It is rn y understanding 15 that is also en Att a c hm en t Three that we 16 talked about a few mome nt s t. g o . ;
i 17 MR. G UI LD: Fine. Now thtt is it 18
- then with the exception of Mr. Ro s s's 1
19 calendar and the concerns that are r e fl e c t e d 20 C ol e?
there and concerns i d e n t i fi e d f rom Mr.
21 THE WITNESS: Yes.
l 22 -
1 l
23 BY MR. GUILD: )
1 24 Q What are you do in g with :ir. C ol e 's. concer ns$
25 A I have talk e d with ' him ~about that. II e EVELYN BERGER ASSOCLATES. STENOTYPE REPORTING SERV 1CE. CHARLOTTE, NORTH CAROUNA
l Davis on - Eir ect 85 l 1 d o c u m e n t e. d that as being something that had occurred 2 and had been N C1' d, and the NCI had b a s i c c 11 7 handic 2 3 thc.t probicm.
4 Q To his s a tis fc etion ?
5 A Yes, he hac not c on tinue d on with that con-6 cern.
7 Q My qu e s tion is to his s atis f a ction ?
8 A You would have to ask him. It is my unde r-9 s tanding that he is s a tis fie d.
10 Q A ll ri gh t, sir; Mr. D a vi s o n, de s c ribe for 11 me, sir, how the procedures for h a n d li n g c o n c t ru c tion 12 d e fi cien cie s in the area of W elding have changed sinc e 13 the pe riod of time when the V. e l d i n g Inspectors ex-14 pressed their concerns.
15 L e t 's say since January of 1982.
16 , A O ka y, the procedurea change quit e f re-17 quentiy ne a matter of course. I am not sure I can 18 id e n tif y c p e cific ally what w s. s charged as a r e s ult of I
19 the Task Force, but h t. s i c a ll y one area th at has chang ed l
20 is the use of the R2A or Discrepancy Report for 21 Teciding In s pe c tio n dis c r e pa ncie s that has come into 22 use.
23 B a sically be f ore then that was not used in 24 that area.
25 Q Yihat was used before then?
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SE RVICE. CHARLOTTE. NORTM CAROUNA
D avic ea - Direct 86 1 A N CIc were the p rima r y means.
2 C Is that the mo s t s i g nifi c a nt change in.your 3 opinion that has occurred in tho s e procedures since 4 about January o f 19 8 2 7 5 A In those procedures, yes. Like I say, the re 6
have been revisions in tho s e procedures as part of an 7
o n g oin g p r o g ra m.
8 Q A ll ri gh t, sir; now explain ~to me why the 9
change was made that you have just referred to.
10 A R2 was a form that used to be en title d, 11
" Minor Diccrepancy R e p o r t . It was u s ed primarily 12 in M e chanic al wh en it was fi r s t developed.
13 As time went along in the We ldin g 14 Inspector Task Forc e, it was indicated th at we neede<1 15 to look at our methods for handling di s c r e p an ci e s ,
16 And it became apparent that the us e of such 17 a form was needed, and R2 was e s s e ntially r e vi s e d 18 to make that available for use in all the in s pec tion l
19 di s cip lin e n .
20 Q How was the f orm or procedure R2 used in 91 the M cchanical a r ea previously7 22 A It was used to document minor di s c r e pa nci e s.
23 Q Give me an example of a hardware item 94 th a t would be appropriately treated by using the R2?
25 3 7f hc was looking at a pipint conficuration.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE. CMARLOTTE. NORTM CAROLINA
D avi c on - Direct 87 I and note s that a long cut or e valve t r. g w t. c mi c s in g 2 or m a yb e a valve w e. r id entifi e d with c. w rong ta; . hc 3 would use R2 to document t h t. t .
4 C How about a con e t ruction deficiency in the 5 M e c ha nic al area; that would be a p p r o p ria t e in your 6 judgment previously for use of R2?
7 A I b elie v e that is just what I described, if 8 I unde r s tand you c o r r e c tly. Minor di c e re pancie s.
9 valves with wron g tage on them, maybe ille gible, 10 maybe the ta g is ille gibl e, maybe a long nut is misz-11 ing off a helted co nn e c tion, that type thing.
12 O A ll right, was a procedure R2 f o rme rly 13 expressly limite d to a M e cha nic al area?
14 A It was limited by reference from other
, 15 M echanic a l pro cedu r e s, Mc chanical proc edu re s refere nce
, w R2 and said to uce that.
17 Q. How about in e pe c tio n procedures in the 18 Me chanical a re a ?
19 A A gain, what is the qu e stio n, how have they 20 been changed?
21 Q No, did th ey reference R2 bef o re ?
A 22 Yec, before t h e y . v. o u l d rcierence, make a 23 reference to R 2 for h a nd lin g discrepancies.
24 C Did R2 limit itccif; was R 2' limited by its 25 terms to a Me ch anic al area?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROLINA L_
D a vic on - Dir e c t 88 1 !. No.
2 Q Sy the termo cf R2 _s p r e viou cly ctated, 3 would R2, w ould those terms be applicable in the 4 W e l d i n g a r e r. p r e viou sly ?
5 A It would have been used in th e W eldin g 6 area, but practice was not to use it. It developed 7 as pa rt of the M e c ha nical area.
8 It war u s e d primarily there.
9 Q A ny other areas?
10 A 1. s the Electrical trea had a form c a ll e d j 11 a Min o r Dicerepancy Report r. s part of one of its ,
1 i
12 procedurec, c. n d that came over to be used. l 13 E2 took the place of it s ome pe riod of tim e 14 ago.
15 Q Eut th e p r a c tic e was not to use it in the j i
l 16 W elding arca? '
17 A Yer, th e r e w t. s no equivalent to pr ac tic e 18 or usage of t h r. t .
19 Q V'hy w z. s , in your cpinion, there a need to 20 replace the use of NCIs by the R2A in the W eldin g 21 area?
22 A Ey using the N CI to document just about 23 every dicerepancy, it cr.used a larger nu mb e r of 24 N CI c to be w rit t en.
25 NCIs were treated with much higher level,
. .tva .u .a a .ociar... .r aerves a roarma . =vice. c=aterrt. acam caaou a
D a vi s o n - Direct
- 89 1 if you will, of involve ment of L lot of diff e rent 2 people; cnd the d e ficie ncic c thtt vc c r t. not major 3 d e ficien c i c e , that were minor in ncture, c ould be 4 handled without that.
5 Q W ha t p r o c edur al changcc in procecs con-6 trol with recpect to l'.' e l d in g h a v e bee n implemented 7 since about January of 1982?
8 A l' m not curc I could li c t all of tho se for 9 you.
10 Q How about id entifyin g ?
11 A To and M 4, that is two procedures that 12 have been replaced, th a t I know were revised and the y 13 were dealing with W elding process control.
14 Q I was going to mo dif y t h c. t que s tion and as i 15 you to id e n tify significcat changes in that area.
1G A Iam act aware of any cignificant changes 4
17 in that area.
18 C The changes in F9 and M4 are not s i g nifi -
19 . c a n t in your o pinion ?
20 A In my o pinio n.
21
, Q Whnt is a procedure F9?
22 A Procedure F9 ic the process control pro-23 cedure for welding and piping system c r e c tion.
24 C Saf e ty relate d ?
M A Y e s .-
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
D avis oa - Direet 90 1 C M4?
2 A It the inc p e c tion proc edur e f or wclding and 3 pi pin g c y t tc m c r e c tion.
4 Q S af ety r elated ?
4 5 A Yez, 6 O Ylhat procedure is used for the in s pe c tion 7 of c onduit ?
8 A That would b e an Ele c t ric al procedure.
9 Q Do you know what the procedure nu mb e r is "
10 A I' m not p o sitive, M40, M 41, one of those 11 two, I b elie ve .
12 Q How about tray hangers?
13 A Elcetrical cable tray hangers?
14 C Yee, sir.
15 A M 4 0, M 41; one of tho s e.
16 Q The same; have ei th e r of thoce procedurec. .
17 those fo r conduits and _ tray hangers, changed in any
~.
18 i signif1: ant way ?
M f. Not that I'm awcre of cr that I recall.
20 C You are aware of the change in the M4 21 .
procedure with re s pe ct to the use of accept reject by M th e inspe cto r to r e fl e c t c ons t ru c tio n deficie ncie e 23 initially detec ted in Vi c. l d i n g In c pe c tio n ?
f 24 A Are you talkin g ab ou t the .u s e of.an' accept 25 or reject block on the -form?
EVELYN BERGER ASSOCM*IS. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAROUNA
3 D avis on . Direct ,
91 1 Q 'Yes. ci r ,
t 2 A Yet, I em t. ware of come changes.
3 Q D e c e rib e those changes.
4 A As I r e c all at one time th o c e blocks were 5 on the f o r m. They were removed for ta p e rio d of
, 6 tim e and then they were added back on.
7 Q When were they on the form initially ?
8 A D at e s, I am not going to be able to tell 9 you.
10 Q A pp r o xi m a ti o n to the best of your 11 r e c oll e c tio n.
12 A I would say du rin g the e a rli e r changea at 13 Catawba they were there in the '76, '77 tim e frame.
14 Q Why were they removed?
15 A Part of a revision to the procedure. I'didn 't 16 revise that procedure. and I can't r e call all that wen t' 17 into that.
18 O You wo rke d with thr.t procedure then ?
19 A Yec, 20 Q Did you_cupervisa in s pecto r e _who were 21 c ::p e c t e d to f o llo w that procedure?
22- A Yec. '
23 Q That was c 'way of identifying 'c o n s t ru c ti o n 2
i 24 d efi ci en ci c e in 'weldin g ?
25 A That wac o n c _. w a y , yee.
.mv .. c. assoc .res. re orve == s==ica. c asons. o= caaou a
Da vis on o Cirect 92 i
O And in that c a pt cit y , do vou hcve any undc r-1 2 s tanding of wh y th e procedure w r. s changed?
3 A I can't r e c a ll, I know t h a. t that wcc dic-4 cusced very e xt e n ri vely at th at time. It was not a 5 fli P P r. n t de cision to do that; but I can't recall.
6 O You have no r e c olle c tio n of the basis for 7 that change?
g A No.
9 O How about the basis for th e change back..
10 th e subsequent change in M4 to include the accept-4 11 reject bio ch e ?
12 A A gain, I would not be able to tell you 13 that. Iam juct aware that that was done.
14 O You have no under standing of why it was 15 done?
16 A Not that I recall right off. ,
17 O A nd a g ai n, th a t use of that accept and 18 r ej e ct box, that is now part of p r o c e d u r e ' h* 4, is'a 19 method for Welding Inspectors to indicate conttrue:Lon 20 deficiencie s in welding ?
21 A It is a ma tter for the in spector to indicate 22 whether he hat accepted or rejected the item; t. n d I -
23 am not cure that ir on every s te p along the way.
24 I kn o w it is there for fin al visual 25 in s p e c tion.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROLINA
)
D a vi s on - Direct 93 1 Q Do you di c t g re e with my cha rac te ria a tion ?
2 !. Y ould you r e c t c t. c it for mc?
3 C Sure, is the use of that accept and reject 4 box on the .'s ' 4 , is the use of the M4 c method with 5 which Vi ci din g In c p e c t o r s can note a c o n s t ru c tion 6 d e fi ci e n c y identified in int pe c tion ?
7 A Yes, it would be a method to do that.
8 Q And when, to the best of your r e c o lle c tio n, 9 whtn was the M4 procedure most recently changed to 10 p r o vid e for the accept-reject?
11 A I can't give you a date on that.
12 Q Since January of 1982?
13 A I would think co; I' m not p o sitiv e about 14 that.
15 0 You don't r e c a ll ?
i le i
A No. 1 I
17 C A re there any equivalent process c o n tr ol 13 ! procedures equivalent to '/.4 such as the procedures 19l thet you've i d e n tifi e d for electrical c o n duit and tray 20 hangere and other eafety r elated area in c o n s t r u c tion 21 at C at awba ?
22 '
- 1. There a r e_ in s pe c tion procedures, yes.
23 R Do those inspection procedures include a 24 c imila r procere control procedure and form where 25 in s p e c to r s in thoce z. r e a s wo uld indicate their EVEwVN SERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE, CNARLOTTE. NORTN CAROUNA -
Davison - Direct 94 I acceptancc or r ej e c tio n by a box lihe the r c ic on the 2 L: 4 form?
3 A Eeme do and some do n ' t.
4 Q C an you t ell me which ones do n't ?
. 5 A Not without looking at all the procedures 6 I c o uldn ' t.
7 C Can you tell me whe th e r- o r not, just give 1
8 me for a judgment, if you can, do moet cafety r ela te d 9 in s p e c tion procedures have procecc control proc edure s 10 where the in cp e cto r can accept or reject where 11 c on s truc tion deficiencie s are id e n tifie d and provide fo r.
12 a c or r e c tio n ac a matter of procccc control?
13 A In gencral I would say that the y do n' t.
14
- The use of the R2 in Mechanical and Electricci area 15 would serve that f un ction.
36 O Thcre has been no significant c h s.n g e in th e 17 use of the E2 procedure in~the Mechanical and M lll E l e c t area r i cina this l period of t i m e 't 19 A No c ig nifi c a nt change.
~
20 Q Eut there has been - a s i g ni fi c a n t change in 21 the Velding crea?
22 A T he u tiliza tion o f "R 2 , . that procedure in '
23 ~
the Vi ci di n g _ area, yes. would cay that i c a signifi-c cant change.
" C Cive me a rcugh l'd e a , if you can, A* r .
EVELYN SERGER ASSOCIATES. STENOTYPE REPOATING SERylCE. CHARLOTTE, NORTM CAROLINA e
r' 3 ~
D cvit on - Direct
_ . 95 1 D t vic on, c. f - h o w many procedurer there t- r e thct are 2 s imila r to the M4 procedure in trenc ethcr than 3 ic1 ding.
4 1. I think thet may depend on what you menn 5 by " s imil c r to." /> 11 of ou r in cpe c tio n procedures are 6 ci mila r to one another, 7 Q Let me see if I can explain it this way:
8 I am i ntending in id entif ying other procedur es in othe r 9 areas than W e ld in g that are simila r to the M4 for 10 VJ e l d i n g .
11 I know thtt they, I know that minor die-12 crepcncies as y o u h s. v e been using that term are 13 identifiable other than by using a n on -c on f o r min g item 14 or an RZA.
15 /.
Y/ciding is a little bit unique in . tha t regarf 16 in thnt a lot o f V. e l d i n g In c p o e tio n s are done in p r o.-
17 cesc while the work is a c t u s11 y going o n.
18 Th:re are certain steps that are inspected 19 b ef o re you go on. You have hold points a t = which the 20 work has to be c om ple t e d and inepected before you 21 go on, 22 Me s t of th e procedures don't have 'tha t type '
23 of hold point or i n - p r o c c e r. In s pe c tio nc . Most of thes e
- 24 are donc af ter the work may be in s talled' and th e n it 25 is- inspected, to in that ce nc e, I 'w ould ray that most EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERylCE. CNARLOTTE. NORTH CAROLt.s4 6
m
4 Davicen - Direc8 3 96 1
of the other proceduies are not o irr.il a r to M4 end ;15 .
2 C That le a ri t n i f i c a r, t dif f e re n c e in th e 3 Yhl d i n g aren in y o.u r o pinio n ?
4 A Yec.
5 O And is t h'a t , s i g ni fi c a n t because in the 6 V.' e l d i n g area in yo u r , o pinion those min o r discrepancie s 7 that are identified in process are r e a dily c o r r e c tibl e 8 by the Craf tsmen ? ,
9 A U su ally that is the case because the.
10 in s p ec tion s occur du rin g the procers, and the Cr af ts-11 man is u c r ally right there while the in s p e ction is 12 g oin g on.
13 C Did I state that--
14 A Yee. I think you rtated t h at accurately.
15 C And i s , it fair to cay by comparison or 16 contrast in other areas the work would be not in 17 process and instead completed at that point where the 18 inspector would r e vi e w it and therefore minor dis-19 crepancier would be less r eadily c o r r e c tible by the 1
20 C raf t s man ? ,
,i 21 A The Craftcmen would not in most cases be 22 available right there<to do that. -
I 4 23 O So how would that c o rre c tion be -a c c o mpli s h-
, 4 24 ed? ,
i N
'If th e Crafrman were th e r e it. could be 25 I:
EVELYN SERGER ASSOCIATES. STENOTYPE REPOP NG SERVICE. CHARLOTTE. NOR*M CAROLINA
. t
, , , 'a
D avic on - Direct 97 1 a c c o m p l i t; h e d that w :. y , dc c um e nted in R2A. Ecme of 2 the other procedurce do provide forme to document 3 c o r re c tio n e.
4 O So I can understand thic in come pe re pectit c, 5 Mr. D avi s o n, wo ul d a cabic tray be an example of 6 a component whose i n s t alla ti o n would be r e vi e w e d upo rt 7 c om ple tio n ?
8 A S a c i c ally, yes.
9 O C an you i de ntif y procedure F13?
10 A I' m f a milia r with that numb e r; I would havo 11 to look at it, s
12 O I am not.
13 A I will have to look at it to identify it.
14 Q Does th a t reinte to the f ab rica tion or 15 in s talla tio n of cable trays?
16 A I would have to loch at it t. n d sec.
17 Q A ll ri gh t, cir; the not e s of Mr. Bryant tha t 18 were id en tifie d contain a reference on the fir s t page, 19 M r. Davison, to a date that ic 9/25/81.
20 One NCI o r ICI 16 2 - 2 7 C ou r then Clace A; 21 ie that an indication of a weld ?
22 A It sounde lik e it.
23 O YTould that be one NI?
24 A One NI would be the u n i t, o n e ' NI eyctem.
25 C V.' h a '. is' NI ar t tem ?
EVELYN DERGER ASSOCIATES. STENCTTPE REPORTING SERVICE. CHARLOTTE. NOGETH CAROUNA
D avis on - Direct 98 1 ! i. Safety Inj ec tio n.
2 C A ll r i ;; h t , sir; do you r e ca ll the incide nt i
3 ffor the pi e c e of work that is referenced the re ?
l 4
l A Yes, I r e c t.11 t h a t . I b e li e v e t h a t. ve a s one 5
of the weld s that was addressed by the Tnchnical 6
Task Force.
7 Q % ould you read now for the Record that 8
s ta t e m e nt dated 9/25/81, one NI 162, Class A?
9 A " W eld repair made on route side of w eld.
10 T he repair area is a pp ro xima t ely six feet f ro m the 11 open end of the pi p e . "
12 "I could not t z. k e a me anin gf ul in s pe c tio n 13 due to a c c e s sibilit y, " s o m e thin g in parentheses, I 14 can't make out what th at is.
15 "NRC instructed me to sign the final vi s u a l 16 a ny wa y. "
17 O Yes, de s c ribe that incident to me.
18 A I under stand that that was a pipe in the 19 NI system that had a r e p t.i r made to it on the route 20 side.
21 Q Route side ?
22 A Yes; and the inspector is referring to he 23 did not f e el he could conduct a m e a nin gf ul e x a mi n a -
24 ti o n of the route of that weld because it was approxi- -
25 mately seven feet up in th e run of the pipe.
EvtLYN $,BERGER CFFICI AL COURT REPORTER U. S. DISTRICT COURT CHARLOTTE, N. C.
D avis on - Direct 99 1 Q Y.' c r e you r. w a r e of that incident at that
\
2 time ?
3 A No.
4 Q Viere you aware of the r e c olu tion of that 5 incident?
6 A yes, 7 O How did you become aware of it ?
8 A It was one of the iteme in the Te chnic al 9 Tack Fcree report.
10 Q That is the fi r s t you became a w r. r e of it?
11 A ye,,
12 O Looking through documents 11/19, during i
la the time when that weld was pe rf o r me d, that is the 14 subject of 181, what was your r e s pon sibility for 15 r eviewin g or originating or r e s olvin g no n conf or ming 16 it e m s in the VJ c l di n g area, Mr. D a vis o n ?
17 A I did not pa rticipate in that at that time.
18 T ha t was when I was QA Manager at the project 19 located here in C ha rlo tt e.
20 Yes, Q sir; not with s p e cific reference to 21 that incident, what was your r e s pon sibility at that 22 t i in c ?
23 A There wac a Project QA Engineer at that
(
24 ti me, and he reported to me; and of c our c e he was 25 re s pon sible as w e ll as my o cif for the impicmentation EVELYN WERGER ASSOCIATES, STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
D avi s on - Direct , 100 1 of the OA Program, w hic h the NCI wac a part of that 2 p ro g r am.
3 O Did you at any point have r e s p on sibilit y fo r 4 o rigin atio n or review or r e s olu tio n of nonconforming 5 it e m s in W eldin g at Ca ta wba?
6 A Yes; when I was the Junior QC E n gin e e r 7 at Catawba, I had th e re s pon sibility for reviewing 8 QC nonconf o rmin g item s at o ri gin atio n.
9 Q When was that?
10 A That would have been f rom 19 7 4 t o Februar y 11 of 1981.
12 Q A nd that was the point where Mr. Bulgin t
13 then took re s p on sibility for that in s p e c tion ?
14 A B a s ic ally, yes.
15 O And he has that r e s pon sibility no w ?
16 A No, the procedure has changed.
17 Q So you no longer have tha.t r e s po n sibility ?
18 A T ha t's correct.
19 O Who does?
20 A There are about six people I b elie v e that 21 are authori=ed to r e vi e w and approve NCIe; and my-M o r ga n, 22 celf, Mr. Bob M o r gan, Joe Shropshire--
23 Q W alt a second, let me write those down.
24 O hn y, Mo r ga n--
I 25 A S h r o p s hi r e ; Ken Schmidt..
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE, NORTH CAROLINA
D avi s on - Direct 101 1
Q % ho is Mr. Sc hmid t ?
2 A A r s ocia te CA En gin e e r at Catawba.
3 C S p ell his last na me.
4 A E - C - H - M - I-D - T .
5 Q What is an A s s o cia te CA Engin ee r ?
6 A He is OA En gine e r at C a. t a w b a .
7 O Not A s s ociate ?
8 A No.
9 O That is four; who els e ?
10 A Mr. Tommy Barron. He is A s s ocia te QA 11 E n gin e e r. Mr. Je rry Goodman, who is the In s p e c tio n 12 Superintendent.
i 13 Q Now?
14 A No.
15 O And until to day ?
16 A That was Mr. Joe V.illis.
17 Q A ll right, and gene r ally how long had these 18 g entle m en or persons who have held their p o s itio n s 19 been responsible for the r e vi e w of the N CIs ? -
20 A All of those people have been reeponsible 21 in p erf o rming th at f u n c ti o n for come time.
22 O W ha t I want to under stand is you did it, ,
23 the n M r. Saldwin' did it af te r you. Then the ce .g enti e-f 24 men did it a f t e r _ M r. B s id win. Is that e s s en tially M the sequence?
evetvu seasia associates, stemorvre aeroarino scavice. cwantoTrs. Noars camou=
Dnvicon - Direct 102 1 A Let rn e e r. p l a i n ; when I did i t, it w e. c the 2 Senior E n gin e e r R e vie w. I was the Junior En gine e r, 3 okay; so I performed that r e s p on s ibilit y and did that 4 p r a c tic ally 'all the time for those o ri ginatin g the 5 in s p e c tion.
6 Q Say that again.
7 A I pe rf or med that r e s po n sibility p r a c ti c ally 8 for all of thos e originated by in s p e ction. W hen I 9 left Mr. B a ldwin and other Technical Supervisors 10 performed that f un c tio n; and the procedure got revise d 11 cnd e c c enticily e li min a t e d that r e vie w and ki c k e d it 12 over to the CA R e vie w; and these are the p eo ple who 1
13 do the CA R evie w now.
14 Q When would that change have taken place, 15 a p p r o m:i m a t e ly ?
16 A T hi s change li mi t e d it to those p e o ple.
17 T ha t occurred fairly r e c e n tly.
18 Q Within the last we e k or so?
19 A Within the last mo n th.
20 Q So before it was limited within the last 21 month to tho s e peo ple who do it, Baldwin--
M r. !
I 22 A No, let me go back to th e b e ginnin g again:
'I 23 When I was th er e there were three signatures on the 1
24 origination.
25 The re was o ri gina to r. It used to be Junio r EirELYN SERGER ASSOCIATES. STENOTYPE REPORTING SES , * ' E. CHARLOTTE. NORTM CAROUNA
D avir o n - Direct 103 1 E ngin ee r R e vi ew and QA R e vie w, the Senior Engin e e r 2 R e vi e w.
3 Q Let me get the time; this is '74 to '81?
4 1. '74 to '80 time period, and the Senior 5 E n gin e e r changed to T e chnic al R e vi ew, and that is 6 when Mr. B aldwin and the T e c hni c al Engine e r s per-7 formed that fu n c tio n; and that would have been in the 8 ti m e period '81.
9 Then th e procedure was r e vi e we d to e li mi-10 nate that review and put that f un c tio n under the QA 11 R e vie w; and tho s e people I juct named plus others 12 have been authorized to do that.
6 13 Q A nd that is very r e c en tly ?
14 A That is probably a year or two years. A 15 year, maybe a year, possibly. Then very r e c e n tly 16 it has been limited to just those people I named.
17 Q And were th ey named in the -procedure or 18 their title s ?
19 A No,- they are not named in the procedure.
20 O tiow is it li mit e d to the m as a matter of 21 pra ctice ?
22 A I is eue a letter that states that these are 23 the people autho rize d to do that.
24 Q So the terms of procedure of Q1 are not 25 changed to. do that, but your implementation of Q1 cvetv~ mensen associates. sve~ones aracarino suavies. cuantone. wo-rw caneuma
Davison - Direct 104 .
I would be wh at this written lett e r doec change?
2 1. Yea, Q1 har changed to that.
3 C You have made that authorization ?
4 A Yes.
5 Q A nd is that about a month--
6 /. About a m o n th.
7 O Okay, I want to underrtand, Mr. Davison, 8 the period of time that you did this r e vi e w when you 9 performed what you have described as the Senior 10 E n gin e e r R e vi e w.
11 L e t 's take it back from the time when you 12 came on the job at C a tawb a in '74. V. h e n c on e t ru ctio n
(
13 etarted in '75, how were construction deficiencies 14 in the W elding area fir s t identified and documented?
15 A They would be i d e n ti fi e d through the pro-16 cesc of in s pec tion, p rim a rily. Inspectors looked for 17 these things.
18 They could be r e s olved eithe r by c o r r e c tio n 19 to the ine pe ct o r 's n a ti s f a c tio n and therefore he s e ttle s 20 it, or he could write a nonconf o rming item on it.
21 O Okay, under the fi r s t r. l t e r n a t i v e , how wou ld 22 the original deficiency have been d o c um e n t e d ?
23 !. It would not have been documented on the 24 f o rm, i t s e lf. The acceptance of that particular 25 a ctivit y, whateve r wa s being inspected, would have b een EVELYN SERGE R ASSOCIATES. STENOTYPE REPORTING 'iERylCE. CHARLOTTE. NORTH CAmouNA
D a vis o n - Direct 105 1 documented.
2 Q So only the fi n a l acceptance was documente :17 3 A T ha t 's right.
4 Q A ll right, and then if the d e fic ie n c y, if 5 the second alt e r na tiv e were chosen, t h r. t is to write 6 an N C I, how would that occur?
7 A The in spe cto r would o rigin a te that NCI, tak e 8 the form, fill out the form and forward it up to the 9 persons to review it.
10 0 Who would that h r. v e been; who would have 11 fi r s t reviewed it?
12 A P rima rily during that period of tim e that L
13 w oul d have been m e.
14 Q Y ou would have been the fi r s t review at 15 th a t time ?
16 A Yes, they probably, no w they may have 17 talked with - th eir s u p e r vi s o r about it before they cam e 18 to me; but in a lot of cases they would come s'raight 19 to me.
20 Q And wh e r e w ould you have been?
21 A I we.c located on the cite. I had an o f fic e 22 there at the c o n s t ru c tion o f fic e s ..
23 O A ll righ t, the Vi e l d i n g In s p e c to r .phy elcally t-24 gets a form to fill out?
25 A Yec, and they have copies of the form in EVEL)*e PE RGER ASSOCIATES. STENOTYPE REPORTING SEpylCE. CHARLOTTE. NORTH CAROUNA
D avi s on - Direct 106 I their work avec.
2 G A nd the work areas, are there inc p e c tic e 3 areas where the welding is being done in this inc ta nc e?
4 A Right, plus they have an of fi c e in the 5 co n s truc tion dfi c e, too, at this ti me.
6 Q I want to understand the p r a c ti c e then.
7 The %elding Inspector notes a de ficienc y in the proce ss 8 of in s pe ctin g a weld that is b ein g pe r f o r med.
9 Ylhat does ho do?
10 A Okay, if it is a d e fi ci e n c y that can be 11 corrected ea sily and the Craf tsmen are there, he has 12 the Craftsmen correct that and d o e u rn e n t s his accep-13 tance.
14 If it is not in that category, he would get 15 a copy o f z. n NCI f orm.
16 C %' h e r e would he get th e NCI forms ?
17 A He would have t h e m c.vailable in th e work 18 area.
19 Q "
'\ o u ld h e have a s ta c k of them next to him 20 A They have a map shack in the area, and 21 they hec p th eir equipment and forms th e r e.
22 C % hat kind of proximity to the in s p e c tio n 23 nite would that map sheck be?
24 A They are located throughout th e pla nt .
25 Come Icycic might have two on one level of the plant.
EVELYN BERGER ASSOCIATES. STENOTTPE REPORTING SERVICE. CHARLOTTE. NORTH CAROLINA
l D a v i, s o n - Direct 107 1
i 1 C Cive me en iden juct in some kind of men-2 sure to I can underrtaed; a h u n d r e d. feet from the 3 in s p e c tion e, i t e , fif t y feet f rom the in s pe c tion site ?
4 A W ell, it m s. y be furthe r than that from the 5 in s p e c tion site. T he r e might be an area where the 6 map s h r. c k is located at the r e t. c t o r site.
7 ~Q A diff e r en t le v el as we ll ?
8 A It could be.
9 O Would it take as long as five minutes for 10 the in s p ec to r to go to the map chack to get the form?
11 A It could.
12 Q Ton minut e s ?
i 13 A Po a sibly.
14 O So he gets the form and then what does he 15 do?
16 A He fille out th e form.
17 Q il e also has t h e. t tash; that goes alon g with 18 that procedure to identif y the item?
19 A Yes.
20 Q V,' h a t does he do with the tag?
21 A 11 e can sign that tag and pince that tag on 22 it or tag and tape on the i te m, it c cif, to id entif y '
23 that as an item that has been nonconformed.
, 24 O Then what does he do?
25 A Then he would eith e r s end the form or brin g EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
I D a vis on - Direct ,, 108 I th e f o rm up for r e vi ew.
2 O How would he send it?
3 A He might give it to comebody who is c o mir.g 4 up. He rdght send it up through his su pe r vis o r, go 5 to the s up e r vi s o r and ask the supervisor to send it 6 up.
7 Most c o mm o nly they would b rin g it, the m-8 selves, as I recall.
9 O W he re would they send them or b rin g the m ?
10 A To th e cons truc tio n o f fic e.
11 Q To you ?
12 A To me, yes.
13 Q Give me an idea again for proximity of 14 where you were l'o c a t e d then to the in s p e c tio n site.
15 A W ell, the co n s tru c tion of fic e, I was located 16 and th e W elding In s pe c to r s had areas there, too. We 17 were I would say maybe a hundred f e et away f ro m the 18 plant, a hundred fif ty feet away from the plant.
19 O Where is it now? W here was the cons truc tio n 20 of fice ? Give me a reference to the site; what is 21 located the r e now, the same o f fi c e ?
i 22 A Oh, yes; the o f fic e is still there.
I 23 Q The c on s t ru c tio n o ffic e is still the re ?
24 A Yeah.
25 Q All righ t, cir; then what would happen?
l EVELYN BERGER ASSOCIATES. STENCTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROLINA
D a vi s o n - Direct 109 1 W ould they bring the c om ple t e d f orm to you?
2 A Yes.
3 C Ehat would you do with it ?
4 A I wo uld r e vi e w it, make sure that it was 5 an it e m that was nonco nf o rmin g, make sure the de-6 a c ription wa s ac cu rate, all the blanks were fill e d in.
7 I would re ad it, was it p ro pe rly written, 8 and I would sign it and give it back to the in s p e c to r 9 or forward it on to QA.
10 Q A ll right, sir; so you would make sure the 11 form was fille d out properly?
12 A Right.
13 Q What else would you do in your r eview ?
14 A Make sure it was id e n tifi e d properly that 15 you could und e r s tand it. If it needed a location 16 reference or anything lik e that, that war on there 17 and that it was a v a li d non c onf o r min g ite m.
18 C How would you determine whether it was a 19 v ali d no nc o nf o r min g it e m ?
20 A Ey r e ading it, l o o ki n g at it. The re is a 21 space on th e r e, viola tion s , and referring to the docu .
22 ments c it e d.
23 Q Then what would you do? L e t 's say if you 24 where would you sign it?
signed i t, 5 A There was a block on the f or m.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERV 8CE. CHAR 60TTE. NORTH CAAOUNA
D avis on - Direct ,
110 1 Q And what blank was i t, what did it provide t
2 fo r ?
3 A The f orm was organized with the originatio a 4 w hi c h gave all of the details, do cu me nt s violated, 5 and what the problem was and a pla c e for i;h e o rigin a ;or '
6 to sign.
7 And next to that was a place for the reviev -
8 er to sign.
9 O That wa s you?
10 A For the mo s t part I reviewed p ra c tic ally 11 all the in s p e c tio n s . There are others who would re-12 view it and a manager for the QA person, also.
13 Q You signed it, and then what would happent 14 A F o r me rly I would give it b r. c k t o the 15 inspector, and he would turn it into QA.
16 Q Where is QA located ?
17 A In the same building at that tim e, still is 18 in the same b uil di n g .
19 O What would QA do with it?
20 A They would r evie w it also, and there was 21 a space f o r - t h e tn t o indicate their r e vi ew, and they 22 would c.1 c o d e t e r min e who it should be assigned to 23 for r e s olu ti on and mark that on the f o r m.
24 Q A nything else?
25 - A D e t e r mi n e dis t ribu tio n, who should be sent EVELYN SERGER ASSOCIATES. STENOTYPE RSPORTING SERveCE. CMARLOTTE. NORTM CAmouMA a
Davis on - Direct 111 1 a copy of it. The inepector would get a nu mb e r, and 2 the N CI would be lo g g e d in s o m e tim e during that pro.
3 cess.
4 It may be before he brought it to me, it 5 mcy be af te r he brought it to me.
6 C It could be either way?
7 A Eith e r way, the va st m aj o rit y were numbe r < -
8 cd before they b r oug ht it to me.
9 O O ka y, and that process was f ollo w e d con-10 cistently du rin g a pe riod of time from the beS i nning 11 until when, c. e you juet described, with your involve-12 ment?
13 A The period of time I did it would be 14 February, 1981.
15 Q F e b ru a r y, 19 817 16 A (The Vli t n e s s nodded his h e a d n ffirma tiv ely, )
17 Q A nd that process was the same for 18 d efi cien ci c e th a t were noted in all a r e a s of 19 c on s t ruction ?
20 A y,g, 21 Q All ri ght, sir; w h r. t happened in the inntan<:c, 22 Mr. D r. v i r o n , where you do not approve the N CI ?
23 A Then I would get back with the in o pe cto r 24 to discuse that with hi m .
25 O What would h'appen where you did not appro ve EVELYN BERGER ASSOCIATES, STENOTYPE REPORTING SERvlCE. CHARLOTTE NORTH CAmouM4
D a vi s o n - Direct 11 2 1 the N CI ?
2 A I vic ul d get bach with the incpector, c :: p l a ir, 3 to him what I thought the p r o bl e m was, and why I 4 th ou gh t it was not le gitima te.
5 O T y pi c all y he is standing in front of you?
6 A Right, typically it was in one step; althoug h 7 there were cases where they would leave it with me s and I would re view it.
9 Q So let's take it a step at a time. The 10 in s p e c to r is s ta nding in front of you, and you r eview 11 it.
12 Give me an example in the welding s i tu a ti o n i
13 where you d e t e r min e d it was not a v a li d NCI.
14 A There were very, very few , o f .th os e ; and 15 I don't know that I can say, give you s om e thin g that 16 vrould be typical in that case.
17 The typical process would be typical in 18 th at case. The t y pi c al process would be the inspecto r 19 would come up with an NCI with a qu e s tio n, should-20 this be N CI' d ; and he and I wo uld d i s 'c u s s it and com e 21 to a dectrion as t o v;h e t h e r it chould be or should no t 22 be. '
l 1
23 If we decided it should, I would sign it 24 and f o rwa r d it on. If we de ci de d it shouldn't, the 25 in s p e c to r would ta ke that copy with hi m and give it EVELYN BERGER ASSOCIATES. STER 40 TYPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROUNA
Davicon - DirecB 11 3 I back to the inspector.
2 O V. c a that r. cc=censuc decision be twe en the 3 two of you?
4 A Yec.
5 Q A ll right, if the incpcetor dic a gr e e d, if he 6 did not have a consensus, if you said it is not and he 7 said it is--
8 A Then we would t r.1 k about it. I would w s. n t 9 to know why he thought it was and what his basis w a c-10 and I would explain to him what my bacis was.
11 Q And thr.t happened and he still di s a g r ee d 12 with you. Y. hat happens?
13 A Then I w o uld say, I would tell him that is 14 not an N C I; if it has a num b e r on it, I would sign it 15 and on the form I would state my r e a. s o n s and send it 16 on.
17 Q Slow down one second. You were the super -
18 vis o r and th e in s p e c to r was the s upe r vi s e e ?
19 A Yeo.
20 Q Correct; and you were encrcicing manage-21 ment c up e r visio n over the ins pe c tor ?
22 A Yet.
23 Q So if you could agree on it, fine. If you 24 couldn't agree, you would hold to your po sitio n ?
25 A Yoc; n o r m t.11 y in. a case like that if there EVELYN DinGER ASSOCIATES. STENOTTPE REPORTING SERytCE. CHARLOTTE. NORTM CAROLINA
D avis on - Direct 114 I were d i s a g r e e m c. n t e I would go back to the supervicor ,
2 go back to other people involved, ra n k e curo I h ud 3 all the in f o r ma tio n , all the facts availabic on it.
4 C But ultima t ely it was you r de cision to make 5 in your judgment ?
6 A Yes.
7 Q So in th e cituation where it comes to you a and you have de t e r min e d that it is not a valid NCI 9 and the paperwork has been done, you would sign it to and indicate your reasons on th e fo rm ?
11 A If the number were already on it.
12 C Then what?
13 A I would sign i t, get th e QA to r e vi e w it, 14 and I would state on th e r e why I f elt it was invalid 15 and turn it back over to QA; and they would r eview 16 th a t .
17 O A nd you would document that in _ you r opinio n 18 it was invalid ?
19 A For the f ollowin g reasons thic is not v ali d ,
20 Q And that w o uld be under the r e s olu tion 21 portion of the N CI ?
22 A Yee. '
23 G And then you would put down, what would i
24 you put down a c r e s olu tion in that in s tanc e ?
25 A I w ould say this NCI le not valid f or the.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMAR OTTE, NORTH CAROLINA
Davison - Direct 115 1 f o llowin g recrene, and I yould li s t the m, t
2 Q And what would you put for c o r r e c tiv e 3 a ction ?
4 A NA.
5 Q Jus t not applic able ?
6 A Right.
7 Q If you would ever, in trying to resolve thi n.
8 dispute, Ict's say there is a dispute. The W eldin g 9 In s p e c to r b eli e v e s it is a valid NCI and you b elie v e 10 o the r wi s e.
11 Would you ever go to the in c pe c tio n sit e 12 and like in this instance see the weldin g ?
1 13 /. Yec. I would do that or I might poseibly 14 do that. I might take the supervisor wit h me. I 15 might take the ins pe ctor with me.
16 Q W ould that be unucual for you to do that?
17 A No, it wouldn't be unueual. Thic whole 18 c i tu a t io n is unusual in that it occurred very, very 19 r r. r e l y .
20 Q Would typically you involve, if you were-21 going to the in s pe ction rItc with the in=pector nnd 22 maybe his s u p e r vi s o r, would you involve the C raf t
- 23 who had performed the w or k ?
24 A -If the y needed to be involved in it.
25 Q W ould- that be unucuni in the ritua tion ?
EWELYN BERGE R ASSOCIATES. STENOTTPE REPORTING SERylCE. CNARLOTTE. feOseTe9 CAROUNA
D avic on - Direct _ ,
116 1 A More often than not I would say the Craft 2 would not be involved.
l 3 Q May the y have been?
r l
[ 4 A O cc a c io nally, yes.
5 Q How about th e Craf t s u pe rvision ?
6 A Perhepr.
7 Q L e t 's say it is a ritua tio n that you have 8 just referred to, and you go back to the in s p e c tio n 9 cite to look at the piece of work and you s ati sf y your-10 scif that your conclucion was correct, all right, that 11 t h e. work war not a pp r o p ria tely n o n c o nf o r ming.
12 W ould you r efic c t that o pinio n on the form ?
13 W ould you write that u p, yours elf ?
14 A If the form airc ady had the number on it, 15 that is what I would do; yes.
16 C You would note that, th at you had ' looked at 17 the piece of work and you confirm it is a nonco nf orm ing 18 it em ?
19 A Yes; and here again, I want to reiterate 20 this happens so rarely, there ar e p robably not a 'lo t 21 of cacco thct did occur.
22 O Okay, if you did look at the piece of work '
23 in your re view to dete rmine whether it was a valid 24 N CI, Mr. D t vi c o n, would you list your s elf as an 25 in s p ec to r ?
[
l t
l avetvm etnoen associates, siswotvea narontino samvies. cMantoTTs. Noarn camoussa I
L .
D a vis on - Direct 11 7 1 V ould you document your in o pc etion of the 2 piece of werh?
3 A If I looked at the ite m and determined that 4 it was acceptable. I wovid document thct on the NCI, 5 if the NCI had a numb e r.
6 If the NCI did not have a number, I wo ul d 7 get back with the inspector or his cupervision and 8 say, "T hi s doc o n't need to be N C I' d. It is neceptabl e,"
9 and I would enpinin why.
10 Q Right, but taking the rituation you have 11 referred to where there is a piece of p r- p o r with a 12 numbe r on it, an N C I n u m b e r:.; you a re .rtill of the 13 o pinion it is not a valid NCI af t e r havin g looked at 14 the piece of work.
15 A nd you send it back to CA and write it 16 up as no n-a pplicable or follow up or whatever it 17 cays.
18 Would you note on the document that you 19 had inspected the item ?
20 A I may and may not. I would lict my rea-21 ;
sons for why it wcc not valid.
22 " i O Would you note on nny of the procece
. l 23- control do cum e nt s that you had inspceted that?
i 24 A No, I c an't think~ of any ca se s where 'that 25 occurred.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA ,
)
- _ _ _ _ _ - _ _ - - - _ _ _ _ - - - . - - - - - _ - _ _ _ _ _ _ _ - _ _ _ _ - - _ _ _ - - - _ _ - - - - - _ _ _ . . _ _ . - - _ _ _ _ __ - - -- -- __ .-. _ .-__= -___
Davison -
Diroct 118 1 Q A ll right, sir; now then, let's take the 2 other cituation; an ine pe cto r cemes to you and fi r c t 3 there hac not been a number on the NCI, but the 4 in s p ecto r would typically have c o mple t e d the form?
5 A Correct, yes. W ell, he may have c o m ple t e d 6 it 'o r he may have a qu e s tion -- s hould I NCI this ?
7 A lot of times they will complete the form and say 8
here's what I think.
9 Q So he has th e form completed in this 10 eituation. We will talk about the other, if that is 11 i m p o r ta nt.
12 But he c om ple te s the form but there is no 13 rumber on it, and he b rin g s it to you and you deter-14 mine, you reach the c on clu sion that it is not a valid 15 NCI either by looking at the paper and talking to him 16 or looking at the paper and talking to him and going 17 back to the site and looking at the piece of workman-18 ship. )
c 19 T ha t would happen; right?
20 A O c c a s io nally.
21 O Wha t v.o u l d be th e re s olution in that inctan ce?
22 '
A Would you go through that a g ain ?
4 23 Q Su r e; the paper has been fill e d out by the 24 inspector.
25 A O ka y.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SE RyaCE. CHARLOTTE. NORTM CAROLINA
D a vis on - Dir e c t 119 1 G He comes to you fir c t. There is no numbe r 2 on the N CI.
3 A Okay.
4 Q You talk to him about it, r e vie w it, do 5 w'a a te ve r you need to do, including going back to the 6 it e m or working the weld or other piece of work.
7 You s till c o n c'l u d e it is not a v a li d NCI.
8 I want to unde r s tand the dis p o s itio n.
9 A I would explain to the in c pec to r why it is 10 not a valid NCI.
11 Q You explain it to him. Then w h r. t h a p p e n s i 12 A The situation ends there. If the inspector 13 is s till of the o pinion it is, I certainly listen to him 14 and Isay okay, I understand what you are saying; 15 and I explain why.
16 Q You go around and around and basically the 17 decision is youre?
18 A Right.
19 Q W ha t happens to the N CI, its elf ?
20 A I would give it back to the inspector.
21 Q For what purpose?
22 A Di s p o c e of it.
23 Q Throw it away?
' l 24 A What e ve r. l 25 Q Vi h a t was he supposed to do with it ?
l EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE, CHARLOTTE NORTM CAROUNA P
Davicon - Direct 120 3
A N ot hin g, t
2 Q All right, was there any documentation of 3 your decision to i n va li da t e the NCI in that situation ?
4 A In that case, no.
5 Q Do you maintain any documentation of NCIs 6 that you invalidate d in that way, M r. Davis on ?
7 A No.
8 Q Do you maintain a personal diary or calen-9 dar?
10 A No, I kept a calendar; the c al e nda r was 11 just for a ppointm ent e and that type of thing.
12 O Would you note on your calendar if you met i
13 with the inspector concerning a concern about a .
14 Po s sible NCI?
15 A No.
16 Q Would you note on your calendar if the 17 r e s olu tion of th e item or the matter required a meet -
18 ing, wasn't just a face to face with the inspector at 19 that point, but let's say it is a s i tu a ti o n where the 20 next day you are going to meet with the ; ins pe ctor a nil 21 his supervisor or maybe the C raf t or somebody els e ?
22 Would you put that on your c alenda r ? ,
23 A No. I I
24 Q You wouldn' t ? l 25 A No.
I I
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
D a vi s on - Direct 121 1 Q Never?
2 h No.
3 Q .'. r . D avi s on. do you maintain your calen-4 dars?
5 A I keep them for the year and the next year 6 I get anothe r one. No, I don't keep th e m beyond.
7 Q What is the: oldest calendcr that you have?
8 A I have one for 1983.
9 Q Do you have you r 19 8 2 calendar?
10 A No.
11 Q What did you do vith it?
12 A Threw it away.
13 Q Do you have a secretary that works for 14 you?
15 A No.
16 Q Did you have one in 19 8 2 ?
17 A No.
18 O Is there anybody els e that maintained 19 records of your appointments during 1982 or e a rli e r ?
20 A No.
21 Q A ll right, sir; Mr. D a vi c o n , . I would_ask 22 '
that you maintain your 1983 c alen da r and protect it 23 and keep it in good order, and we would intend to i
24 eeek its production in the course of the Licensing 25 H ea rin g; all r 'i g h t , sir ?
EVELvN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLCITTE. NORTH CAs00UNA
i l i
Davison - Direct 122 l I
l 3
1 A Okay, i
i l
2 Q L e t 's talk about the piece of work that Mr, 3 Eryant de s c rib ed in the document e a r li e r . Now this 4 is the 9 /25/81.
5 You weren't at the C atawba site then; is 6 th at correct?
7 A That's c o r r e c t.
3 Q You were bach here in Charlotte ?
9 A T hat 's correct.
10 Q And you did not have anything to do with 11 the r e s olu tion of that pa r ticula r item ?
12 A Right.
13 Q But as a ma tt e r of policy and pr oc e dur e, 14 how should th at have been handled in your o pini on 15 is what I want to under s tand.
16 C-R.B E you recognize that as Mr. Baldwin ?
17 A ye,,
18 Q He was pe rf o r ming the review function that 19 you have de s c rib e d ths.t you performed befor e him ?
20 g y,c, 21 Q Did you instruct Mr.- Baldwin in how to 22 perform that review when he took over th at '
23 r e s po n sibili ty ?
24
/. No.
25 O N ot at all ?
EVELYN SERGER ASSOCIATES, STENCTYPE REPORTING SERytCE. CHARLOTTL NO8tTH CAROUNA
Davison - Direct 123 i
1 .1 No, 2 Q Yi h e inctructed him, if you know?
3 A l'm not aware of anybody that ins tructed 4 him.
5 Q Did M r. B a l d wi n work for you when you 6
were doing this job?
7 A Yes.
8 Q Did he have occasion to observe how you 9 performed the func tion ?
10 A O h, yes.
11 Q A nd you worked to ge th e r for s o me period 12 of time doin g this f u n c ti o n ? He as sis ted you in doing 13 this fun ction ?
14 A Yes, he was involved in a lot of cituation s.
15 He knew what I did.
16 Q Did you have any reason to b elie v e anyone 17 instructed him diff e r ently when he took over the 18 situation ?
19 A No, not that I am aware o f.
20 Q And you would have expe cte d that h e wo u l d 21 do it the way you had done it?
22 A Ycc, 23 Q 11 o w would the cir cumo tance s deceribed in 24 that reference to that p a r ti c u la r weld, how would they 25 have.been h andl e d ?
EVELTN BERGER ASSOCIATES. STENOTTPE PCPOPTING SERvmE, CHARLOTTE. NORTH CAROUNA
Devioon - Direct 12 4 1
Lead me through the process, hi r . Da vi r o n .
2 I don't wa nt to ash you to couch four facts tht.t you 3
don't know about.
4 I want you to consider this in the realm 5 of a hypothetical in this in stan c e, how would this 6
have been handled through the procecs of id entif ying 7
d e fi ci e n ci e s that we have di s c u s s e d ?.-
8 A I can tell 3 6u my understanding.
9 Q That w ould b e fin e.
10 A Here a gai n, ' fi r s t hand knowledge--
11 O I understand t h r. t .
I 12 MR. GIBSON: Before we b e gin, can 13 I be clear which s p e cific item we are re-14 ferring to ?
15 MR. GUILD: Yes, 9/23/81 16 MR. GIBSON: T he' on e that was read II ea rlie r ?
18 MR. GUILO: Yc3, it 1- the weld 19 r epair incido 'the seven foot, up in the pip e; oo go ahead. -
91 THE Vc IT N E S S : Okay, the in's p e c t o r no had a que s ti on 1(,cause the ripair was seve n 23 feet'b ck up in the pipe and said, " Hey, I a4 c an 't eee that very w e ll, an d, I don' t believ e i
,,t l '/ \ ..
2, Ican do a meaningfu$ ins pe ction of it , " an d EVELYN SERGER AS500tATES. STENOTYPE REPORTING SEnvlCE. CNARLOTTE. NORTH CtM3 LINA i
D a vi s on - Direct 125 ll 1 he contacted the s u p e r v i s. o r who--
4 2
3 3Y MR. GUILD:
4 Q Vi h o would have been?
5 A Mr. Ross. He s aid, "What s hould I do?"
6 I b e li e v e Mr. Ross talked to M r. Baldwin. That is 7 my un de r s ta nding.
8 Q M r. B aldwin ?
9 A Yes, that is my und e r e t t n din g. A gain, I 10 wasn't there; I wa sn't involved in it so I do n ' t know.
11 Q nut the decision was that you think this 12 falls clearly within th e ina c c e s sible po rtion of M4 13 that has a table in it which tells you what is con-14 sidered accescible f rom the idea of a pipe, how far 15 you have to be from the o p enin g in a pipe to be 16 a c c e s sible for in c p e c tion.
17 A T hi s was clearly beyond those limi t s so 18 you do the best you can do utilizing the best tools 19 and e culpm e nt that you can come up with to do it.
20 Q Okay.
21 A A nd then you conduct the in s p e c tio n that 22 way, -
23 Q A ll right, l l
24 A If you can i de ntif y a n y t hin g that way then l 25 you reject it. O th erwi s e you' would accept .i t .
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NOMTM CAROUNA
Da vis on - Direc8 .- 126 1 O Now I'm asking you not how thic pa r ticula r 2 one wcz handled, but let'c say U. r . Baldwin was in 3 a p o s ition that you were in; that is r e vi e wi n g the 4 proposed no nc onf o r min g it e m e , and Mr. Ross precente 5 this to you, and what would you expect Mr. Daldwin, G according to procedure, to do?
7 Tihat would the ap p r o p ria t e procedure cnd 8 in s t r uctio ns be?
9 A C omin g in the f o rm of a que s tionin g, there 10 is a weld at =cven feet back up in the pipe, and I 11 c an't see it very w ell, what should I do--r ef e r back 12 to procedure again for limi t s of a c c e s sibility.
13 Clearly this is beyond the limi t s of 14 ac c e s ribility. Do th e beet you can. If there is any.
15 thing we have to help you, we will do the best we can 16 with what we 'v e got.
17 Q Like what ?
18 A Mirrors, poles, anythin g . you might use to 19 get a review of that s e c tion, vi e w that s e c tio n back "O
up in the pipe.
21 Q Viould it be appropriate to conduct a welding 94 in c p e c ti on using a mirror and a pole ?
03 A Yea, under ther e ' circum s tances where you 94 are beyond the limit s of ac c c c s ibility.
25 O To look in the pipe ?
L*VELYN SERGER ASSOCIATES. STENOTYPE REPORTING SEnveCE, CMARLOTTE. NORTM CAROuMA
Davison - Direct 127 i I. Yec.
t 2 C M o ve do you unde re ta nd what the ditmeter 3 of the pipe is we are talking t. bout?
4 A I und e r s te nd it is a rix inch pipe.
5 Q You would agree he c o ul d not go up in th e 6 pipe and look?
7 A I wouldn't think so, no.
8 Q So what is the inspector supposed to do 9 under the procedure?
10 A It is beyond the li mi t s of ac c e t ribility; 11 he doec the be st he can under the cir cum s t anc e s.
12 Q T ell me how he is suppoced to do it. I
\
13 want to unde rs tand phy sically how an inspector is 14 suppored to do it according to procedure under those 15 cir c um s ta n c e s .
16 A He would like to see what aids he might 17 have to help him in doin g that.
18 Q Vihat aids would he use to do it?
19 A Maybe a mirror attached to a pole ctuck 20 up there with a fla s hli g h t.
21 Q Vlould you expect the inspector to do that 22 with a weld reven feet up in a rix inch pipe ?
23 A I would expect him to do the best he could 24 do.
25 O I want to un d c r a t and what an ins pe cto r
.mva ...or. ...oci.rs . svi~orne aeroari~o seawea. caa.'orre acara caaoua.
D a vi s on - Direct 128 1 should do in your eupervisory c a pa ci t y.
2 A If an in spe c tor cannot see it and it le 3 beyond the limit s of c ec e r sibility, the n the procedure 4 r e c o g ni z e r that if it is beyond this point.
5 O " visual examina tio n s should g e n e r a lly be 6 conducted by the direct method. The angle of vision 7 to the eurface to be e xa min e d should be no more than s 30 degrees and the eye no more than 24 inches f r o rn 9 the surf ac e."
10 "For ob s e rvation of r e la ti v e heights and 11 other c o n di tio n e which require a p r o file vi e w of the 12 piece to be examined, the angle of vision should be t
13 within 20 degrees if p e r p endicula r to the piece."
14 "If th e s e conditions cannot be met, indirec t 15 e xa mina tio n will have to be e m ploye d. " I am r e a din g:
16 out of Procedure L80. Does that s ound like the 17 policy at the time we are talking about?
18 A Yes, I think that i s - -I' m not aware of 19 any r e vi s io n e .
20 Q A ll right, sir. "For ob s e rva tion of rela-21 tive heights and other conditions which require a 22 p r o fil e v i e ty of the piece to be e xa mine d, the angle '
23 of vi r io n thould be wi t hi n 20 degrees if perpendicula r i
24 to the piece."
25 "If these c o ndition s cannot be m s t, indirec t 1
EVLiVN SERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CNA81LCITTE. NORTH CAROUNA '
D avis on - Direct 129 4
l 1
' exa mina tio n will have to be employed. Mirrors, tele-i 2
'scopec, bor e scopes, or other s uit a ble in s t rum en t e 3
may be used."
4 "Ma gnifie r s may be used as an aid to 5
visual examination. Adequate illumination i s require d 6
to insure there is no loss of s en sitivity in the 7
exa mina tion. "
8 "If a fin e line 1/32 incht or less in width 9
on an 18 percent neutral gray card or some other 10 a r ti fi cia l flaw (scribe lin e , pencil mark, etc., 1/32 11 inch wide maximum) located on the surface to be 12 e x a mi n e d can be e a s ily seen, the illumination is 13
^
adequate. "
14 "If th e 1/ 3 2 in ch line or a r tificial fl a w 15 cannot be e a sily seen, additional illumination such 16 as a fla s hli ght s h all be employe d. "
17 Was that the p olic y and procedure in effec t 18 at t h s. t tim e ?
19 A Yes, what you are r e a din g ap plie s to the 20 outside surface of a weld.
21 Q A bout the inside surf ace ?
22 A N o r m ally it will not be accessible. That .
23 is what th e ta ble is th e r e for, to tell you when you i
24 can conduct a visual exa mina tio n.
25 )
Q So n_o n e of that procedure, that does not '
EvtLYN S, BERGER OFDCIAL COURT RLPORTER
- u. S. OtSTRICT COURT <
CH ARLOTTE, N. C. l
D avic on - Direct 130 1
jhave anything to say about the cituation that Mr.
1 2 i Bryant was talking about or we are hypothesizing i
3 here, the incide route side of the weld and the pipe ?
4 A For route conditions of a weld, the M4 5
e s ta blis he s what is accessible for in s p e c tion and wha t 6
is not a cc es sible for in s p e c tio n.
7 O Here is M4, take a look at it and direct 8
my attention to that (indic a tin g ) .
9 A Here is a graph that shows the internal 10 diam e te r of the pipe.
11
, Q Identif y what you have the re.
12 A OA Procedure M4, Page 10 Revision 0.
13 Q Okay.
14 A And it shows the internal diamete r in 15 inches, inside dia me te r of th e pipe in inches and 16 internal a c c e s sibility for ins p e c tio n.
17 O So for a six inch pipe what is the standard 18 a c c or din g to that table ?
19 A Veell, a six inch pipe. I would have to loot 20 to see what the inside diam e t e r of that would be; but 21 if you are a s s umin g it is six inches--
22 O L e t 's say it is four inches, how about that ?
23 A Internal distance in inches would be seven 24 inches.
25 n y,,,,,,,
^
g,, en m, if y, e e s c ume it is four EVELYN $ BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT ,
CHARLOTTE, N. C,
D a vi s o n - Direct 131
(
1 inches incide dia m e t e r , what does that r e sult tell 2 l you ?
3 A That it is not accessible for di r e c t visual 4 in s p ec tion beyond four inches incide the run of the 5 pipe.
6 O Seven indeed is beyond four inches, right?
7 A Right.
8 Q So M4 has s aid we cannot get the visual 9 in s p e c ti on; right?
10 A R ig ht.
11 Q Then what is the inspector supposed to do.
12 having made that det e r mination ?
13 A He uses whatever means he can to do the 14 best in s p e c tion he can.
15 Q Best visual in s p e c tion ?
16 A Yes, if he enn't it is very likely he cannot 17 do a visual in s p e c tio n. You obviously cannot do a 18 visual ins pe ction of a roof in a clo s ure weld.
19 Q Wha t is that?
i 20 A The last weld in the pipe, so there is no l l
21 opening.
22 Q No way to get to the inside at all ?
23 A Right. l 24 Q Now there is a way to get into this one in l 25 your ex a m pl e, rig ht. - seven feet up but there is an EVELYN S. BERGER OFFICIAL COURT REPORTER '
U. S. DISTRICT COURT .
CH ARLOTTE. N. C,
Davison ~. Direct .. 132 r 1 lopen end, right?
l 2
! A Hight.
3 Q Does he go to the procedure guidance in 4
80 to fi g u r e out the best way hc can do it?
5 A He uses that in co m bin a tio n with M 4.
6 Q M4 says you cannot do a straight visual.
7 and you are saying the p olic y is to do th e best he can; ,
8 right?
9 A Right.
10 Q M ith regard to doing the best he can, all 11 this paragraph in L80 tells him, it describes the use 12 of mirrors, illu mi n a ti o n and m a g ni fi c a tio n to do the 13 visual; right?
14 A Right.
15 Q It tells hi m how much light he needs to be 16 able to do it without further illu min a ti on.
17 A The M4 has alr eady told him it is inaccesri-18 ble.
19 O But you are tellin g him to do the best he 20 can? !
21 A Right, use whatever mea sure s he can.
22 Q He does to L80 and all the business about 23 gray cards and 1/ 3 2- i n c h lin e s , and it doec not take a 24 genius to fi gu r e out when it is 7 feet out he will not 25 be able to meet that standardt he has t o' c e t' a fla sh.
Evrtyn S. BtRotR CFFICIAL COURT REPORTER U. S. Ol5TRICT COURT CHARLOTTC. N. C.
D a vis on - Direct 133 1 ; li ght, right?
2 , A Right.
3 Q Then he gets a fla s hlig ht and he has the 4 mirror on a pole and he s tic h o the mirror up a pole.
5 Is it your p o s itio n that is how he is suppos ed to 6 form the visual?
7 A Under th e circums tanc e s here he will use 8
whatever he felt like was the best he could do.
9 Q I want to understand what you think under 10 tho s e circum s tan c e s is the best he can do. You are 11 the one reviewin g the NCIs and s up e r vi sing the work.
12 A A nything els e I can think of that would be 13 better than that in this situation--
14 Q Is there anything else?
15 A You might get a borescope. Here again, it 16 will be ve ry limited in terms of what you can see, 17 make out and interpret.
18 Q What do you ure a borescope for?
19 A M any things.
20 Q T ell me so I will und e r s ta nd how that w o ul d l
21 help you under the circums tanc es.
22 A It might enable you to get a better look.
23 O T ell me what it looke li k e .
24 A A bore scope is a f l e ::i b l e or inflexible 25 lencth of tu bin e that has a means of trancmitting ligh t EvtLYN $. 6(RGER CFFICIAL COURT REPORTER U. S. CISTRICT COURT CH ARLOTTE, N. C.
1 D avis on - Direct ,, 134 l 1 down into the pipe to look in and eee out the other 2 iend. l 3 O A nd it is used for exa minin g welde in pipes?
4 A It would b e used for a lot of purposes.
5 Q Can you use a bore scope to look seven feet 6 up a pip e ?
7 A You possibly could.
8 Q C oul d you; I'm a sking ?
9 A I would expect so.
10 Q C ould you observe an adequate vi s u al 11 e x a m i n t. t i o n of a weld with a bore scope?
12 A I do n' t know, it w ou ld depend on the 13 r e s olu tio n of the bo re s co pe. I don't know.
14 Q At C a tawb a in your W eldin g In s pe ctio n 15 experience was the r e available to W eldin g Inspectors 16 a bor. scope that would a ll o w him to perform an 17 adequate visual examination?
18 A No, there was not a bo r es c ope available ~
19 to him there.
20 Q Okay, do they have the m now?
21 A we s ve got one on order, yeah.
22 O Okay, did you have a bore scope out there 23 before ?
24 A The in s p e ction group didn't have one; no.
25 O Did they have one out the r e at all?
EVELYN $, BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT -'
CHARLOTTE, N. C.
D avi r on - DirecQ 135 1 ! A In s p ec tion and C on s t ru ctio n ; Nuclear Pro-2 ; duc tion, I don 't know whether they had one or not.
i 3 I b e li e v e they do.
4 Q Do you know what they uce the m f or as a 5 normal matte r ?
6 A No.
7 Q Those are in Ope rationc ?
8 A I a s sume so, yes.
9 Q S om e thin g to do with examining the inte rna ls 10 of a reactor, getting into the eteam generator, doing 11 s o me thin g like that, doing repair work?
12 A I do n't know what they use th e m f o r.
13 Q But you don't use th e m for in s p e c tion ?
14 A Not no r m ally, no.
15 C The short and long of it, Mr. Davicon, 16 th e in s p ec to r having studied the procedures or havin g 17 m e mo riz e d the m or having ju ct common sense perhaps 18 reaches the c o n clus ion that he cannot do his job, he 19 cannot vi s ually inspect the weld repair; what then 20 is he suppoced to do under the procedure as you 21 und e r t ta nd it?
22 A Then if it is the interior, the r o ute p a r t .
23 of the w eld is inz.c c e s s ibl e for in s p e c tio n, then he does 24 the best he can.
25 O And what is he ru nno s ed to do: v hat does Evrtym S. BERCER CFFICI AL COURT REPORTER U S. DISTRICT COURT CH ARLOTTE. N. C.
Davison - D.i r e c t .. 136 1 lthat mean?
l 2 ! A It m e t. n z he does the beet job he can.
3 Q I want to under s tan d what c t a ti d a r d you are 4 holding th e s e people to, sir. V. h r. t is the best he 5
can do under the cir cum s tan c e s we have just d e fi n e d "
6 A A ttaching a fla shlight and mirror and pole 7
under those ci rc um s tan c e s and doin g th e best he can.
8 Q All right, th e Vi e l din g In spec tor come s to 9
you or throu gh his s u p e r vi s o r and sayc I can't see
.)
10 that weld, I c an 't in s p e c t that weld. !
11 VJhat is he supposed to do then at that 12 point?
13 A Taen he gets direction from his super-14 visor.
15 Q And what di r e c ti on is a pprop riate ?
16 A If the weld in inaccessible, he would say 17 sure you can't, it is beyond the limi t s of a c c e s sibili ty, 18 the repair.
19 As I under s tand it it is for a r adio g r aphy 20 defect never detected vi s u a ll y to b e gin with s o at 21 that time ra di o g ra ph y will have gone over it af ter the 22 r e p air is complete to see if the defect, the radiog-23 raphy picked up hac been corrected.
24 You a re not looking at th e d e f e c' t because j 25 you did not detect it vi r u a lly to be ci n with. It was EvtLYN S. BtmotR OFFICIAL court REPORTER
- u. S. DISTRICT court CH ARLCTTE, N. C.
D a vis on -
Digept 137 ;
1
( 1 i P
detected b; the radiography, so r r. d i o g :- a p h y would l
9 2 , h r. v e to pick that up.
3 He cannot inspect it in accordance with the 4 limit s of a c c e s sibili ty. I would ctill expcet him to 5 look to the extent that he can.
6 C A nd what is he suppos ed to do?
7 A He is supposed to indicate his acceptance 8
as a re sult of what we have de c e rib e d. It wo uld be 9
no diff e re nt .han him indicating his acceptance of a 10 closure weld when he can't oce the route of it.
11 Q Should he indicate that he was unable to 12 vis ually inspect the weld?
13 A He can, there would be nothing--
14 Q Would it be ' c e pt e d as a matter of pro-15 cedure that he indicated that he could not visually 16 inspect the weld ?
17 A N o.
18 Q It is not required that he document that the 19 visur1 ins pe ction did not occur and was not possible 20 because of the inac c e s sibility of the weld ?
21 A Not in this case, no.
22 Q Is it proper in that c t. c e for him to sign 23 it off?
24 A Yeah.
25 O A nd you would have dir e cte d the inspector EVELYN S. BERcta OFFICIAL COURT REPORTER U. S. DISTR.CT COURT C H ARLOTTE. *f. C.
Davison - Direct ,,
138 1 to sign it of f in this case?
2 ,
A I would have caid ir there anything we can 3 use to get a better view of it; and if you have u s ed 4 e v e r y thi n g we have available to do it and in our vie w 5 we ca n' t see a nyt! i n g wrong with it, you ehould sign 6 it.
7 Q A nd you would have instructed him to sign 8 it off ?
9 A Yes; the r e again, knowin g that it had been 10 radiographed.
11 Q W o uld you document that as w e ll ?
12 A No, I would not document that.
13 O How would you have insured that th e weld 14 was radiographed s u b s equ e ntly ?
15 A The sys tem that we have in place checked 16 to make sure that every weld that is required to be 17 radiographed is radiographed, the same s ys te m we 18 are talkin g about now.
19 Q What I want to understand--
20 A The QA Program.
21 Q How do you document that this is a pp r o p riat e-22 ly signed of f on vis ual by the W eldin g Inspector 23 because you, one, can't see it and two, expect that 24 it is going to be s ub s e qu ently radiographed--
25 How do you document those two c onditions ?
EVELYN $. BERCER CFFICIAL COURT REPORTER U S. 0857RICT COURT CH ARLOTTE, N. C.
l t
l Davison . Direct 139 1
, 1 ; A Vi e ll, the fo r m, it will in dic a te r adio g-l I 2 raphy is required; and that form will have to be l 3 c o m ple t e d and Radiography will sign it.
4 Q And that is.the procesa control?
5 A Yee.
6 Q A nd no other documentation is required 7 under these circums tance s ?
8 A No.
9 MR. GIBSON: Is this a good stoppina 10 point. .
11 MR. GUILD: A 11 right.
12 13 BY MR. GUILD:
14 Q A ll right, sir; I'm showing you a copy of 15 procedure M 4, and this is the weld process control 16 sheet M4A; is that the process control form you are 17 talking about?
18 A Yes.
19 C And that is the current r e vision a s best 20 yoit know?
21 A ye,,
22 Q That is not id en tic al to the f orm used '
I 23 during this whole form?
(
24 A No. I l
25 Q That has the accent-reiect boxen on it that EVELYN $ BERGER OFFICIAL COURT REPORTER l
U. S. DISTRICT COURT CH ARLOTTE, N. C.
D a vis on - Direct ,
140 I
1 I fo r a ti me were not on it?
2 A It has the accept-reject box for f i n z.1 visual 3 in c p e c tion.
4 C And that was not the final f o rm used?
5 A I don' t b e lie ve co.
6 Q Under the ci r c um e tanc e s we have described, 7 where would the W eldin g Inspector be instructed to 8 sign off ?
9 A He would do the final visual in s p ec tio n.
10 Q O ka y, is there a lin e refe renc e ?
11 A Number Seven.
12 Q It says, "ID a c c e p ta ble - "
13 A A cc e s sible.
14 Q Is he supposed to check that yes?
15 A In this case you would c h e c k 'i t no.
16 Q Was that p r o vi s ion on the f orm in e a r li e r 17 ver sions ?
18 A I ha v e n ' t always been there; I don't know 19 when that revision came up.
20 Q Do you know whe th e r that "ID a c c e s s ible, 21 yes/no" box revision came up?
22 A I don't know.
23 Q Do you know how long that "ID accessible, 24 yes/no" box h r. s been on th e r e ?
25 l A No, I would jus t have to guess.
EVE LYN $ 8ERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE, N. C.
D avis on . Direct 141 1 Q Do you know whe th e r that provision was 2 changed cc c r e sult of the Tack Force r e com mend atio n?
3 A Not right off; I would have to look at it 4 to tell.
5 Q And so he would sign off, he would check 6 no final visual in s pe c tio n, check ID ac c e s sible, no, 7 line seven; correct?
8 A Yes.
9 Q And then where would he sign?
10 A Here (in di c a tin g) .
11 Q U nd er the r e p air c olumn ?
12 A Yes, a s s u min g this was a repair.
13 Q A s s umin g it was af ter re pair ?
14 A yes, 15 Q That is Revision 13 to M4; correct?
16 A Yes.
17 O I will show you another document (indicating).
18 Is this a process control sheet in the form e a r lie r 19 employed?
20 A T hi s is M4A, R e vi s io n 11, it looks lik e .
21 O Is that an e a r lie r ve r s io n of that f orm ?
22 A Yes, it looks to be.
23 Q And let's see, final records check is at the 24 very bottom of the f o rm. What is the date th a t 25 appears on this ?
EVELYN $. B(RGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE, N. C.
i Davison - Direct 142 1 A
- 8/8/77.
2 l O Do you r e c o p, n i z e that ac a form that would i
I 3 have been used ap p r oxima t ely at that time ?
4 A Yes.
5 Q How would the example that we have just 6
t a lk e d about be c o mple te d ? What would the Welding 7
Inspector be instructed to sign off in the e a rli e r 8
version of the form ?
9 A You are saying on this form how would that 10 e xa mple --
11 g yes, 12 3 yes, 13 Q The s pe cific aspect of it, the Felding 14 Inspector's signing off per in s t ru c tio ns , h avin g dis- '
15 covered that he could not under M4 see the w el d, the 16 o tte side of the weld, what was he supposed to do?
17 A W ell, he would not perform any docume n-18 tation of that on here. There would not be any docu-19 m en t.
20 Q W ould he still sign the control sheet?
21 A Yes.
22 O Where would he sign ?
23 A Here in block ten.
24 Q Block ten is identified as " Visual 25 In s p e c tio n " ?
EVELYN $. BERGER OFFICIAL COURT REPORTER
- u. S. DISTRICT COURT CHARLOTTE. N. C,
Davis on - Direct 143 I
l
, 1 A Yec.
2 Q And he would not r ej ect it?
3 A A s suming he did not see anything he felt 4 was rejectable.
5 O A s s uming he did not see it because he 6 could not see it, he would accept it and put his 7 initials down?
8 A Yes.
9 Q But you would not be expected to other-10 wise document the circums tanc e s ?
11 A He would not be required to, no.
12 O L e t 's see if we can--I think it is tim e to
(
13 break, but I would like to identify this as the next 14 numb e r, just th e fir st copy.
15 ( Wh e r eu po n, the document re-16 referred to as Weld Process Control 17 Sheet was marked and received by the 18 Court R e p o r t e r. as Davison Exhibit 19 Five and e nt e r e d into th'e R e co r d. )
20 MR. GIBSON: Guild, Mr. one other 21 thin g we need to take up. I suggest right 22 af ter lunch, is s c h e dulin g for ne xt week. '
23 I will give you a lette r whic h sets 1
24 forth our understanding ofr e v e r yo ne 's avail.
25 a bilit y or u n a v a ila bili t y.
EvELYN $. BERGER -
CFFICIAL COURT REPORTER U. S. DISTRICT COURT ,
CHARLOTTE, N. C. '
7 t
I 144 l
l l l l 1
( l Fome folks warned us to let the m know
! I 2 ! by noontime to d c y, and we have gonc pact 3 th a t.
I 4
Vi e will r e sume in an hour. !
5 ( Wh e r eupo n, Mr. D a vi s on 's 6
De po sition wa s adjourned, to be con-7 cluded on July 13, 1983.)
8 9
10 11 12 Larry'R.
(
I, D a vi s o n, hereby c e r tif y 13 that I have read and understand the f o r e going tran-14 script and believe it to be a true, accurate and 15 c o m pl e t e trans c ript of my te s tim ony, 16 17 18 Larry R. Davison 20 This D e po s ition was signed in my 21 precence by Larry R. D a vi s o n on the day of July,
'2 1983.
23 i
24 25 Notary P u b li c EVELYN $. BERGER CFFICIAL COURT REPORTER 1, U. 5. DISTRICT COURT l CH ARLOTTE, N. C.
- . _ _ - _ - _ _ _ - _ - _ _ _ _ _ l
145 l
1 ,
C E R T I F I C A T E i
2 l STATE OF NonTH C AR O LIN A I
3 I COUNTY OF MECELENBURG 4 I, Lynn L. G illi a m , do hereby c e rtif y 5 that the proceedings were by me reduced to m a c hin e 6 shorthand in the presence of the Witne s s, af t e rwa r d s 7 trans c ribe d upon a typewriter under my di r e c tio n; 8 and that the foregoing is a true and correct tran-9 script of the p r oc e e din g s .
10 I further c e r tif y that these proceed-11 ings were taken at the time end place in the fore-12 going caption s p e cified.
(
13 I further c e r tif y that I am not a 14 r elative, Councel or A tto rn e y for eith e r Party or 15 o the r wis e interested is the o utc o m e of this action.
16 IN h ITNESS WHEREOF, I have here-17 unto set my hand at Charlotte, N o r th C a r olin a, on 18 this the day of July, 1983.
19 20 21 LYNN B. GILLIA M ,
22 Court Reporter .
23 24 25 My Co mmic cion ex pir e s May 12, 1588.
Evt LYN S. BERctR OFFICIAL COURT REPORTER U. S. OISTRICT COURT CH ARLOTTE, N. C.
e m-n 4 0
} This appraisal is being done because of a fair rating received by Beau on his i i "; last annual appraisal which identified a need for further development. It s j !; covers two per:ods of time, one being before 1 November 1932 and the other
-;A after. While Beau's performance in the areas of planning and organizing Q )<g work assignments remains acceptable, his performance in several other areas Wi}j as a supervisor still demonstrate a clear need for further development.
Generally, Beau's understanding of his role as a supervisor and his L
J p responsibilities to other organizations (i.e. crafts), his employees, i -
3 li 4 and his management needs improvement. Beau's successful performance as a supervisor necessitates his clearly understanding his responsibilities and
.d-5>*' 1 ( 5' carrying them out properly. Without improvement in these areas Beau's continued assignment as a supervisor will not be appropriate.
The following specific areas illustrate the problem discussed above:
When the decision was made to start recertifying welding inspectors in MT and PT at Catawba, Beau asked his supervisor if that meant that the people being recertified were going to be transferred to Cherokee? The answer was no, that we were preparing to better utilize the workforce at Catawba. Beau evidently did not accept this explanation as he took the first opportunity to ask his second line supervisor the same question who gave him the same answer. This was not the proper action for him to take.
When clarification was received from QA Technical Services concerning the proper use of R-2As and this information was communicated to Beau, he said that this interpretation showed a lack of support for him and his inspectors.
However, he did agree' that the final product would meet all QA requirements.
The communication between Beau, his crew, craft, and Technical Support has gotten better but still needs much improvement. Of particular concern is the ccmunication problems between Beau and Craf t supervision. For example, when craft supervision or technical support personnel have questions con-cerning Beau's inspectors, inspections, or inspection interpretations, which require looking at the item being inspected, he of ten will send another inspector to look at the item. This is unacceptable as it is his responsi-bility to interface with these various groups. This responsibility cannot be delagated. This action. detracts from his effectiveness as a supdrvisor and isolates him from the problems. Beau views this approach as being supportive of his crew but in fact is shirking his duty as a supervisor.
These actions were demonstrated when craft tried to enlist his help with structural steel on the ramp of Unit 2, tack welds in #2 diesel generator room, and paint in welds of Unit 2 diesel generator. Beau interfaced with the personnel involved and looked at the welds only after being directed by his supervisor. These are only a few of the numerous times this has happened. Because of this attitude, these people are hesitant to go to Beau with problems. The com.unications between Beau and other -
supervisors in his area is also at a minimum because of his attitude.
He is very quick to find reasons why new plans and ideas won't work rather than trying to find ways to make them work.
00'/ $500 L'4 n
.. S /
A W/9 a
Beau also has a problem in acceptir.g Code requirements as being strigent enough. For example, af ter having been given a copy of the Code criteria
- for NF welds and being instructed to have some hanger material inspected by these criteria, the inspector listed several items as rejectable that the criteria clearly did not specify. Considerable time and effort had
.to be spent to properly inspect the material listing Code rejectable items separately from other observed questionable conditions.
in carrying out his duties as a supervisor Beau has problems answering the questions of his employees in the proper manner. All supervisors were instructed in June to provide answers to employee questions when they knew the answer. When they did not, to go to the next level of supervision with the question to get the answer and.then communicate it to the employee.
Recently one of Beau's inspectors had several questions about a NCI.
Instead of following the method above which he had been instructed to do, Beau attempted to answer the questions himself which he could not do.
Then he referred the inspector to his (Beau's) supervisor. The inspector later stated that he thought Beau had told him that he would probably need to file recourse to get an answer. Beau does not seem to understand his role as a supervisor in answering or getting answers to his employee's questions.
- Beau has felt that he should not be held accountable for his employees actions.in areas of safety, attendance and job performance. This was illustrated by his reluctance to write his Personal Performance Plan Worksheet (PPPW) for the coming year listing objectives in these areas although the other supervisors had no objections to these accountabilities and felt them to be valid. Again this pointed out a basic misunderstanding of his role as a supervisor. However, once the PPPW was written, he has attempted to improve in the areas identified. Improvement has been made in his crew's attendance and some improvement has been made in his communications with craf t and technical support personnel, however, more improvement is needed in this and the other areas listed on his PPPW.
~
1 .
May 26, 1cB3 G E Ross .
Re: Catawba 1-2 Employee Recourse, G E Ross to L R Davison dated May 12, 198,3 I an writin~g this letter to you in response to your recourse to me regarding your recent performance appraisal.
In looking into your recourse I have talked with both you and Art Allum, I have reviewed the performance appraisal of other supervisors in positions similiar your own to yours; and, i have spent a great deal of time reviewing appraisal.
I can understand hcw one would feel upon learning that his or her performance appraisal was rated lower than expected.
make you feel as if you had not been dealt with fairly. I can understand how this could investigated your appraisal and your concerns about being discriminatedI have thorou against.
i Whereas your feelings are important to me, out of fairness and equity each performance appraisal must be evaluated on its true merits.
This has been my approach in my investigation into this matter.
In short, my decision is that your appraisal conducted this past April .
twoproper.
is itsns. . I think your feelings about this appraisal stem largely from l The first item is the fact that _our expectations of you in your position were not communicated to you clearly enough nor in enough detail. This lack of good communications I accept the responsibility for.
steps to see that it does not occur again. But, even with thisI problem, am taking clear improvement in your performance is noted on your appraisal. I see no reason why thatonshould communication not continue and even get better with improved our part.
h I askyour with thatsupervisor.
you also recognize the importance of your communicating clearly if directions or decisions are of concern to you be them. sure you have used all the proper channels to communicate and resolve The second item discriminated which I concluded had contributed to your feelings of being' against by Art Allum. is your interpretation of certain actions, or inactions, My investigation revealed that in these cases you were not 8 aware of all that had taken place and; therefore, you viewed them as discriminatory against you, or in favor of someone else. Again I ask you htok d 0
- - - _ --4 26k3
c .
to be sure you have communicated your concerns when you feel this way so that misunderstandings do not develop. .
I pledge to you my best efforts to c=mmunicate our expectations to you cicarly; and, I have no doubt of your ability to meet those expectations.
I would be glad to discuss this response with you if you so desire.
Please let me know if you do.
~ .
If you do not feel this response satisfactorily addresses your concerns you should address them to the next management level, the Corporate QA Manager, G W Grier, within 10 days in accordance with the recourse procedure. . .
L R Davison '
i Project QA Manager.
l O
e
l i
- INVESTIGATION INTO RECOURSE SUEMITTED
- TO THE CATAWBA PROJECT QA MANAGER BY G E ROSS ON 5-13-83.
I A. Outline of steps taken in investigation
- 1. Asked G E Ross for extension of time to reply under Duke Management Procedure 8901-0012-QA-001 from four days to 5-27-83 Concurrance from G E Ross obtained..
- 2. Went over with G E Ross in detail following items to be sure understanding of basis of recourse and basis of feelings expressed by G E Ross in the recourse
- a. Recourse letter itself, dated 5-12-83
- b. Evaluation ASSA of G E Ross dated 2-21-83
- c. Preliminary evaluation of G E Ross by Art Allum with note added by Art Allum that it was discussed with G E Ross on 1-26-83
- d. PPPW worksheet for G E Ross approved by Art Allum and J W Willis covering 11-1-82 to 2-1-83
- e. Answer provided to G E Ross from Joe Willis concerning his recourse at that step, dated 4-22-83
- f. Memo to file from G W Grier concerning meeting with G E Ross on this subject dated 4-27-83
- not in detail 3 ReviewedpersonnelfilesofGERoss,SWLedford,BWDeat$n, and Bob Harris. Reviewed performance evaluations for these individuals that were contained in these files. ,
- 4. Discussed results of step 2 with C N Alexander, QA Administrative Services Manager.
5 Went over with Art Allum, G E Ross' supervisor, those items ~
shown in 2) above. ,
- 6. Made G W Grier aware of recourse from G E Ross to me concerning his evaluation.
7 Met with G E Ross and A.E Allum to discuss points of disagreement disclosed in steps 2 and 5.
,. _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ mA $-
B. Findings resulting from investigation
- 1. That Beau's feelings of being discriminated against were based on the outcome of his evaluation and other actions he had observed.
These actions observed by Beau (G E Ross) were viewed from Beau's perspective; and, resulted in conclusions on his part which were not legitimate because he did not know of other factors or actions that resulted in the observed actions.
There was no discrimination against Beau substantiated by the other actions observed by Beau.
- 2. That communications from Art to Beau regarding Beau's performance were informal (i.e. verbal) and not clearly understood by Beau.
3 That communications from Beau to Art were lacking in that Beau did not follow proper p.rocedures (informal or formal recourse) in getting answers to his concerns where he had doubted Art's decision or directions.
~
- 4. That Art's evaluation of Beau's performance was not discriminatory because his evaluations of other persons reporting to him were done in the same manner and with many of the same points as the evaluation of Beau. ,
5 That Art's evaluation of Beau's performance was basically accurate.
- 6. That a large contributor to Beau's feelings of being treated unfairly resulted from the lack of specific, clear standards for Beau's performance and the lack of formal review sessions to go over Beau's performance. .
7 That Beau tends to evaluate himself against his own internalized standards and has difficulty accepting any other evaluation. He also tends to evaluate himself by comparing others in his position against these internalized standards.- This makes meaningful communication sometimes very difficult with him.
- 8. That Art's evaluations of other supervisors who also had concerns expressed in the same manner as Beau did,not support or substantiate discrimination by Art toward them.
C. Conclusion I conclude that there has not been discrimination by Art Allum in G E <
Ross' evaluation. .
I conclude that G E Ross feels there has been'and is discrimination against him because of the poor job-done in communicating to him expected standards of performance in specific detail. He also feels discriminated against because of actions or inactions he has_ observed but does;not see or know all of what goes into these actions. 'In other words, he' has misinterpreted his observations, and, in some cases, just does not know the facts. f
i ,
i
, , i
- 2 .-
t i
1 D. Recommendations .
I recommend steps be taken to ensure more formal comunications about performance between first and second level supervision and an independent review of first line sdpervisor's PPWs.
To this end I will instruct the employee relations assistant at Catawba to do several things. They are:
- 1. Track the conductance of PPPW reviews at the required intervals for first line supervisors.
- 2. Review all generated PPPWs for clairity and as objective as possible standards for all first line supervisors.
3 To report to me any cases where poor comunication about performance standarh is suspected.
These steps will remain in effect until such t me i as I conclude proper communication is occuring.
Signed,j 22c m u % Date J - 2 /, - P 3 L R Davison '
Catawba QA Manager J t
cc: G W Grier C N Alexander
/
\
f 9
o P T 6
c..-
, w.3 .
. . ,, . - - Q p:. ,.. . . ,
. Q ._ _
...w
,=rn. ,. a m.m . , _ , , .
S'.- 4 A l rs c.s .:; . : *, .
7, l F C F. f.'.
o e.iii:L : .:E
- E- ;5 " E ~
/ ,j.:-= -
w.5 i ? .u n DUKE POWER CC' IPA NY 2 - E 3 :2:.-@ I i / r./ i ,J..' * *' ^!
.. t : < t > CON STRUCT!C"" DePARTf.'.E -
inro SEv' n. l i ?7n cc em .at i o.
=Y v == .:t .n u c v -2.A - 7 i PROJECT 00 7~Ab} B O .NT rr l
0 WELD PROCES5 CONTROL SHEET R []Rf) l
- i.5 C F..@ C N f AQCii5 CChi AOL. . C we
- d N:. Ok N N' N Ct:ss b EWOS. ^//4 me I
'/4 t,: v,. . pa C M - O R tJ - 55 P-e. et eu s. ceo the
! 'I F.:et P:s:/Re;;ir NCE Wd - !
PC An N:. Weid Re;ctr No. '
F-S3 Re-dred Yes 2': N:C 3 Type Wetd bv77~ Finct NCE PT::. A-) A Ce l 30 e=0 l-4//
P!;e Size SO~ Je' ! Thl:kness - O 3'75 ' > 1"Celto Fctrile Check (M 32) Reqeired Yes C No. m M:*eri:t b b b O~/ Re .cris-I.
Re e.: tis: .
1.
y
./ MSPE TIONS /,
A'.!THORf 2ED INSFECTOR R EV'EW 2 WO W DATE 7/ ~M /7 -'
- tMtiet H:!
Ste;s ti. rw 7 Are M:rd:tery Scia P:ir.?s U-Jess ~* Po #"I I^IIICI UI' '
C9c .ise 1.. ::::et *ASNT TC-IA u.c e n . a ate d Prc:. R ev. l l l 4//4 (AMl,.//4 . l j
!' He :!r N C E la///
I pr/,f l {
2 Cle:nline ss 3 l Fit Up I r//4 (g// l l Li .ited A::e ss.Elity (Crit e ria )
is Limite: A::ess R e:wir e d Ye s O No C3 - Af4 r//A 3 Purge l
ff/4 l r.//4 l l 3 5l Pre heet l A//I lf//4 a
' l
\
7 l Rect P:ss NDE Pre . R e v. l l l M/4 hr/jj g/4 i l j 1
l g/A l,v// 1 l i 6 Rxt P:ss
, 9 Yle!! Ce rn;te te / h/4 l h/4 ,{ I l l / l .M L *//J4[rp! ]
y 10. Vis uel t .s:ection
) *l l l p//3 - p)/d ,
( i 11 l l .servie. Ins:e etten Pre p. (Criter":
12 l NCE Ins:e ction I Re v. l l l //// ' l /j// 1 'I l e. Li:vid Penete:nt Froe.
- b. L':;neti: P:rtte ct Prec. 4 3 Raf. 4' d l d t$ ! Sl 7/f/7.7 .
~
1 c. Ultr:seni:s Prec./~#' R e v. 6 M l 8[ lg j>/f77~7l { l l1 R:di:grc:hy Pre e. Ra v. C.C.
l g/4 lg/M //4 l -l pj/j lN//.lh/4 C. A. 1 l 13 P:si Y/efd Hect Trect nent Proc. R e v. [r/A ih/A L l I!4 l Atik.:rit ed less e :t er Fir.cl Vis u ct (If Desired) l Viemnq Port Used en Et:cir ' Yes 8 'No (RT fr.tervol ~y M T M chin e S e rt:I N u r-: c r (4.cf 9 a' W E L D IN FCR *.'ATION RECOROS . .
FILLt a McA;/Laf 0,$ g3,gg73, *,7g v :- t . : . re.st4 f t.L,t l @vst: ,rlt@, 337,.
I tw.e .:c t uu. . s.:t tv ct mur:: uci wuwsca l l l 1 l
] >
, l
. l L l , .
- t. ., . . a l l.
l 1
,. . \
. 1 . .
\ .
( /} TRACEAE:LITY REC p { *//S .
I I ~~ ~iECCRCr CF SUAFACE CEFECTS BY MT/PT
} .
- f oc cf Defects '
- 2. Piping veterief s ji. i
' Mc:t Numbers
. . . ;f:c.s re r.:<e d s r#::al a _
c-'*".> m(- go i
. smt ed ty ).1T/PT ; c. u... ;;;E **
. o.s.,
~ \
k NDE Piece Merk 0- '
. ' ' ") .'7 'a m -.
0$mMng Rimf Hect Nurste'r .
k i .m h/4
, <. s
--.f-:
a