ML20082C134
| ML20082C134 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/06/1983 |
| From: | Grier G DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20082C119 | List: |
| References | |
| FOIA-83-434 NUDOCS 8311210474 | |
| Download: ML20082C134 (223) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY CO!CIISSICN i
! BEFORE THE ATCMIC SAFETY AND LICENSING BOARD j ,.
1 i In the Mattor oft )
)
ll DUKE POWER COMPANY, et al. ) Docket 170s. 50-413
) 50-414 (Catawba Nuclear Station, )
Units 1 and 2) )
't.
t DEPOSITION _OF:
GEORGE W. GRIER, III
. g 4 i b July 6, 1983 8:40 a.m. ! ,
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( hDdIhofj74830825 gg AHLERS83-434 PDR
. 1 Evelyn Berger Associates ~% l s STENOTYPE REPORTING CERVICE N '
P. O. BOX 19444
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1 APPC.YJJ.NCES :
2' P.CSEP.T GUILD, ESO.
[ Columbia, S. C.
3-l; Counsel on Behalf of Intervenor, Palmetto 4 ;i Alliance Corporation 5
" g RONALD L. GIBSON, ESO. '
6 ) Charlotte , N. C.
j i
, ; Counsel on Behalf of Applicant, Duke Power Company ,'
8 Also Prese.7t:
9 Glenn H. Bell Duke Power Company 10
, William O. Henry 11 Duke Power Company 12 Roger Ouellette Duke Power Company 13 Michael F. Lowe 14 Palmetto Alliance 15 Phil Joc Palmetto Alliance 16 !
i Betcy Levitts 17 Carolina Environmental .
Study Group 18 19
(
20 21 INDEX 22 Direct Cross 23 Georce W. Grier
~ 4 208 24 25 EVELYN $. SIRGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CHARLOTTE, N. C.
2s 1
Y r II ! B I T S o
- i Pace
(
Grier Exhibit one 136 Grier Exhibit Two 146
. Grier Exhibit Three None 6
% Grier Exhibit Four 173 I! 7
) Grier Exhibit Five 183 8
9 10 11 12 13 14 15 4
16 Il 17 >
18 4
. 19 ! .
( 20
~
21 22 23 24 25 EvtLYN S. BERGER
- OFFICIAL court REPORTER U. S. DISTRtCT COURT CH ARLOTTE, M. C.
3 1
1
- The deposition of George W. Grier, III, is taken at 2 ,l the Corporate Offices of Duke Power Company, Charlotte, North 4
3 I' Carolina, on the this the 6th day of July,1983, in the presence i
4 !
! of Robert Guild, Attorney for the Intervonor, and Ronald L.
5 Gibson, Attorney for the Applicant. ,
6 All formalities as to caption, certificate and .
7 transmission are waived. It is agreed that Lynn B. Gilliam, 8
Notary Public in and for the State of North Carolina, may take 9
said deposition in machine shorthand and transcribe the same to 10 typewriting. Said deposition is taken subject alone to toeti-11 monyy for competency, relevancy and materiality; and objections e 12 save as to the form of questions asked, are reserved until the 13 hearing.
14 IS GEORGE W. GRIER, III, 16 having been first duly sworn to tell the truth, was examined and II tectified as follows:
18 1
19
, DIRECT EYJWINATION '
20 37 gn, ggytp 2'
O Good morning, Mr. Grier. Would you state your full 22 name and business address for the Record?
23
! A George William Grier, III; Post Office Box 33169, 24 Charlotte, 28242.
25 Q Is that at the Corporate Headquarters of Duke Power?
EVELYN SERGER ASSOCIATED. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROLINA
Grior - Dircet 4 1
x y er, ,
2 Q :n what espacity are you employed at Duke Power 7 3 A Corporate Quality Assurance Manager.
4 Q I am Robert Guild, Counsel for Palmetto Alliance.
5 I know you have heard this introductory material; but for the ,
6 Record, as you know, Palmetto Alliance is an Intervenor in the .
7 l l Catawba Operating License case; and I trust you are aware that,
\
8 Palmetto has filed for litigation a Contention Six that questio ns 9
the Quality Assurance in Construction at Catawba?
10 A Yes, I am.
11 O If you would, sir, let's see if we can for the Record --
12 you have been present for a number of the depositions of other la witnesses -- maybe you can run down that list and tell me which 14 depositions you sat in on, Mr. Grier?
15 A I sat in on a deposition of Glenn Bell, Gail Addis, 16 J. C. Rogers , D. G. Becm, V7. O. Henry.
37 Q All right, cir; thank you.
18 MR. GIBSON: Mr. Guild, can we get some 19 procedural matters out of the way? We will proceed P l 20 under the same stipulationc; that is all questions 21 are deemed reserved except as to objections of form?
22 MR. GUILD That is fine.
23 MR. GIBSON: Pursuant to your Notice of 24 Ceposition and our continuing effort to identify 25 documents that might be responsive to your discovery EVELYN SERGER ASSOCIATES. STENOTYPE RSPORTING SERVtCE. CHARLOTTE. NORTH CAROUNA
Grior - Direct $
I I
requests, Mr. Grier is making available to Palmetto 2
some documents that I will describe generally right 3
now; and then you can ask Mr. Grier some specifics 4
if you wish.
MR. GUILD: That would be fine. -
6 MR. GIBSON: Using the July 15, 1982, memorandum
- 4 7
% from C. N. Alexander to George Grier, which discusses
,T g the status of the Welding Inspector non-technical 9'
concerns, I want to identify for you some followup 10 documents related to the implementation of the tion-11 technical recommendations and what I say will basically 12 follow that memorandum, in case you review this with-13 cut the benefit of a transcript later on.
14 In Paragraph la under the General Recommendations, 15 the memo reads, well the memo references a program ir, entitled The Inspector, which will train Incpectors 17 in their. role and responsibilities as it relates to .
18 g the Craft.
19 -
We have made a transcription of the vidoctcpe
\ 20 presentation, The Inspector. That would be the first 21 document. Following in that memo, implementation of 22 a " Teamwork Program."
23 What we have for you is a status memo concernirig 24 implementation of the Teamwork Program, which also 25 varmem +n the wavinna anan4 .
F4 n man.an+m ap +he SWOLYN SSROEM ASSOCa47sB STENOTYPE nePORTHe6 SSRvlCS CMAALOTTE NOstfM CAROufeA
Grier - Direct 6 1
Teamwork Program. I will hand you a copy of that and
~
perhaps you can follow with me as I identify these.
4 As you can see, Number One is a standard hard 4
hat. It is my understanding that has been implemented.
5
, " Adopt logo" we have for you the logo and an -
6 announcement in a document entitled The OA Record, ~
i}-l -
e which is a document newsletter which is referred to' 8
in Item Three of this Teamwork Program memo, so we 9
are making available the newsletter which shows the 10 logo which was implemented and to give you a 11 representative sample of ,the newsletter.
12 Item Four refers to a Bulletin, and we have a 13 copy of that Bulletin as a representative sample of 14 that item.
15 Item Six refers to Employee Forum. This is a 16 procedure involving employees, and we were making
, 17 available a copy of that procedure effective .
18 ,
1 February 1, 1983.
19 ~
Item Seven refers to Out.lity Circle Program, ,
\ 20
~
l and the only documentation relating to this Quality 21 l Circle Program is the May 17, 1982 memo from Grier I
- to W. H. Owen, which basically advises him of the !
i
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Quality circle Program.
24 Also there is a copy of the QA Record referred j 25 l te earlier that else dieca eer the 0"=11ty M w h EVELYN SERGER ASSOCIATES. STENOTYPE REPORTNee SERvtCE, CHARLOTTE. PeORTM CAROUNA I
J
j k
Grior - Dirret 7
ji l
i I
that follows the memo, l
2 . !
The next item refers to increased training, 1 3 i safety first-aid and d velopment. What we have is 4
the Human Relations Training Series for 1983 through 5
~ 1987, Supervisory ar.d Non-Supervisory Employees. '
6 t.h Then going back to Mr. Alexander's memo and ~
7 following, it refers to Paragraph Two, which refers ~ i a
a to Recourse, three procedures are lisi.ed, Documental 9
Recourse Procedure implemented July 1, 1982.
10 Documental Quality Recourse Procedure and 11 Documental Harrassement Procedure implemented July, 12
'82. We have a copy of each of those procedures 13 referred to in Paragraph No of the Recourse in 14 Mr. Alexander's memo and Mr. Grier's.
15 The next item under Paragraph Four of Mr.
16 Ale nnder's memo refers to communications end a 17 program for Supervisors at Catawba for training in -
18 g
a program entitled Effective Communication Skills.
19 ~
As you cc.n see, Mr. Guild, this is a fairly .
en lengthy book which is the course book for that ni Effective Communication Skills series. I would 04
- i I
- simply request that when you have a moment if you -1 23 would take a look and determine whether you.would 24 like a copy of this made and simply want to review 25 it. If vnit wank a ennv. wm t.,411 have that Annar l
EveLYN SERGER ASSOCRATES. SteNOTYPe REPORUNS SSRwCE. CHARLOTTS. NORTH CAROUMA l m . _
l Grier - Dir:ct 8 l l l
I J but it is a fairly lengthy document.
2 Mr. crier reviewed his files again in prepa'ra-tion for the deposition and identified a July 29, 4
l 1982 memo to W. H. Owen indicating the status of the 5
task force recommendations, which we believe was not -
6
-} made available during discovery. -
Also a memorandum of March 2, '82, telephone .
conference between Mr. Grier and a Welding Inspector named Philip Edwards concerning production of documents to Palmetto Alliance.
11 We have a memo to Mr. Grier's file regarding 12 that convernation. Also, Mr. Grier checked with each of the Employee Relations Personnel in the QA Depart- -
ment to see if they had documents which might be Ifi discoverable or might arcuably fcil within the scope 16 cf discoveryr and identified from the file of Mrc.
17 Darbara Horne,an Employee Relations Assistant, a .
g June 2nd, '83 memo regarding her conversations with Mr. recmeter, Eddio Fecmster, a Uciding Inspector; ,
\ 20 and alco a May 6, '83 meno from the file of Debbie 21 Ensley , which discusses a conversation she had with 22 Ken Carter.
23 And finally, earlier during a previous depo-24 sition you referred or asked some questions about 25 the Sten One Pay Reenurse Documents. We are DresentLv EVELYN 3SmotR ASSOCIATES. STENOTYPE REPORTING SsRveCE. CMARLOTTE. feOftTH CAROL 8MA
Gricr - Direct 5
I having those actual documents copied and there should 2
be a copy ready for you this morning.
3 I would simply note that a representative 4
sample on each of those letters which were verbally 5
identical were included in the Gail Addis materials ,
6
! _'}-
and Warren Owen materials identified during discovery;-
7 but we are makintf the actual file of Step One Docu .
8 ments available.
9 During the Larry Davison deposition I!r. Davison 10 produced documents relating to John Rockholt in M 11 1
memo he had written. Upon receipt of that memo by 12 Mr. Grier he wrote a June 27, 1983 memo to Mr. Larry 13 Davison and C. N. Alexander.
14 We are making available tioday a copy of the 15 memo written by Mr. Grier; and for convenience we have 16 attached to it all of the same Rockholt documents H
i produced during the Davison deposition.
18 t
Okay, you may proceed, Mr. Guild. '
19 ,
4 20 BY MR. GUILD:
21 Q Mr. Grier, if you would tell me when you first came 22 to Duke Power Company and the positions you have held, sir?
23 A I was employed in June of 19 69 at the Oconee Nuclear 24 Station. I was responsible there for Welding Inspection, Non-25 i
Destrictive Examination. After that job --
4 EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA
i CriOr - Direct 10 l.i t.
Iy Q Excuse me, what was your job title then, if ycu can 2
recall?
3 A I was hired I believe es an Assistant Field Engineer 4
! and later promoted to Field Enginear.
5 Q All right, can you tell when you got the first pro- ,
8
- - motion? l 7
[ A Not exactly, I would think it was probably Spring of i
l is !
8 1970.
8
- Q All right, sir. Assistant Field Engineer and then 10 Field Engineer at Oconee?
II A That's correct.
12 Q All right.
1 I3 j A And then in May of '71 I was assigned to the McGuire I4
! Nuclear Station as Senior Field Engineer responsible for I6 Construction, Technical Support Function, the Planning and 16 Scheduling Functicns and the Quality Control Inspection Functions.
' I I remained ct McGuire until May.of 1980. My title I
changed in 1974 to Project Engineer. At that same time, at
- I9
. nearly the scne time the Ouclity Assurance Department was ~
- 20 formed and my recponcibility included the Technical Support "I
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area, the Manngement Scheduling area and the Administrative i
l Supervision of the Quality Control Inspectors. ,
23 And then in May of 1980 I was assigned at Catawba 24
- Nuclear Station as Planning Manager. I remained there until l October of 1981 and was assioned responsibility for Manaaement system senoen associares. stumotves necontmo senwice. cuantorre. Nowrw camouma
Gricr - Direct 11 1 of the Oconee Station Support Division.
l 2 In February of '82 I was assigned to my present 3 responsibility as Corporate Quality Assurance Manager.
4 0 All right, sir; and prior to your employment by 5 Duke Power Company would you summarise your professional train-t .
~_ 6 ing and experience, please?
l
) 7 A I received a Bachelor of Science Degree in Phys 19s
~
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8 from Georgia Tech in June of 1964 and I entered the Navy and 9 served as an Officer in the Nuclear Submarine Area for five 10 years until June of 1969 when I was emplo"ed with Duke.
11 O All right, sir; what were your duties in the Navy 12 if you could summarize those?
13 A For a period of time I was engaged in training both 14 at Nuclear Power Scope Proto-Time Reactor Training and 15 Submarine School.
16 After that training period, which was about a year 17 and a-half in length, I was assigned to a Nuclear Submarine and 18 held positions as Electrical Division Officer, Communicator, .
s .
i 19 Sonor Division Officer, Supply Officer and Operations Officer. -
- 29 O Mr. Grier, I want to understand your experience and '
23 qualifications in the area specifically related to first Welding 22 and then Welding Inspection. Are you a Welder, sir?
1 23 A No, I am not.
24 0 Have you ever worked as a Walder?
l 25 A No, I haven't.
SWELvM SENGER AStoctATES. STENOTYPS RSPORTING SERVICS. CHARLOTTE, NORTH CAROUNA
Gricr - DirOct 12 I
O Whet, if any, formal training have you had in Welding?
2 g g ve attended some courses presented by organizationo 3
such as ANS on Welding. I attended a course presented by the 4
University of Tennessee on Welding Metaltaggyanddameconsee 5
presented by Ohio State University on Non-Destructive Examina- .
6 tion as well as Welding Theory. .
7 .
O All right, sir; were those courses during your tenural 8
with Duke Power?
9 A That's correct.
I" Q Civo me an idea of the scope and extent. Were thy II shcrt courses?
12 A The one at Tennessee was one week in length and the 33 one at Chio State was four wocks in length; and I attended a 34 course primarily in Non-Destructive Examination primarily at t r>
Massachusetts Institute of Technology.
II' O Was your work experience involved in Welding or II Supervision of Uniding?
18 A As I said, at Oconee my responsibility included
- I"
. Supervision, Second-Level Supervision of Welding Inspectorc
- tnd Ecn-Destructive Examination Inspectors; and during that {
21 l period of time I attended the training courses such ac the ones 22 I've described plus a one-month training course presented by 9
Babcock and Wilcox centered around the Non-Destructive Examina-04
~
tion areas.
05 I subsecuently was certified as a Level-Threc _.
twtLYN SimQtR ASSOctATES, STSNOTYPS RePosPTING SeRveCE. CHAflLOTTE NORTH CAROWNA
Grier - Direct 13 l
1 Inspector in Liquid Penetrant Examination, Magnetic Particle 2
Examination, Radiography and --
3 O These are basically Non-Destructive techniquer?
4 A Radiceraphy, Ultra-Sonic Examination, Magnetic Particle 5 Examination and Liquid Penetrant Examination. .
6 Q All right, sir; how about in the area of visual .
7 inspection of welds? ,
8 A In the area of visual inspection, alot of the train-9 ing involved inspections such as magnetic particle and liquid 19 penetrant inspections centered around the adequacy of a we.16.
Il for those inspections; and there is quite a bit on the nature 12 of welding defects, volume, metrics as they would relate to 13 radiography and ultra-sonic and surface defects.
14 Q Have you ever been certified as a Visual Welding II' Inspector?
I6 A No, I have not.
II Q Do you hold yourself out as qualified to perform 18 Visual Inspections of Welds? -
I9 A *
. Mot at the present time.
2" Q Have you ever been so qualified in your opinion?
21 A I've never been certified with Duke Power Company tc >
22 perform visual inspections, so I've never performcd that 23 inspection. In the training, education and certification in 24 regards to Non-Destructive Examination Techniques, I became 25 very familiar with the visual standards and was well versed l
EVELYN SERGER ASSOCIATES, STSNOTve n. 4 TING SSRVICS. CHARLOTTS. NORTH CAROUNA
(
t _ .- -
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Grier - Direct 14 i
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l in those standards.
2 Q Mr. Grier, tell t e when in your work with Duke that 8
you have supervised Inspectors in the Welding area.
4 A At Oconee during the period that I have already 5
mentioned I was a Second-Level Supervisor of Welding Inspectors. .
And then during the period of time at McGuire that I mentioned -
-}3 .
I was, I supervised the Manager or Senior Quality control 8
Engineer, who among other Inspectors, had Welding ~ Inspectors reporting to him.
10 And then in my present assignment, of course, there II are Inspectors in the organization.
12 Q llave you ever had responsibility for reviewing the la Inspection documents originated by Welding Inspectors in your I'
work for Duke Powcr Company?
16 A In my first assignment at Oconec I had responsibility 16 for reviewing the Incpcetion Records generated. That in the only time that I have had a direct responsibility in my ascign-y ,
ment at McGuire.
19 l
I reviewed ocsmo documentation on occasion, but that
'o l.
o was not a direct responsibility that I had.
al
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i Q So in approximately '69, '70 your first two positions with the Company, you did some actual review of Welding Inspec-l tion documents?
24 A That's correct.
25 O When you were at Mennfra warm vnn-rmennnafhlm for BVELYN SERGER ASSOCIATSS. STENOTYPE RSPOftTING SERVICS, CHARLOTTE. NOfrTH CAROUNA
Grier - Direct 15 3
supervising all Quality control Inspections?
A Yes, I was administrative 1y after the Quality 3
i _ ._
3 Assurance Department was organized in 1974.
4 O How about functionally?
3 A Prior to the organization of the Quality Assurance 6
Department, both the Technical and Functional Direction of p .
7 the Quality control Inspection rested within the Quality -
g Assurance Department.
9 We had, not reporting to me, a Quality Assurance 10 Engineer who rsported to a Manager in the Construction Depart-11 ment's General Office. But as far as the Technical and 12 Administrative Direction of Inspectors, that rested in my 33 organization; and of course, in '74 that was reorganized, the 34 Quality Assurance Department then was responsible for the 15 Technical Supervision and Direction and Construction for the 33 Administration.
i- Q Is that the way it remains at this time?
l ig A No, in February of 1981 the Quality control organi- -
~
19 zation was con.bined with the Quality Assurance Department so .
2o at the present time Quality Assurance is responsible for both l
21 Technical and Administration Direction of the Quality Control 22 Inspectors.
l 23 Q Mr. Grier, describe for me the circumstances in which 24 you became Corporate Quality Assurance Manager.
I 25 A Well, I had an interview with Warren Owen, who is EVELYN SEMOER ASSOCIATES. STENOTYPE MSPORTING SERVICE. CHARLOTTE. NORTH CAnOuMA
Crior - Dir0ct 16 I
I 2
present Executive Vice President of Design and Construction.
And af ter that interview he asked me if I would be inter 4
in taking the position of Corporate Quality Assurance Manager .
5 I told him that I would be and he indicated that I would be
- assi ned to that position effective February lat, 1982. '
6 Q
.I 7 And when was that interview approximately? ~
A 8
The last week in January, I'm not sure of the exact date; the'last week in January of 1982.
9 Q
Why had that position become available?
10 A
11 The Institute of Nuclear Power Operations, INPO, 12 was at that time beginning to put into put into place what they I*
termed as Phase Two, that being the evaluation of the Design Construction Phase of Nuclear Plant Operations, and Mr . Owen I4 15 was on a Guiding Committee for the Phase Two implementation .
16 As I understand it there was a need for a highly 17 qualified individual who.was familiar with various phases of I
that Design Conctruction Operation, and he had decided that -
I9 Mr. J. R. Wells, who had been, who was Corporate OA Manager at
. ~m that time, had the Quality Assurance background plus'a Construc e
'l tion background, as well as having an Engineering education 22 and with those qualifications, decided that Mr. Wells would be 03
~
an excellent candidate to be heavily involved in the implementa--
tion of that Phase Two 24 So he obviously made a decision to make Mr. Wells a
vailable for that oositione and then it was dataminao tn niacet EVELYN SERGER ASSOCIATES. STENOTYPE REPONTING SERV 9CE. CHARLOTTE.
GriCr - Direct 17 1
me in the Corporate Quality Assurance job.
2 O What was the nature of your working relationship widi 3 Mr. Wells", Mr. Grier?
4 A I'm not sure I understand the question. What period 5 of time?
6 0 Well, at the point when you became Corporate Quality
- Assurance Manager?
s A After I became Corporate Quality Assurance Manager?
9 0 No, before, sir, m A Well, at the immediate time before my assignment es 11 Corporate Quality Assurance Manager.I was the Manager of the 12 Oconce Station Support Division; and in that assignment I had ja no Quality Control Inspectors.
y In other words, there was no individual in the Quality 15 .,ccurance Department reporting to me. My interface with the m Quality Accurance Department was mainly with the Senior Quality j 1- Accurance Engineer at the Oconee Station; and I had during that is period of time between October '81 and February of '82,very ,
t 19 little contact with Mr. Wells. .
l 20 Q okay, prior to that pocition?
l 21 A Again, as a Planning Manager at Catawba, my activities 22 were not highly interfaced with the Quality Assurance Departmen<::
I zi and other than some conversations when he would visit the 24 Catawba Station, I really did not have any dealings with him.
m O Let's focus on that period you were at Catawba, EVELYN BERGER ASSOCIATES. STENOTTPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
GriGr - Dir:Ict 18 I
1 except for the October '81 til February '82 you were at Catawba?
2 A Prom May of 1980 until October of '81.
3 O As a Planning Manager what was your area of responsi- -
4 bility?
5 A I was responsible for maintaining and refining the
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6 Construction Schedule and Resource Budget for Catawba, establish-y .
7 ing milestone dates and production rates and that sort of
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8 thing, directing the sequence of work for the Craft Organiza-9 tions.
10 Primarily that did involve scheduling work for the 11 Support Groups that support the Craft function.
12 Q Such as Inspectors?
13 A The schedules that we produced were sent to the 14 Quality Assurance Group at Catawba so that they could understand 15 what sequence of inspections needed to take place, what systems 16 needed records reviewed for subsecuent turnover to the Operations 17 area.
18 0 Is it fair to understand then that in part your .
19 responsibility was for scheduling of the Inspection function? -
20 , A The scheduling that we did did point out to them 21 what sequence of work they needed to perform so that schedules 22 reproduced were the documents they used to understand their 23 work schedule. l 24 O And from which their work schedules were derived?
i 25 A That's correct. j l
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA i
l \
1 Grier - Dircet 19 1
Q All right, help me understand how that function 2
worked, Mr. Crier. You established a series of constructien 3
milestones, and to accomplish those milestones not only did 4
certain Construction activities have to take place, but accord-5 ing to procedures, certain Inspection: functions had to support .
6 7
those Construction activities. -
7 Is that generally true? .
8 A That's correct.
8 Q How would the Welding, let's take Welding as an area.
IU and enemple; how would the schedule of an individual Welding II Inspector be derived from your scheduling decisions in 19
~
Construction?
I3 You gave me kind of a thumb-nail sketch how one would I4 derive from the other.
I0 A All right, the Welding Inspectors were accigned 16 by the Qunlity Accurance Department to work in creac of the II Plant. As the Crcft hcd work that needed inspecting,ac they
. finished work and it needed inspecting they would inform the Incpectors and the Inspectorn vould perform their incpections "
s .
so essenticily the Uciding Inspecterc were en a call basic.
oi The Quality Assurance Management basically would 22 take the schedules that we produced, loch at the volume of 03
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work that was likely to be generated by the schedulos and make I
e4
~ l sure they had sufficient nudber of Welding Inspectors assigned i 25 to an area to cover that volume of work.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SEPVCE. CMARLOTTE PeORTM CAROWNA
Gricr - Diroet 20 I
The Craf ts would then, the Inspectors had what we 2
call sign-up sheets. The Craft, if they weren't able to 3
communicate directly with an Inspector, would say what activity 4
needed inspecting, and the Inspector would perform that activity.
6 So the Welding Inspectors do not have a schedule .
6 precisely, but rather were called out by the Craft to perferm .
those inspection activities. .
8 0 If I am a Welding Inspector and come into work the 9
first shift in the morning, how do I know where my area of work I"
is to be? What documents would reflect scheduling instructions to me?
I2 A Ac a Uciding Inspector you would likcly not see a 13 scheduling docun.cnt. You would be assigned to an area and that would be a long-term assignment, generally; so you would know 15 what area you were to work in.
16 The Criftc would bc cdvicing you of work they had I
finished to the point they needed an inspection done. You I8 a would do that inspection and perform your activities in that
- 19 -
. mEnner.
oo
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Q What do you menn by long-tcrm; give me an idoc what 91
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that wocid mean. _ s A As fur as assignment to nrecs, yes; possibly a year 91 or longer.
04 l Q By ttn arca, do you mean a particular system or sub-l l 95 l system of the Plant?
I avstyn asnos a associate s. stemorves aerontimo saavies. cuantorts. moarw camouma
l l
Grier - Dircct 21 l l
l 1
f A No, an elevation or rather a particular floor, the 2 first floor of the Auxiliary Building or the operating floor 3 or area of the Reactor Building.
4 All right, how would the sign-up sheets that you Q
5 referred to relate to a schedule of a Welding Inspector?
6 -
A As I say, first a Welding Inspector, the Welding -
7 Inspectors work from a particular location where they have a ,
8 desk and some areas to keep their procedures and materials and 9
equipment they use for their Inspections.
10 The sign-up sheets would be located there. If when 11 a Craftsman had a weld or activity that needed inspecting and 12 came to that area and found no Inspector available, they would 13 write down the description of what needed inspecting, the 14 location; and as an Inspector came back from another assignment 15 he would see that sheet and go and inspect the next work 16 activity that was on the sheet.
17 O All right, sir; now what would be the first level 18 of Supervision above an Inspector; in tlnis case, a Welding .
19
, Inspector that would have a scheduling document available to -
- 20 him?
21 A The Supervisor would have those schedule documents.
22 O Would that be the Technical Supervising Technicians?
23 A Supervising Technicians.
24 Q And what would that document consist of?
25 A That would be a document that would show the EVELYN BERGER ASSOCIATES. STENOTYPE REPONTING SERWE. CHARLOTTE. NOsrTM CAROuMA
Grior - Direct 22 i
i i
sequence of system completion, particularly pointing out mile-2 stone dates such as completing a system to begin flushing or l 3
fibrostatic testing or turn over of that system to the Nuclear 4
Production Department.
5 Q What would that document be called? What is the ~
6 name of it? ~
~
7 '
A I'm not sure what it is callad now. I think that 8
we termed it the Testing and Turn Over Schedule Document.
9 0 Is that a computer-generated document?
10 A The actual document, it is not. The testing logic Il and sequence is on a computer program; but we did not generate 12 and still do not generate these documents directly from the la computer.
I4 O And is this the same schedule that would be used by I^
Construction Craft Supervision for scheduling purposes?
16 A Yes, it is.
II O And the same document that is used by more Senior I8
. Management in the Company to monitor Construction completion? -
I9
, Is There are scheduling documents that are less detailed ^
2k that give Senior Management status of milestones. The document 2I I've described would be available to Senior Management to 22 r,yg,y,
~
23 0 All right, give me some idea of what the size of 24 the testing and turn over schedule is you have referred to. Is 25 it a telephone book?
EVELYN SERGER ASSOCIAT A S. STENOTYPS REPORTING SERVICE. CMARLOTTE. NORTM CAROUNA
__________________.__-._____---__o
Gricr - Dir:ct 23 I
A Well, the document that is generated and given to 2
the Supervision that I have described probably would be standard 3
eight and a-half by eleven sheets, each sheet indicating the 4
schedule for a particular system might have twenty or twenty-5 five sheets or twenty or twenty-five systems at a time. .
6
_ That esentially is a slice out of the entire project -
schedule. The schedule only looks ahead a certain period of .
8 time, maybe ten to twelve weeks, the document that is given 9
to the Supervision.
IU Q Dy that we are referring to the First Level Super-visor, the Supervising Technician?
I2 A That's correct.
la O Would it just be in the particular systems that his crew were assigned to work on?
A I believe each Supervisor would get the entire package.
O Ilow is Production evaluated and monitored for Craft '
- at Catawba?
- A Well, there are units of mer.surement that relate to no
~
ecch type of work for the electrical area. For example, that oi
~
unite maybe number of cables pulled, number of connectors 04
~~
te..minated.
I 93 The scheduling organization computes the units that 24 need to be produced in order to make the Schedule. Actually it os
~
is the other way arounds the schedule is made. Dassed on to the l
EVELYN BERGER ASSOCIATES. STENOTYPE RSPORTING SERVICE. CHARLOTTE. NORTM CAROL 8MA
Gricr - Dir0ct 24 I
productivity that can be generated by the amount of resources 2
that can be placed productively into a certain area. But as the 3
work is ccznpleted the Craft report the number of units through 4
methods that we have for reporting, and that is then calculated 5
and the basic productivity is monitored from that information. ,
6 Q And is that productivity a measure derived for each .
Craftsman? .
8 A No.
Q Is a measure derived for a major unit of the Craft Organization 7 11 A Each crew can be measured. A crew would be a 12 Supervisor and maybe a dozen Craftsmen.
'3 Q Now give me, if you can, in the general Craft areas, the units of measure that are employed. You have used --
A Electrical I've mentioned already.
Q Ycs, cir.
A In the Civil area we use tons of reinforcing steel I
S placed. We also use yards of concrete placed, square feet of -
I" ~
. form wcrh crected, tons of structural steel erected.
. on In the Instrumentation area we une number of instrument
1 loops erected. And in the Welding area we use the number of ecsentially the number of welds that are made. The welds are
'n
~
standardized based on size and diameter of the pipe and thick-
.n
~
ness of the piper and we use a standardized weld so that each m~
weld is not counted as one weld, but rather a narcentace of EVELVN SdRGER ASSOCIATES. STENOTYPE REFORTING SERVICE. CHARLOTTE. NORTH CAROUNA
Cricr - Direct 25 J
I an equivalent standard weld.
2 O How.about giving me a realistic example of how that 3
standardized unit of measure for welding would be computed?
4 A The schedule would indicate that a certain number of 6
equivalent welds would need to be produced in order to make the f'
schedule as the weld documentation is signed off and comes back
~ '
7 for processing, the number of equivalent welds made would be 8
computated and compared against the sched'le. u O As the term is generally employed, equivalent welds - -
'" A I can't recall right now the precise term we use.
II I may recall it.
12 0 Okay, help me understand what is the standard 1;acic.
I3 A Excuse me, weighted value in the term we use.
Q Yeah, how would you use that term in connection when
"' referring to welds?
I' A Well, the schedule might call for ten weighted value 17 to be reduced for smc11 diameter piping that might equate to S thirty welds for large diameter welds. It might equate to half -
I" *
. a weld.
. '80
~
Q What is the standard unit that establishes the
~>n standardized unit of measure in welding; do you know?
- o. ,
~~
A 1 am sorry.
.y' What is the standard six-inch pipe, is it a three-O
.,4 inch wold or -- i 25 A I am sorry. I don't recall the standard.
1 SWELTN BS AGSM ASSOCIATES, STSNOfvPS RSPOmflNG SSIBWICS. CMARLOTTS. NONTH CAROuesA
Grict - Direct 26 I
Q It is based on the dimensions of the weld to be 2
i performed?
3
, A It is based on the diameter of the pipe and thick-4 ness of the pipe.
5 Q All right, sir; now for the Quality Control Inspection, what if any standards of production are employed? .
A There are no standards of production developed by ,
8 the construction Management Group for Quality control work.
9 Q Are there any standards of production developed by 10 anyone?
A There are targets for productivity, for production I
that are established by Quality Assurance Supervision as they 13 analyze the scheduling documents produced by the Construction I4 Department.
They may see in the area of Radiography, for example ,
16 that they would need to radiograph a certain number of welds I
per shift and will establish that as a goal or skandard to meet ,
18 P
. O And what would the unit of measure be for that -
19 -
. target?
~
. oo
~
A 1: umber of acceptable radiographs.
- l Q How about for visual inspection?
l A Those, I don't believe there is a standard produced
~
23 for those because the Welding Inspectors are assigned in the 24 areas to inspect the volume of work that the Craft generate, ,
, and by marianing a sufficient nm har of Ynnometers to the area.
4mm u.a . .noe .n.. m onn = m ==.e.. c .u>m. - ca.ou s
t
Grior - DirOct 27 I
they match the Craft production.
2 O What would then form the basis for a measure of 8
productivity for a visual inspection function with the matching l Craft?
5 A That's correct, but there really is no measurement 6
rE their production or productivity. .
~ "
Q Let me understand this: would that be unique to ,
8 the visual inspection of welds, or is that unique to all 9
Quality control Inspections?
10 A That is not unique with the Welding Inspectors, but 11 in other areas such as Radiography or Hanger Inspection, there I
are production standards that are laid out or rather the Quality 13 Assurance Supervision can see the volume of work that has to 14 be generated and set some standards for the Inspectors to go 15 do the Inspection welding, Inspection or Visual Inspection is 1G different from the others in thr.t there are hold point types 17 of inspections and work cannot proceed until that Visus 1
. Inspection is performed. -
~
, For an activity cuch as Hanger Inspection, a back
~
- "O
~
log of work can build up and the Inspector can go do the
l
~
Inspection without essentially, I will say, interfacing with 22 the Craft Production efforts.
93
~
So for those types of situations Radiography, Hanger
~ 4 l
Inspections,would be another one, Instrument Loop.' File Inspec-25 l tinna would be another. Einem there is no held neint tvoe of
(
.m.......... m.. - .c,.u,m. - -
l l
l L-________ _ _ __
Grier - tirect 28 I
relationst.ip with the Craft, the Quality Assurance Organization 2
has to be careful that we are not building a backlog of unin-3 spected work and therefore we do set some standard of number of 4
loops we need to inspect per shift or whatever.
5 0 All right, what other areas beyond the Visual ,
6 Inspection of welds are not the subject of either production .
I goals or targets by Quality Assurance Supervision) 8 A Well, the inspection of concrete pours would be an 9
example. That is not a hold point type of situation where the Inspector must be present as the activity is taking place, so the Inspectorc are assigned to work as the concrete is being 10~
placed, and there will be no productien-type goals set for that 33 activity.
Q All right, how about any others?
I A Something like the Inspection activity that goes on 36 during a Hydrostatic test, that again is a cituation where the
'I Inspector must be present as the activity is being performed, 18 so there is a hold point, no production type of goal is set -
~
. there.
. oO
~
Q Okay, how about any other Construction-type cetivities?
- 1
~
A I'm sor: y?
O of the same character, any other Construction-type a3
~
activities of the same character? I understand you to say with
.y
~
hold points the Inspector needs to be present and it is not appropriate to set production coals.
SWELYN SERGER ASSOCIATES. STSNOTYPE RSPORTwe4 SERVICS. CHARLOTTE. NORTM CAROUMA
Grior - Direct 29 I
A Visual concrete pours, hydrostatic testings; I can't !
2 think of any others.
3 Q How about anything in the electrical area or instru-4 mentation area?
8 A I believe that those activities are not hold point-8 typa of activities. Therefore they will not fall in the same .
~ '
7 category. ,
8 Q Now I understand that it was earlier believed by the 9
Company that it was appropriate to place the Quality Control 10 function of Construction und3r the Construction Department for Administrative purposes out of a need to effectively schedule 12 works is that correct?
13 A Well, essentially I believe the decision was based more on the fact that there is a general need to work overtime I5 in Construction activities, and that it would be more convenient 36 for the Construction Organization to schedule all that overtime-type of work; and therefore it was thought that it worked best 38
. if the Construction Organization was able to staff up the -
I9 "
. Quality Control Group with sufficient personnel to perform the
- 2 work ct the rcte that Constructien was scheduling it to be done:
2' in addition, to be able to assign and schedule overtime work
.n as needed for the amount of work that the Crafts were performing.
23 O And this was the judgment that underlied the 2'
organization of the Quality Assurance Department in 1978 with 25 respect to the QC function?
. m v,... .....oe..n . on n - .mc..c - m. m.c. u
Grier - Direct 30 I I
1 I
I A I believe so.
2 Q And that organizational structure was changed; was in 3
not?
4 A Yeah, in February of 1981.
5 Q And withangard to this matter of scheduling the QE ,
function, why was the reorganization performed?. .
A I y sn't involved in the decision to reorganise, so .
8 I don't know the specific reasons that the appropriate Manage-9 ment decided to make the change.
10 Q Who would know?
11 A I would expect that Bob Dick, Warren Owen and Jim Wells would know.
13 Q All right, sir; what is the impact, as you know, if 14 you know, of the reorganization on the efficiency of scheduling' 15 of the QC function 7 16 A There has not been any adverse impact that I've noted.
17 We have, since we have added a Plannir.g responsibility to the .
=
Catawba organization that was not present previously, we have
- ebout.three people who are assigned, not classical Quality Assurance functions, but rather the function of taking the 21 scheduling documents, the scheduling plan produced by construc-22 tion, and making sure that is in the form that it can be under-23 stood by the Supervisors and the Quality Assurance Department.
24 These individuals interface with the Planning 25 ornanimat4nn una r'anntene&4nn en make mure &he num11tv Amanranm evetvw manaan associares. stewovves nerosmme senwice. cuantorts, nowrw capouna i
GriOr - Direct 31 I
correctly interprets the schedule and will have sufficient 2
recourses available to match the construction schedule.
Q Who would those people be by_name and title at 4
Catawba?
5 A The Planning and Scheduling Supervisor is E. B. Millo r .,
6 He has a Technician working for him named Ray Williams and a -
Clerk; and I'm sorry, but I don't recall the Clerk's name right .
8 now.
8 O And Mr. Millar's title?
10 A Manager and Scheduling Supervisor I believe, I'
And he works in the Quality Assurance Department?
~
Q A That's correct. Reports to Mr. Davicon.
O And Mr. Williams, if you know his title, please?
A I believe his title is Scheduling Expediter, I'm 15 not sure about that; but I believe it is.
16 Q Mr. Grier, how long has that Planning and Scheduling 17 function under Quality Assurance been in place at Catawba, if
=
you know?
- 19 .
- A Mr. Miller was assigned that responsibility in
- 90
~
Sepcember of '82. Mr. Williams came earlier than that, I 21 think about June,of 1982.
22 O All dght, sir; and before they were assigned that 93
~
responsibility how was it carried out or who did it?
o4 A The Supervision and Quality Assurance had the 95
~
function of receivine the scheduline information from the evitvu ...aen assocuns. sumows a.m.nwa sonnes. cuantom, no=ra camouma l l
1 Crior - Dircet 32 l
I Construction Department and analyzing it for their area of 2
responsibility to be sure that they understood scheduling 3
requirements and what their particular group needed to do to be 4
responsible for the scheduling.-
5 They also attended schedule meetings in which the 6
status and projection of schedule plans were presented. .
Q I want to understand, Mr. Crier, how current produc- ,
8 tion schedules or ratings for completion of various pieces of work, using the standard units of measure that you have referred 10 to, compare ct present at Catawba with somo cther periods of II time in the past.
1~0 Do you undcr:tand generally the area I am interested I
in?
14 A Let me see if I understand. You are interested in 15 productivity Ucights on the part of the Craf t?
16 0 Ycs.
17 h UOW versus some particular time in the past? ,
I
= O Yoc, gene. rally. -
19 '
. A 1 don't review that informaticn commonly. Kow I do
' ~
cttend the periodic Prof eet EcVicu Mcetingc that are held, and 91
~
there is some precentation of that information in regard to the current production.
93
~
But ac far as production in the pact, I can only 94
~
l rely on my recc11cetion from seme years ago, and well, to tell you the truth. I really cannot tell vou how the productivity l . ~ , ..-..... ,,,.. .,. ,- - - ... ... - ~. - ,,.e, -
l l
Crior - Dirset 33 1
compares now with some time in the past. There has been an 2
increase in production in the Hanger area, for example.
3 But then there has been an increase in the resources i 4
placed on that activity; so how that would relate in number of 5
Hangers per work hour, I can't say. ,
. l 6
0 Is it fair to conclude that Construction at Catawba ,
- 7 is moving faster than anticipated or then expected, given the 8
prior scheduling milestones?
l 9
A No, I don't believe so.
I" O Well, for instance, Mr. Grier, we undcrstand than II the Company informed the Planning Board and the Operating 12 Licensing proceeding that the scheduling for completion and I3 fuel loading has been advanced by some four months. Do you I4 krmw that to be the case?
18 A I den't know if four months is right or not. I know 16 that the fuel lond date has been advanced over one immedictcly II preceding that announcement of the advancement.
I8
. 0 Right, are you aware of any prior occasion at which .
I" Construction completion has been advanced at Catawbc? -
- oo A Uc, I'm not.
91
~
0 Are you aware of any prior instance where constructic'n 22 completion has been advanced at any other facility that Duke al
~
has constructed?
04 A I am not personally aware. I don't know whether it 25 has happened or not.
EVELYN SERGER ASSOCIATES. STENOTYPE REPOSETING SERVICE. CHARLOTTE. NORTM CAROUNA
1 Grier - Dircet 34 l!
- 1 '
0 Are you aware generally of Construction more 2
. , frequently being delayed?
i 3
A Yes, I am.
4 0 At catawba previously?
6 A Yes.
8 0 And at McGuire and oconee? ,
7 A Yes. ,
~
8 Q Generally would you agree that at all of those 9
facilities that Duke has constructed, completion schedules have 10 been put bach repeatedly and actual completion has been delayed 11 some years over the initial planned completion dates? Is that n 12 fair characterization?
13 A I agree generally the schedules have been delayed 14 over the initial expectations of the projects.
15 0 All right, what is your understanding of the reason 16 why, by contract at Cattwba, the schedule has been advanced so II nuch?
18
. A As I said, the announcement of the pulling back of -
19 '
, the fuel load date was a pulling bcch from the latest current
" schedule information. Ac I recall there had been not long before 2I that a delay in that date; so in fact, the current fuel leading 22 date is not much different from the fuel loading date that was 23 in effect when I was the planning Manager at Catawba.
94 For example, I don't _ remember exactly the date when ::
25 was there, but in other words what I am describing is that the mu .. .. ...oe .. m om. .o== c.c =m. o= caaou
Gritr - DirOct 35 l
date through some analysis was pushed up in time and then a o
subsequent analysis said well, maybe that amount of time we 8
pushed it out was not entirely valid.
4 That is one of the observations I make about a 5
situation. The other, of course, is that there was a decision ,
6 by Construction to reorganize the way they managed the project. .
That has had some impact on the ability to perform work on ,
8 scheduh.
8 Also Craft persons as well as Inspectors and Quality 10 Assurance personnel have become available frem the McGuire Project to place at the Catawba Project.
12 0 licu abcut from Cherokee?
13 A There is a number of people who come from Cherokee, 14 but that occurred really prior to this recent announcement of 15 this schedule improvement.
ir, o There has been eccentially no construction nctivity at Cherokee for como time?
- I8 A That's correct. -
l 19 -
O And any trancferc from Cherokee to Catawba wculd have
. ,,o
~
occurred chrlicr?
ol A Yec, I don't recall the time frame but essentially
! at the time ve announced the curtailment of work on Unit One, i
I O'}
~
I can't recall e::cetly when it was.
l 04 0 All right, give me a rough idea if you know, Mr.
l os
~
! Grier, how many Craft have transferred from McGuire to the 1
l svstem esnaan associatss. stamoryps neronvues senwes. cMAntoTTs. Montw canoLueA
Grier - Dircet 36 1
Catawba Project?
2 i A This would be a very rough guess, and let me put somo 3 time frames on it. I would say in the last, since the first of 4 the year, there has probably been Fifteen Hundred or so.
5 Q And roughly how many Inspectors, Quality control
'6 Inspectors from McGuire to Catawba? ,
7 A In round numbers, I would think Pifteen to Twenty. ,
8 O All right, sir; now do you recall previously a fuel 9 load target of October, 19847 10 No, I think that was the one that came out of an A
11 analysis that was completed in the period of time that I was at 12 Oconee. I don't think that was the target date when I was the 13 Planning !!anager there.
14 0 Uould that, if you accept October '84 as being the 15 previous fuel load target, would that have be en the target that 10 reficcted the anticipated slippage that was then regained 17 essentially which you were describing earlier? Does this sound 18
- right? -
19
, A I would think so, yes. *
~
29 C Do you know anything cisc about the basis for the 21 anticipated clippage to the October date, or whatever date it 22 was before it was then more recently advanced to the previous 23 projected completion date?
24 A I don't know anything specifically about that analysis.
25 I would expect it was an analysis similar to the ones that were
...o .. . .noc .n.. .n orm - n.v ca. c= unn. r ca.ou
Gricr - Dircct 37 1
1 performed when I was Planning Manager.
2 Now tell me what you. meant by the Construction Q
3 Reorganization at Catawba.
4 A The Construction Organization has been a pretty 5
classic pyramid-type organization in which the Project Manager 6
had a Craft Organization with Craft Supervision at variour ,
7 levels, a Technical Support Organization with the same sort of ,
8 pyramid structure, a Planning Organization similar structured, 9
and Administrativo area.
19 The Conctruction Department decidad to put in place 11 a matrix-typc of organization which involved individuals within 12 the Technical Support Organization and within the Planning 13 Organization actually becoming part of a Unit Organization that 14 included Craft Supervision, such that one Manager who may have 15 responsibility for Unit One Rcactor Building would not only in 33.tc the Creft ccsigned to do the work in that building, but II would he.ve enginecra and technicians rerponsible for developing 18 l
Construction procedures and communicating with Design Engineering.
l 19
, as necd be to rer.olt'e problems. '
~ 20 That percon would clso hn?c come plenning individual a 21 capable of producing deteiled schedulet for that work.
l M O And when wac this reorganization implemented?
23 A In the June / July /Aucunt time frame of last year.
24 0 Of 19827 U A I belicyc that's correct.
EVELYN SERGER ASSOCIATES. STENOTYPS REPORTweG SGRvtCS CMARLOTTS. PeORTH CAROUNA
Grior - DirGct 38 1
O Were there any significant changes in personnel responsible for the new organization?
3 A Within the new organization there were some key 4
individuals from the McGuire Organization that came and fillad 5
some slots in that new organization. ,
, Q Who were the key McGuire people? -
A The individual who was the Senior Construction .
8 Engineer at McGuire came and became responsibic for the Unit 9
One Construction activity; and by that I mean that this'percon 10 was responsiale, is responsible, for supervising the Unit one 11 cctivities, including Craft, the Technicians and Engineers.
12 I have described the Planning people who were matrixed 13 into that organization. The individual who was responsible for 14 Planning and scheduling at McGuire came into the Planning 15 Organization ct Catawba.
16 inc Construction Engineer responsible in the Mechanical 17 icchnical Support area at licGuire was assigned at Catawba and .
18 is recponsible for the supervision of these Engineers and
' ~
19 -
Technicians who were matrixed into this Construction Unit that '
20 l've cescripci.
I 21 1
The Ccnetruction Engineer responsible for Hangers at 22 McGuire was assigned in the Hanger area at Catawba. Those are 23 some of the key reassignments.
24 O Let's see if we can put some names with those peoplem 25 tchn vnn the Anninr ennnernetinn Pnninmar?
Evf LTN SERGER ASSOCIATES. STENOTTPE REPOsmhG SERWCE. CMARLOTTE. NORTH CAROUNA
c riar - Divaat 39 l
1 A T. E. Touchstone.
2 Spelled like it sounds?
O 3 A Right, Touchstone.
4 O All right, sir; and Planning and Scheduling?
5 A That was T. L. Hunt.
6 O And Construction and Engineering Mechanical Structural?
.' 7 A That is 3. E. Bright, B-R-I-G-H-T. {
. t
- 8 O And the Hanger area?
9 A That was II. L. Wallace. 3 10 Q Any McGuire people in the Weldintr area?
11 A tio, I don't believe co.
12 O now, did thene key people displace persons previously 13 responsible at Catawba?
14 A Uo, these were pocitions created by this different 15 arrangement of crganiration and Construction.
10 0 row did the reorganication affect the respencibility 17
, er et thority of the Project Menarcr?
18
, A There was no difference in his responsibility or .
19 authority. '
20 .
0 n w did thir reorganizatien nffect the Ouality 21 Assurance area at Catawba?
22 A There was no affect on our authority or support crea.
23 0 How about on the organization of the Ouality 24 Accurance?
25 A As I mentioned, we determined that we needed to evetv .. .....oci.n. .r =on m ..e..e . con.. m.ca oun.
i Cricr - Direct 40 l
l I
assign some full-tiwe personnel in the Plannip--type area. We 2
did make an organizational change at Catawba, net in relction-3 ship to this Construction Reorganization, but rather because we 4
have people available in the McGuire organization as that 5
activity decreased at McGuire.
6 O All right, and what significant changes came about 7 '
in QA at Catawba in that manner?
8 A We assigned the person who had held the task of 8
Senior Quality Assurance Engineer at McGuire, that being the
- Senior position in QA at McGuire. We assigned thet percen Oc II the Quality Centrol Superintendent; and this person supervises I2 all of the Inspectors at Catawha cnd reports to the Project 13 QA Manager. At the same time we eliminated the position of 14 QA Manager Projects, that being the position that supervised 15 the Catawba, McGuire and Cherchec Conatruction Quality 16 Assuranco Effort.
I Uo climincted that position. Che remaining I8
. Construction Quality Assurance activity at McGuire was placed .
, under the Operr tionc QA Division, who had beco e well staffed - -
- ao at McGuire; and that percon Uho held the CA Manager Project "I
~
pcsition was then :scigned as the QA Manager at Catawba responsible for the Catawba Quality Assurance activitics, also
- 3
~
for the Quality Assurance effort that remains at Cherokee.
94
~
At the same time we made that change, in addition 25
, to the Plannine Supervisor we reorganized or rather had the EwELYN SERGER ASSOCIATES. STENOTYPE REPORTHeG SEnWICE. CHARLOTTE. MONTN CAROUNA
Grier - DirOct 41 l
I surveillance, our QA Surveillance Activity Supervisor report 2
directly to the Project QA Manager instead of to the Seriior QA 3
Engineer. ,
4 So essentially in that organization we put a Quality 5
Assurance Manager on site at Catawba. Reporting to him is the
~
6 Quality Control Superintendent, the Senior QA Engineer responsib le.
~
for technical activities and Record Administration and a Plannirgr "
~
8 Supervisor and the Surveillance Supervisor.
9 There is also an Employee Relations Assistant who 10 reports to the QA Manager.
11 0 I think I missed the QA Technical area.
A That Uas the Senior Quality Assurance Engineer.
13 O Ee became Quality Control Superintendent?
14 A I'm sorry; the Senior Quality Assurence Engineer 15 at McGuire becamc the Quality Centrol Superintendent at 10 Catawba. 7.le Senior Quality Assurance Engineer at Catawba 17 n.cintained that titic, but the respcnsibility involved the
=
Technical and Record Adninistration. -
. R And the Superintendent position is a new position?
' oo
- i. 2 hat was a nc.w pccition.
21 Q And that took some of the responsibility from the Senior QA Engineer?
"3
~
A That's CorrCct.
94 Q Iielp me understand, first 1c 'c fill sene names in.
95
~
Who is now the OC Superintendent?
EVELYN BERGER ASSOCIATES. STENOTYPE RSPOstTWee SERvtCS, CHARLOTTE. NORTM CAROLINA
Crier - Direct 42 I
l' 1
A That is Joe Willist J. W. Willis, I believe.
2 Q And the Quality Assurance Manager now?
3 A That is L. R. Davison.
4 Q He held the position of QA Manager of Projects 8
before?
6 A Thats correct. .
O And the Senior QA Engineer? ,
8 A That is Bob Morgan, R. A. Morgan.
8 O How about the Surveillance area?
- A That is Rob Atkins.
II Q All right, c:: plain how Mr. Willis and Mr. Morgan's 12 responsibilitics cre broken up between the two of them.
I3 A Well, Mr. Willis has responsibility for Supervision I4 of cil the Quality Control Inspectors. Mr. Morgan supervises 15 the Qua 'ty Accurence Enginecrs and the Technicians who are 16 recpensibit for the intcrpretation of Quality Assurance I
Procedurce, the revicw of Construction Procedures. generated by 18
. construction. -
, Ec Elso cuperviscs the Records, QA Records Supervisor ,
- oo thic crce ic recpencible for revicuing all of the Quhlity 91 Assurance de umentation produced by the Inspectors as well as by construction cnd for filing and maintaining that documentation.
93
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Q All right, what was Mr. Morgan's responsibility 24 formerly?
25 A He had the responsibility I have inst described clus
.mm .. .. . noci.n .n on= === . c.. c um.. - - --
Grior - Dir3ct 43 the responsibility for supervision of the Quality control 2
Inspectors.
3 Q Why was that change made?
4 A Because of the availability of Mr. Willis freen 5
McGuire,and the feeling that our organization would be more efficient broken down in the manner that I've described. .
. 7 -
O liow held me understand, Mr. Grier, what the response ,
1
- 8 would be from the Project Manager, Project Management if i
1 9 l Quality control Inspectors in an area were not meeting productio n i 10 targets? Int's talk about an area such as Hangers. ,
11 What would you understand the procedures and policy 12 to be if appropriate Management observed that Hanger Incpectors 13 were not keeping up with production expectations?
14 A With our present setup I would expect that that 15 information would como to us through the Management and 16 Scheduling Supervisor position, through Mr. niller. He would 17 he told or would obacrve through his contcets with the 18
- Construction Planning Organization that, in fact, we were not -
19 ~
. keeping up in that !.nLpection area. .
lie would discess that with his stcff at Catawba, 21 with Mr. Davison, with Mr. Willis and other Supervision as 22 needed. And they would determine the correct course of action 23 to resolve tnat situation.
24 It might bc a case where there was a short-term 25 ap4ke in m nA n r + i nn ub i r.h M y hn e-m1rg n , g, m pr by w=a sveorm osnoen assocsares. siswovves menontwee mesmes. cuantorts. monru e --
Grior - Dir ct 44 l
l i
1 scheduled overtime, sore weekend work. If, in fact, it looked 2
like a long-term situation, then we would, the Catawba QA staff, 3
would indicate to the Management of Administrative Services 4
that more resources were needed.
6 Those resources might be obtained by hiring from -
6 outside or transferring from some other organization within .
~ .
7 Quality Assurance, or transferring from some other department ,
8 in the Company.
9 0 What other possible causes might you anticipate?
10 7 7,m not sure I understand what you mean "causes"?
II O You have identified if you saw it as It't keeping up 12 with the prodvetion level and the Craft in satisfying Hangers, 13 L tcrporary cpine in production, you add more Inspectors, more 14 overtime on a short-term basis?
IS A Right.
16 Q !.cnr tern, you add mere Inspecters, new hirec, new II transferr?
I8
- 7. Correct. -
19
, 0 Uhat !f it in rimply not a question of there being
- more work but the Inspectors not verking at an appropriate level 91
~
cf production?
oo
~~
A Uell, that would be something that the First Line 93 Supervisor would be rerponsible for observing to nthe sure that,
~
94
~
in fact, the Inspectors were on the job, were carrying out their
" activities in a timely manner.
j gygLvN gENGER ASSOCIATES. STSNOTTPS RSPostTwee SERVICE. CHAflLOTTE.' NORTH CA8tOL38eA l
i
Grier - Dir0ct 4S I
1 If hypothetically he observed an Inspector or more 2 er assumed not to be- at their work place as required or keeping 3 up with their production, that Supervisor would have some 4
counseling with that employee to determine the cause and to 5 resolve the matter and make sure the Inspector understood his 6 responsibility for adequate production.
~
7 O Does that exhaust this hypothetical instance? Let's 8
take the instance of Hangers, in Hangers you have some objective 9
measures of production, right, for inspection? There are 10 targets?
11 A that's correct.
12 0 7.nd there are also some cbjective measures of 13 Construction productivity standard units of measure, Hangers 14 installed?
la 7. (Witncsc nodded his head affirmatively.)
16
? The unit of production in the Hanger area are 37 constantly, I asrure we are not recing a cpike in levele of I8
. Eangers installed; they are following the form. .
19
- 7. "cll, th:t might not alwcyc be the catc. ,
- 20 0 Certcinly, but let's arrumc, let's try to held that ol contttnt.
22
?. All ri ht.
23 O There in no changc in prcductivity level'in the 24 Craft and/or Ranger installation area, but there is a drop in 1
1 oO l
the productivity level of the Hanger Inspection function. Now, l .mn. .. .. ...ocim. m m. -- .mc.. c -m. - e.aou
Grior - DirCct 46 3
kind of programatically., what I am trying to get a handle on, 2
Mr. Grier, is how ycur organisation responds in that hypotheti-3 cal instance if you have an individual and he is not where he in 4
supposed to be on time, or he is observed doing something other-s 5
wise that accounts for his production being low.
8 I can understand your answer, but programatically , .
7 now in the Hanger example we see Hanger Inspection falling down g, 8
and what programaticaiiy do you do? What is the response?
9 A Well, I am sure there would be some analysis by the 10 appropriate Supervisors in Quality Assurance to sees whether 11 there is some particular problem with the sequence whereby we 12 are carrying oyt our inspection when there is some particular 13 requirement of our Inspection Procedure that is giving the 14 Inspectors trouble in determining acceptability.
15 There might be a case where they are, the Inspector to poesibly, is taking longer to do a certain type of Inspection
'I then was anticipated; and some analysis would be made to see
- 18 if there is a more efficient we.y to do that. -
19 *
. Of course, if not, of course the alternative would 2"
be to increase the resources.
23 Q Now, later circumstances reduced the production by 22 the Quality Control Inspectors. Th.it has occurred.at Catawba, 23 has it not?
24 A IJm not aware of any substantial, or any situation 25 that comes to mind, where we've seen a decrease in production by .
EVELTN SERGER ASSOCIATES. STENOTYPE feEPOfrfleeG SEEFACE. CMAflLOTTE. NOarTM CAleOLie64
l l
Grier - Direct 47 I
Quality Control. I certainly cannot think of any specific i
examples, no; but there are circumstances where our backlog has {
3 increased in certain areas and we have taken steps to increase our effort to reduce the backlog of work.
5 Q Give me an example of that; where has that occurred .
, where you have had a backlog? -
A Well, the Hanger area I think is an example of that. .
8 Where in the past we have had some number of Hangers to inspect 9
and that has been built up by the Craft and we have taken steps 10 to reduce that backlog.
11 Q What did you do in that case?
12 A We worked some overtime and we added Inspectors to 13 the organization; and I believe we did some changing in the 14 sequencing, or rather the manner in which the Inspectors 15 carried out their assignment, the interfacing that they had with 16 the Craft and with the Technicians and Engineers who were on 17 Site.
, We increased the availability that those Inspectors '
~
19 . -
have with those individuals. '
. 20 Q When did this example occur in the Hanger area?
21 A Well, the most recent example I think may have been l 22 l three or four months ago.
23 0 Describe generally, using this Hanger example now, 24 how you changed the manner of performing their Inspection 25 f11Ft#*h I fnM _
EvgLYN SENGEM ASSOCIATE S. STSNOTYPE REPOMTING SSRW9CE. CHARLOTTE. NOfrTM CAmOLsN4
Grior Grier Dircct - Direct 48 I
I A Well, what we did, was form some Inspection Teams.
2 The previous Inspectors had essentially been assigned to 3
inspect Hangers in a particular area, and as Hangers were 4
available in that area, they were given Process Control infor-5 mation and they would go out and inspect those Hangers.
6 What we did was form an Inspection Team that works .
7 closely with the Craft and Technical and Design Team that is ,
8 doing the Hanger erection so that instead of the Inspectors 9
inspecting Hangers that might have been erected some months ago e
- they are inspecting Hangers erected more recently.
II The Crafts are more available in the area to assist I2 the Inspectors in putting scaffolding in place for the Inspectors I3 to get to the Hangers for inspection and performing those kinds I4 of tasks to facilitate the function.
O Are there Hanger Craft assigned to the Inspection Team?
A No, it is the other way around. There is a craft Technical Design Engineering Team that is involved in the proceus-
. of erecting Hangers; and what we did was assign some Inspectors
- I l
. oo
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to work with those teams.
91 Q And were there appropriate changes made in Inspection i procedures, Quality Assurance Department procedures, to affect l
l -
03
~
that change?
04 A The inspection instructions remained the same.
- 5
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There is no chance in the criteria for_the acceptability of a EVELYN SERGER ASSOctATES STENOTTPS REPORTING SSRVtCE. CHAMLOTTE. NC;4TM CAROLIN4
Gr:te - ;;ro:: 49
..-.= - --
l 1
Hanger ere ct:sr., so there tre no charges in the instructicns to the Inspecscre hs to hev to perform the inspection.
3 I telieve that in the basic Quality Assurance pro-4 cedure that covers Hanger Ir.spection there was some Administra-5 tive information put in that procedure to describe this working .
, relationship. -
7 0 All right, can you identify by letter or number that .
~
8 procedure for Hangers?
9 A That procedure is M51, I believe.
10 Q All right, would you like to take a break, ten 11 minutes?
12 MR. GIBSON: Yes.
13 (Whereupon, the deposition recessed at 10:10 14 a.m. and resumed at 10:40 a.m. following an Off-the-15 Record conversation regarding the avsf lability of 16 Mr. Davison as a witness.)
17
. 18 MR. GUILD:
. If there is anything you can do as 19 .
far as arranging Mr. Davison's vacation schedule --
20 MR. GIBSON: If matters change from what we 21 have indicated in that letter --
22 MR. GUILD: My request is to have him availabit i
~
23 through the 15th.
24 MR. GIBSON: We are saying he will not be 25 mum 41mhim nav& wamk-svetvm sanoen associares. sismorves nepoemne seavica. countoria. nonym camouma
GriCr - DirCct 50 1
I MR. GUILD: Are we ready to resume?
MR. GIBSO:a: Not yet, hang on.
3 (Whereupon, the deposition was adjourned from 4
10:44 a.m. to 10:55 a.m. and reconvened as followss) 5 6
, BY MR. GUILD:
- O We were talking, Mr. Grier,'about Hangers as an -
8 example of an inspection area where there has been a backlog 9
previously, and you were talking about the corrective action, 10 the adjustments made to respond to that backlog and you have 11 changes in the Administrative handling of the Inspection process 12 and gave reference to the M51 Procedure which deals with Hanger 13 Inspection procedures; is that correct?
14 A That's correct.
15 0 Describe as specifically as you can without the 16 document in front of you what the nature of the procedural 17 changes were that you refer to. ,
. A I would have to just give you a general description, I
19 -
l but cos.e of the Administrative changes dealt with how Decign I
- 20 l'
Engineers that are stationed in a field can review inspection 21 discrepancies and determine the disposition of those dis ~crepan-22
' cies, l
23 That is one area that is dealt with in the procedure ,
24 I believe.
25 Q Am T vaem11 the nthe r Infnematinn that would have avetvw sanoan associ4Tas. stenovves napoortwo senvca. cuantovTs. wasme CAnOWfeA
l crior - Direct 51 )
I been changed in the procedure describes the fact that there are 2 i tear.s of craftm en, Technicians, Engineers, who are engaged in i
3 I this erection process.
4 A I don't believe there is much detail in the procedure 5
in regard to that; but I believe there is some mention in regard ,
6 to the procedure. .
~
7 0 would the team include a representative from Design _
8 Engineering?
9 A Yes, it would.
IU '
O Who would have been the authority to review and II identify the discrepancies?
12 A That'c correct?
13 0 Who would that person's pocition and title be; do I4 you know?
IS A I don't know whether they have actually been given I"
come functional title. They would be a Design Engineer, some II pay clacsification; and they would be charged with exercising
. 18
, the Engineering judgment as Engineering judgment was affected
- 19 '
by the nesciution of an identified discrepancy.
' U Ac I reccll their authority is to determine whether al
~
an identified deficiency or discrepancy fa.11s within the 22 design's specification allowances or not.
23 0 What if a discrepancy falls outside of the construction 94
~
l specifications? Tould they have the authority to approve it's 1 25 acceptability as is on the basis of Engineering iudgment?
...u .. .. a. c .r... .r. w aria. ..avic . caaamn . ao= c*aouaa
Grior - Diroct $2 1
J. I'm not absolutely clear en that right now in my 2
mind. I think that in that case the problem identified has to 3
be reviewed, not on site by Engineering but rather in the 4
working office of the Design Engineering Group.
5 0 can you give me a realistic example of what that 6
distinction would be, something within the authority of that -
7 Design nature, something beyond the nature of a discrepancy in .
8 the design of the Hanger? I 9
A I really have not reviewed some examples in some 10 period of time, co I'm not sure whether I can come up with c 11 good example. I'll try.
12 There may be a situation where some angles specified 33 on some menber of the Hanger and our inspection instructions 14 tell the Inspector to perform the inspection in a certain manner .
35 The Design specification might give some more tolerances that t r>
Were not given in the inepection inctructions, and in that case II the Decign Engineer may be able to e:: plain by references to the
- 18
, specifications that that cituation was acceptable.
39 If it van not acceptable to the Design specificatienc
~
^
2" likely the action would be to rework it and to bring it into 21 specificatiens; but there is a possibility that it could be 22 reviewed by the Design Engineering Group and through qualifica-23 tions, determined that in fact it meets the Design requirement.
24 0 Typically would that Design Engineer on the team 25 with the Inspector have the authority to make such a calculation EVELTN SERGER ASSOCIATES. STENOTYPE REPORTING SenytCE. CMARLOTTE. NORTM CAnouMA
Grier - Direct 53 I
iin Engineering judemont?
2 A I don't believe that the Engineers on the team have 3
that responsibility. I think any calculations used in the 4
course of any justification would be done by the Design Engineer-5 ing Group in the office.
6 Q Many of these in the Hanger example, Hangers are .
~ "
7 for purposes of seismic bracing? ,
8 A Well, among other things.
9 '
O Am I correct in assuming that a number of the 30 Hangers that are specified are expressly for seismic 11 bracing?
I2 A There are likely seme parts that only serve a I3 scicmic loading function; but moet supports also serve a gravity support function and a thermo-loading function.
IS There are generally a combination; there may be some to that are specifically and only for seismic functions.
'I O Let's say hypothetically that a Hanger that serves
. 18 exclunively a seismic function is placed backwards so that it -
/
19 ~
, faces the wrong we.y. That happens as a matter of course some-
~
2" times?
21 A Well, I don't recall an instance; but I would expect 22 it could happen.
23 0 Someone reads the plans wrong and just puts it in 2'
. backwards. With that hypothetical would the Design Engineer 25 team member have the authority to accept the backwards seismic EVELYN 8 ERGER ASSOCIATES. STENOTYPE REPORTwee SelmOCS. CNAnLOTTE. NORTH CAROUNA
< - 1
- i l e l Grier - Direct , 54 1
1 1
Hanger as is?
1 2
A No, I wouldn ' t expect ao. l 3
O That would be sonething that would be a Design 4
Engineering responsibility for prior calculation or something?
5 A Yes, I'm sure the Resolution would ba to rework the 6
support and put it in its correct orientation. -
7 Q How would the discrepancy under the new procedure ,
8 in the Hanger example be documented, Mr. Grier?
9 A There is a form in procedure M51 that is used to 30 document there discrepancies. I believe that the form number 11 is an M51C For.J 12 O Is that in the nature of a Process Control document?
13 A It is part of the Process Control used for Erection 14 Inspection of the Hangers. '
,/7 II' O Is that the document'where the Inspector would 16 document his acceptance of the Hanger as a matter of course?
II A Yes, I believe so. .
- 18 0 Is that comparable to the Process Control in the
- 39 '
( , Welding crc:Ja -
~
~
2" A Not exectly, the M51C if I have that designation J~
21 right, I think I' do, is solely for the Inspector to' document r s discrepancies and then for the- focuments, for some action to 23 be indicated in= re^ gard to the resolution of that discrepancy.
24 The other elements of Process ' Control that go along 25 ~
with Hanger erection to explain'how to erect a-Haneer rather I
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SSRvtCE. CHARLOTTE. NORTM CAROUNA 4
t- , -
Cric: - ! ue : 55 lt '
I h in contrntiM *.hnt with a Welding case, an M4A form hae l
2 inetructirne fer the Craftsmen to perform the activity as well 3
as for the Inspector to perform the inspection activity.
4 0 What I'm trying to distinguish is what is the form 5
for the Inspector in the Hanger example for inspecting the work?
6 A I believe the procedure requires that a stamp be .
' ~
7 placef on the Hanger sketch which is the eight and a-half by ,
8 eleven sheet that gives the dimensions and materials that 8
indicata how the Hanger is to be erected.
ID I believe there is a stamp placed on that form which II contains a bloch for the Inspector to sign off for inspection.
I2 O Do I understand correctly then if the Hanger is la acceptable at the initial Inspection there would be no M51C I4 cr comparable form generated?
I' A I believe that's correct.
I#'
O And that form is generated only if a discrepancy is I
found?
- I8 A I believe that is correct. -
I9 *
. O All right, cir; when is an R2 Procedure, R2 and Form
.>o
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E2A used in the Hanger, for example?
91
~
A R2 is not commonly used in the Hanger area. I 22 believe, I don't think that it is impossible that we would use 23 an R2A form, but the M51C is the same type of document so it 94
~
substitutes for the R2A in the Hanger erection area.
25 0 How about procedure 01, OlA and Non-Conforming Item EVELYN BERGER ASSOCIATES. STENOTYPE REPOftTING SERVICJ. CHARLOTTE. NOfrTH CAROLINA
/
t
Grior - Direct 56 1
- Report in the Hanger an e ?
2 A It would be used in the same, since it would be used 3
in any inspection situation if some deficiency or discrepancy 4
is discovered on a support or Hanger outside our planned 5
inspection activity, and after inspection has been performed on 6
that support then a 01A or Non-Conforming Item Report would be .
7 generated since that would be comparable to an Inspection ,
8 activity failing to pick up a discrepancy or by-passing some 9
hold point.
IU Alco if there is some reason to process the dis-II crepancy within the general office of Design Engineering I2 essentially determining whether or not some justification of 33 discrepancy can be accepted or can be generated, then a Non-I4 Conforming Item would be used in that instance.
15 0 Am I correct in concluding if the Design, in the 16 Engineering judgment, is beyond the authority of the Design 37 Engineer who is assigned to the work group, that the exercice
- I8 of the Engineering judgment would come in the Resolution of -
I9
. a Non-Conf 0rming Item? ~
. on
~
A I believe that is how it would come primarily.
91 And the NCI or the 010 would be the form for 0
exercising and documenting that Engineering judgment?
93 A That's correct.
24 0 Mr. Grier, you have probably memorized this; you 25 are familiar with Appendix B to 10CFR, Part 50?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERYlCE. CHARLOTTE. NORTM CAROUNA
Crier - Direct 57 Id 7. Yes, I am.
l!
2h O Have you memorized it?
3 A No, I haven't.
4 0 close to it, I'll give you a test: I want to show 8
you a copy of the text of Quality Assurance Criterion Sixteen, 6
Corrective Action (indicating). Are you familiar generally ,
7 with that requirement?
8 A Yes, I am.
9 Q All right, sir; taking the example of Hangers that we 19 have just gone through, how is the root cause of the discrepancy 11 identified and effective corrective action taken to prevent the 12 recurrence of that deficiency in the Hanger example?
13 A That is taken care of in the Q1 Process in the NCI 34 Process. In addition there is a trending of deficiencies or 15 discrepancies that are. identified on the M51C forms.
16 Q All right, sir; how long have you been trending the II M51C discrepancies?
- I8 A That activity is just getting under way, I think. .
39
. That has not been done for a very long hy period of time. ,
~
- Phy did you begin trending the M51Cs?
O 23 A I believe that was as a result of a finding in the 22 October, 19825 elf Initiated Evaluation.
23 Q Mr. Grier, that same evaluation October '82 Evaluation, 1
24 recommended that you trend R2 as well?
25 A As I recall the recommendation was to trend other EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE CMARLOTTE. NORTH CAROUNA
Grior - Dirset E8 I
areau similar to the way we had begun R2As.
i 2
O So your recommendation is that you had already been 3
trending R2As?
4 A That's correct.
6 0 I just remember somebody else testifying that they .
6 believed the R2A trending began as a result of the recommenda- -
tion of that evaluation.. Do you know when you began trending .
R2As?
9 A No, I don't.
IU Q Would it have been much before the October '82 II Evaluation?
I2 A
I don't think it would have been much before that.
la I don't believo we have been trending them for a vc..y lengthy I4 period of time.
O So the M51C trending of identified deficienciec is in the Hanger area. What other areas had comparable Inspection Procedurec for identifying discrepancies for which the trending ,
- I8
. was recc=nended as a result of the '82 Self-Evaluation? '
19
- l A '" hat is hind of convoluted, if you can follow that. ,
. \
m~
I don't believe the recommendation was that similar types of !
ol
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documentation similar to R2As should be trended; atd the M51C is the only other type of documentation similar to R2A in the ol
~'
area inspection.
24 Arca R2As would be used in the sarte sense that an 05
~
M51c would be us:aa f n a stanyn e =*==-
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. feORTM CAnouu
Cricr - Direct 59 i
I O At you state in other areas, then they wcu'.d be 2
l documented on the R2A and would have been trended before?
3 A That's correct.
4 Q And if they weren't documented on the R2A they would 5
have been documented on the 01A and they were trended before? ,
8 A That's correct; now in some areas there are, the -
Inspector has available to him places where they can write down .
8 discrepancies on specific forms. For example, in Radiography 9
on the Radiography review sheet the Inspector can write down what rejectchie identifications might be evident in the film; 11 no there arc other places available for documenting deficiencien .
I2 0 In thc 17ciding erec on the Welding process Control 13 Shect?
14 A Yes, there are places available to reject or 15 describe deficiencica en the M4A form, for c:: ample.
16 Q I.nd on th0cc spccific forms where Inspectors, in the 17 cource of inspections, would note discrepancies, are those
. discrepancicc trcaded? -
A Uc, they cre not.
.>o
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Q Is there any other documentation that you are aware '
1 91
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1 of made of those identified dincrepancicc?
A No, not that I'm aware of.
m' O And then with respect to those discrepancies, Mr.
i 24 Grier, in light of the requirements of Quality Assurance 25 criterion Sixteen reanrMnc corrective netion. how are the i
swatyn sanoen associatus, sismotves nerontino sanvoca.CHAnLOTTs NORTM CAnOUNA l
I l
l
Crior - Direct C0 l1 1
Irect causes of those deficiencies identified and appropriate 2
corrective action taken?
3 A It is my understano.ing of Criterion Sixteen, that 4
the identification and cause end condition of corrective action 5
is to be done for significant conditions, not all conditions.
6 Basically our NCI, Q1 Procedure is used to document .
7 those significant conditions which then are required to be ,
8 evaluated under criterion Sixteen for deficiencies that we .
9 expect to find in the course of Planned Inspections.
M The criteria requires that we establich methods to 11 identify and correct.
12 0 Let's just cenetruct a hypothetical, and if I'm not 13 doing this right or if this is acmething obviously erroneous, 14 tell me.
15 But let's say in the Hanger area there is a recurring M
problem with Craft reading of blue printe. Let's say they read II the blue prints concistently wrong; cither they don't read the
= 18 angle specifications correctly er there is some other recurring M
. deficiency in the way the Craf t interpretc the blue prints, and *
~
2" that deficiency ic identified by the Inspceter in the course, 21 normal' course, preplanned inspection of the Hangers.
22 It is noted on the Hanger Process form and appropriate, U
correction is made, but it recurs. How is the cause of that 24 recurring deficiency identified and effective corrective action
" taken, Mr. Grier?
EVELYN SERGER ASSOCIATES, STENOTYPE REPORTNeG SERVICE. CMAtOTTE. NORTM CAROUNA
Gric e - Di re.ct 61
=_..
o b
IJ ~
An the trending of M51C is put into place, then a 2
trend like that uccid be observed and appropriate action would 8
be taken based on that trend.
4 Q All right, in the Welding area, Mr. Crier, welds are 6
refermed with deficiencies that are noted in the course of a .
6 i preplanned inspection; deficiencies which have the common cause -
7 l
of a lack of some specific training in the welding area, let's .
I 8 say.
l They are noted in the course of the Inspection and
'U they are corrceted by the Crnft when the Inspecter notes tho II deficiency, but they are not documented on an R2A or Non-12 Conforming Item Report.
I3 How in that circumstance would the root cause of that, 14 recurring deficiency be identified and effective corrective 15 action taken?
16 A That would occur not in the course of any cpecific I
requirement in our Inspection Procedurc, but rather by the
- I8
, observation that production in that particular area had dropped -
19 offbecauseofthenurberofrejectstbathadoccurred;and
- oo
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there would likely be seme investigation of the cause for that
'l
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lack of production.
O All right, sir; new at the time you became Corporate as
~
Quality Assurance Manager, Mr. Grier, there was an outstanding 94
~
significant problem in Welding area at Catawba; was there not?
25 A I don't recall anv.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTtNG SERVICE. CHARLOTTE. NORTM CANOUMA
1 Grior - DirIct 62 i
i I '
C You were aware at the point where you became Corporat.e 2 Quality Assurance Mana-er that there had been numercus technical 3
and non-technical concerne expressed by Welding Inspectors at 4
the Catawba Station?
5 Yes, I was aware of those.
A .
6 O And those concerns related to their work, related ~,
7 to Welding Inspection, Welding work with Welding Craft, the ,
8 organization of the Quality Assurance Program at the Catawba 9
Station?
10 A There were c nunbcr of concerns expressed and quite II a variety of reascns for those concerns.
12 O Yes, thone coneerns, we can agree you sat through 13 a nunber of depositions on this subject -- We can agree at the 14 start those concerns did not relate to,you know, the food in 15 the cafeteria or when you get to tahc your vacation.
16 I menn they related to work; can we agree on that?
II A They related to the ucy that Outlity Control,
. 18 Welding Inspectors, were carrying out their activities; yes. .
I9 '
. O What was the effect of the status of Welding
~
2" Inspectors, Uniding Inspector concerns, the way they carried 21 on their work on production levcis in Welding?
22 A I don't recall any affect.
23 Q Did you have information available to you at the 24 titue you took the job as Corporate OA funager that would lead i
25 l you to reach a conclusion on that quert y one way or the other?
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NOstTM CAROUNA
i l
l Grier - Direct 63 j
~$
li :
!i A Well, there was a monitoring of the number of NCIs i i
21beinggeneratedinthatareh, and I was aware that that was I
J going on and got some amount of information from that monitoring 4
- process to see whether the NCIs generated were more or less 5
than they had been in the past.
6 As far as the general area of Production, I didn't .
have any specific information other than the knowledge that if ~
8 our Welding Inspection activity were affecting Production, that 9
Management Group at Catawba would point that out to both 30 Construction Management and Quality Assurance Management; and Il there was no indication from them that there was any affect on 12 Production.
13 0 What was the affect of the number of NCIs in the I4 Welding area?
IS A As I recall, we saw no significant affect or no --
16 I believe the monitoring was put into place to see whether 37 there ould be some substantial increase in the generation of
' I8 NCIs; and there was no substantial increase. .
39 '
So as I reen11 that was the information we got
~
2" from that monitoring. .
21 O No substantial increase in the number of NCIs from 22 that?
23 A From the previous concerns, prior to the written 24 concerns being submitted.
25 O So the number of NCIs was consistent over time in avnov= maana associares. ers=orvre aeroari=o esavies. cuantorre. woaru ciaou== )
1
i l
i Orior - Direct 64 i i !
1 i the Welding area prior to and after the Welding Inspector t
2 concerns.
3 A As I remember, that's correct. Subsequent to that 4 time we did revise our Q1 procedure and explain the philosophy 5 in regard to Qls and RD2s; and that has subsequently had an
~
6 affect on the number of NCIs generated, but not until some 7 specific action procedurally was taken, did we see any change 8 in that rate or generation.
9 O And that reduced the number of NCIs?
10 A That's correct.
11 Q You are satisfied from reviewing the monitoring 12 information, Mr. Grier, that the number of NCIs in the Welding 13 area did not increase after the filing of the recourses by the 14 Welding Inspectors?
15 A That is my recollection; I did not review that 16 information in any great detail. I did not feel that that was 17 a significant mer.sure of really anything, the number of NCIs
~
- 18 generated.
l 19 I really felt that the issue wac being sure we -
l i
20 explained to the Inspectors, not just the Welding Inspectors, 21 but other Inspectors, the proper use of NCIs and accomplishing 22 that fact, then we would be generating NCIs correctly.
23 So some short period of time on monitoring, that 24 didn't seem all that significant to me; so I really did not 25 review that in any detail.
EVELYN SERGER ASSOctATES, STENOTYPE REPORTING SERVCE. CHARLOTTE, NORTM CAROUNA
Grier - Direct 65 I
i !
I i Q All right, what was the form of this r.onitoring?
l 2
A I don't believe I ever saw any physical evidence of 3
the monitoring. I was getting a verbal report. I would presume 4
there was some draf t, some sort of written document.
5 0 And who were the reports from?
6 A I received my input from Larry Davison, who was the .
7 QA Manager of Projects at that time. I presume he got them ,
8 from Bob Morgan.
8 0 All right, and to the best of your recollection, I"
Mr. Grier, how many NCIs on the average were occurring in the II Welding area during the period before the O1A Procedure was 12 revised?
13 A I couldn't tell you that.
14 Q Who would know?
15 g g,17, 7 m not sure; perhaps Bob Morgan or Larry 30 Davison might know.
II O And how about after the OlA Procedure was revised
' I8 in the Welding Area? -
I ^
39 '
. A I don't have those figures in my head.
2" O Do you have an idea, an approximation?
21 A I really couldn't guess.
22 O Who, Mr. Morgan or Mr. Davison likely would know?
23 A They might know or might be able to guess.
04 1 O How about beyond the Welding area, Non-Conforming 25 Item Reports in other areas of Construction at Catawba on an EVELYN SERGER ASSOCLATES. STENOTYPE REPORTING SSRVICS, CHARLOTTE NORTH CANCUNA
~ - __
Crier - Dircct 66 i
I
' average, how many NCIs would you say?
o I
l A I really couldn't say what, the information that I 3
reviewed is a continuing trend graph of the number of NCIs that 4
have historically been generated at Catawbar and that trend 5
graph is showing a decrease over the last several months or last 6
six or nine months. -
I can't tell you the rate, but it is trending down .
8 or a decreasing in the number generated per period of time.
U Q And who produces the trend graph of NCIs?
I" A I believe that particular graph that I am thinking II of is produced in our Project' Control organization using data I
from the Construction Department.
I3 Q And who is responsible for the Project Control?
I4 A That group is headed by Mike Hart, J. M. Hart.
O Is that here at the Corporate Office?
A That'c correct.
17 O And who does Mr. Hart report to?
' I8 A He reports to Warren Owen. -
'9 "
0 Would you erpect Mr. oven to be familiar with those oo trend analyses?
oi A Mr. Owen receives a copy of the Project Review Meeting Minutes; and those drafts are contained in the Minutes, 93 so they are available to him.
24 Q A Project Review Meeting is planned specifically to 25 '
Catawba?
EVELYN BERGER ASSOCIATES. STSNOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
Grier - Direct 67 i
I A That's correct.
l i
2 O Iw that weekly, bi-weekly?
l 3 A No, that meeting is held about every two to three i 4 months.
5 0 Mr. Owen does not attend that meeting? I 6 A That's correct.
. 1 7 O The Project Manager and his staff?
8 A The Department heads and the Construction Department, 9 Design Engineering Department, Quality Assurance Department and to Nuclear Production Department att'end that meeting with members 11 of their staff.
12 O And so who would be the representative from Construc--
la tion?
14 A Mr. Bob Dick and the Vice President.
15 0 Anybody from Quality Assurance?
16 A I attend and generally Larry Davison, Mr. W. O. Henry ,
17 perhaps some members of Mr. Davison's staff.
18 0 okay, is this the primary reporting mechanism for ,
19 trending Non-Conforming Item Reports? -
20 A That is not the trending program for p
21 NCIs. The graph I am describing is just a convenient time 22 quantity history of NCIs at Catawba. The Quality Assurance 23 Department maintains the trending of NCIs in order to deduce any 24 categories of discrepancies that are showing up more than others ;.
25 O How are those trend analyses maintained?
EVELYN SERGER ASSOCIATES. STENOTTPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA
1 Grior - Dir00t 68 i
t.
I A
( They are produced by the Technical Services organiza-2 tion within Quality A.ssurance and distributed to appropriate 1
3 Supervisors and Managers in the Quality Assurance and Construction 4
Departments for action based on the trend information in those 5
reports.
6 0 What is the title of that document; what is it called , .
7 sir? .
8 A It is sent.out as a letter. I suspect the subject 9
is Non-Conforming Item Trend Report.
I" O And ic there a narrative analysis of the subject of II Non-Conforming Items?
12 A Yes, there is some description of what area a 13 particular organizational group needs to look into to respond, 14 make some corrective action response.
I^
O Who is the author of that?
16 A I am not sure exactly the individual in Technical II Services organization that produces it. We have trends on NCIs I8
,' from different' areas. We trend NCIs in the Design Engineering -
I9 "
crea, in Construction, in the Nuclear Production Department;
~
2" and I believe there are different individuals who are responsible 21 for those trends.
22 O How about in Construction?
23 A I don't know the name of the individual for sure.
a4 O Who would that person work for?
A That is within Mr. Henry's Technical Services EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SEPVICE. CNARLOTTE. NORTN CAROUNA
1 Grior - Dircct 69 I
l[crganization. It would be specifically within the area of a 1.
n :
~ hSupervisor,LarryCoggin,underMr. Henry.
i!
y 0 Maybe Mr. Coggins is the author?
,h A I don't believe so; I believe he assigns an individuti
' f, 5
fwithinhisgrouptodotheactualtrendanalysis. ,
t 0 '
Q Are those trend analyses in Construction now; are -
they provided to the Nuclear Regulatory Commission? .
8 A No.
9 Q Are you aware of the Nuclear Regulatory Commission 10 reviewing those documents?
11 A I am not specifically aware, but I feel sure that our Resident Inspector at Catawba has seen the trends, the 13 reports; and has reviewed some of them.
14 Q 11as he ever talked to you about them?
15 A We have had some conversations about the Non-Conforming 16 Item Procedure, and I'm sure we must have talked about trending 17 in the course of that. I believe our conversation would have ~
- 18
. been basically about the procedure rather than specific trends -
I ~
! or correctivo actions.
i -
go I don't believe any specific topic conversation or al
~
specific item of non-conformance. We have discussed particular
~
non-conformances in the past.
'3
~
Q How about trend analyses, let me start again: Withir, 24 the trend analysis for the Construction Department are there 25 analyses done of ennatituant arman where nnn-r=nn formi ne Itama
( ava6vu asnoen associaiss. srs=orvra aeronnne sanwice. cuantorra. wonm cAnouma l
\
-, -~ .- - . .
Grier - Direct 70 i ,
l 1
< ihave occurred either by Craft or by systems under Construction? )
I 2 A They are breken down by topical areas; and by that 3 I mean areas such as Procedure Violations, incorrect installaticln ,
4 I guess I would say they are broken down by discrepancy topics. i 5
0 And whose topical organization is that? Is there sous
~
6 Duke standard format for classifying NCIs that you are aware of1 ,
- ~
7 A You mean throughout the industry?
~
8 0 In whatever way you do it?
9 A I believe that we determine the breakdown of the 10 topics. There are always broken down by the area that they cre 11 generated from. I believe the breakdown level is to the point 12 of saying that it came fram the Craft, it came from the Construc -
13 tion Technical Support organization or it came from the Quality 14 Assurance organization; and then Quality Assurance, I believe
!^ it is broken down to whether it came from OC Inspection organi-16 zation or Quclity Accurance or Technical Support or Records 17 area.
- 18 0 And that last breakdown is by the identity of the .
19
, originator? -
- 20 ;. No, by the identity of the group that generated the 21 discrepancy, so to speak.
U 0 The group to whom responsibility for having caused 23 the discrepancy is assigned?
24 A That's correct.
" O And who makes that determination?
EVELYN SERGER ASSOCsATES. STENOTYPE REPOsmMG SefMCE. CHAftLOTTE. NORTH CAftOufeA l
Grier - Dircet 71 I
A As to what category to put that in?
Q Yes, as to who to attribute the cause of the 3
discrepancy? i I 4 l A The individual responsible for producing the Trend '
5 Report makes that determination on the information stated in the Non-Conforming Item Report. -
g .
Q Well, let's put it in some concrete terms: A ,
8 Welding Inspector under the earlier procedure where NCIs were 9
used to document identified discrepancies in the process of an 10 Inspection, they were used that way, were they not?
11 A They were used on some occasions that way; yes.
12 C An Inspector identified an Inspection and documents 13 it with a Non-Conforming Item Report, it is a discrepancy that 14 you would characterize or has been characterized as a minor 15 discrepancy. That characterization has been used of NCIs that 16 Welding Inspectors wrote under the former procedure, hasn't it?
17 A Well, I would rather characterize it as something .
- 18
. that was discovered in the course of a planned inspection that -
19 .
could have been under our newer philosophy handled on an R2A
- ~
20 for example.
21 O All right, let's say it is a discrepancy identified oo
~~
in the course of a preplanned inspection and it is readily 23 correctible I think is a term previously used by the Welder, 24 and it is corrected as the result of the Resolution of the 25 NCI.
avatvu ernamn associatus, stenorves aeroarrimo sanvica. cuantoTrs. Howrw cancerna
Crior - Dircct 72 i would it be identified which organization would be 2'
identified as the cause of the discrepancy in the way that NCI 3
was trended?
4 A I feel sure that the Crafts would be identified as 5
~
the cause for the discrepancy. ,
6
. O So the trend analysis identified the original
- 7
~
responsibility for the non-conformance and the topical area .
8 of the non-conformance; and you use the example Procedural 9
Violation, Incorrect Installation; are there other topical areast?
10 A Yes, there are. I can't quote them all.
11 O How many are there, do you know?
12 A Oh, about a dozen I would think.
13 0 What other information is analyzed in the' trending 14 analysis?
15 A Basically the number of NCIs generated in these la categories against the historical average, so to speak, of the 17 NCIs or rather the number of NCIs in the last report as compared ,
. 18 to the NCIs in each category in the current report. '
19 .
O Is there any basis, Mr. Grier, for trying to, shall l 20 l we say, formalize tne raw number of NCIs to reflect status of. !
Construction or level of Construction activity or level of T.
Production?
23 l A Not in the trend report, itself. That has to be done t 24 l
by the appropriate Manager who is analyzing this trend report I 25 2::: = h .=1;ig: :: la;a :: ;;;in ;i.
EVELYN SERGE R ASSOCIATES. STENOTYPE REPORTING SERVICE. CNARLOTTE. NORTH CAROUNA
Crier - tirect 73 fa 7- 1 li O So the normalization, if that is a fair term to use !
2 in this context, that would be done by the reader of the Trend '
3 Analysis?
4 A That's correct.
5 0 On the basis of information available to the reader 6
about matters external to rimply the number of NCIs or the ,
I subject of the NCIs or the organization responsibility?
8 3 yem not sure I follow that question.
9 0 Okay, I want to understand how you use the informa-
- tion, and I think you said earlier that the raw number of NCIs Il may not be a useful measure.
12 A I don't recall saying that.
I3 0 Maybe it was in another context. Do you believe tham 34 the raw number of NCIs is a useful measure of the level of I'
quality and Construction?
16 A I think it certainly can be used. Obviously each NOI documents some discrepancies that need not have been
- 38 generated in the first place; so those raw numbers can be useful .
. to a Manager to determine how to reduce those numbers. -
' ->n 0 All right, sir; what other information is needed?
- 1 Let's take the area of Construction, that is what I'm' interested no
-- l in; what other information is needed in order to effectively l j
oa utilize that trend analysis of NCIs? '
l 24
! A Well, in one sense nothing. Those trend reports l 1 l 25 1 contain information that indicates whether the number of NCIs EVELYN BERGE R ASSOCIATES. STSNOTYPE REPORT 1MO SERVICE. CMARLOTTE. NORTM CAROUMA l
Grier - Dirset 74 1
being generated in a cenain area, for example Construction, and related to a certcin discrepancy, is going up or down.
3 If the Hanager is interested in that trend being 4
done, he has the information available to him to know that fact.
5 0 Okay, what information is that?
A That would be the number of NCIs generated in a .
previous report versus the number generated for that category ,
8 in the current report.
9 0 What I'm trying to focus on is the external data to 10 the NCI trend analysis that the Manager has and needs in order 11 to formalize the raw number of NCIs to put them in some kind 12 of content for planning purposes.
13 The NCI numbers may track the level of Construction 14 activity in a particular area; is that possible?
In A That is possible.
16 O The number of NCIs may increase, not because the 17 quality of the work is eroded, but because the amount of work
= 18
, in a particular area is increasing; is that fair? -
19 .
A That could happen.
20 O What information would be needed in order to dis-21 tinguish that circumstance from a circumstance of deteriorating e
~~
workmanship as the cause?
23 A That would be generated by the department within 24 Construction that would show productivity rates, levels of 25 met 4v4&4mm 4n a nav&4en1me seem crum1mA sa4 th the Manana,e a man avstyn sanos= associares. svenorvre morosmwe senwice. cuantorva. nourw camouma
Orier - Direct 75 l
1 l I
! knowledge of the level of activity or the area of reverses l
2 applied in a particular area. j O Is that planning analysis done explicitly? Did 4
someone sit down and take a NCI Trend Analysis and put that 5
together with such information as production levels in a parti-cular area? .
7 A 1 don't believe that is in -- that is not done in ,
8 every case. I don't think it is done commonly.
O okay, is it done in response to an indication of an 10 increasing trend in the raw data?
II A It could be done; I'm not specifically aware of that 12 type of information ec:ning back as a reason for an upward trend ,
la and therefore being answered that no corrective action is needed.
I4 That could be the answer that might come back, I don't remember is one like that specifically.
16 0 Let's take a hypothetical situation of a Manager who 17 is removed enough from the other concerning this external level
" I
, of activity and is concerned about cost and scheduling and -
'9 '
getting the Plant done and built right but did not know wnst oO
~
systems are having increased activity or increased levels of.
91
~
production, and he sees on the trend analysis the number of oo
~~
NCIs going up.
93
~~
How does that Manager, what information is available
- 4
~
to that Manager to be able to. interpret that trend analysis?
25 A Well, I imagine that level would likely ce==nunicate EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE NORTH CAROuteA
Grier - Diroct 76 u
I with Management at a low enough level to get the facts of the 2
matter and get his or har question answered.
3 The Trend Reports, let me say it this way: The level 4
of Management that gets the Trend Reporte to determine or to 5
feed back to Quality Assurance corrective actions where indi-6 cated are at a low enough level where they have personal .
knowledge of the levels of production over the periods of time ,
8 that they would be talking about, and also have ready access 0
to the Planning Department, Planning Groups, documents that to are generated.
11 Q All right, what level of Managers would that be that 12 you are referring to?
13 A The actual development of corrective action would 34 take place at equivalent of a Construction Engineer level, 15 which is essentially three, two levels below the Project 36 Manager on site.
I O And they would formulate this corrective action on
'8
, the basis of the trend analysis that we are talking about? -
39 ~
A The trend analysis would indicate the need for
.>o investigation for corrective action, and they would carry out 21 that hvestigation. They would likely go and look at a specific NCI in that category, themselves, and determine some common-
.y' ality in that NCI and generate corrective action based on a 94
~
specific review.
25 O Would such a review be documented?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTHeO SERVDCE. CMARLOTTE. NORTM CAROUNA
Grict - Direct 7; i
- y. , i 1
A 2
O In what form?
3 A That would be in a letter back to Quality Assurance 4
Technical Services organization indicating what action, what 5
corrective action was proposed for ths trend.
6 O If a programatic;. corrective action were indicated .
7 and taken as a result of the identified trends, would that 8
corrective action be reflected in the original Non-Conforming 3
Item Report?
M A No, it wouldn't.
11 O Is there any other document that is systematically 12 used to reflect the identification of the trends and corrective 13 action in Non-Conforming Items?
14 A Well, we have put into place recently a revision to 15 procure 01 and the generation of a new procedure that I think to speaks to this area.
37 That procedure is called Significant Corrective 18 Action, I believe Procedure R6. As each NCI is generated and .
- W resolved in the sense of laying out the specific corrective -
~ .
2" action for that discrepancy on the NCI, that NCI is reviewed 2I for significance to determine whether there is some indicction 22 of a need to investigate generic corrective action or correctiv o 23 action that might speak to more than just that deficiency 24 documented on the NCI.
U That corrective action is placed on the R6A Form, EVELYN BERGER ASSOCIATES. STSNOTY*E REPORT 1NO SEIMCE. CHARLOTTE. NORTM CAROUNA
1 Crior - Dir0ct 78 l -
i I
!which is a form in that new procedure.
2 O When was that procedure implemented? 1 3
A Recently, in June, I believe.
4 Q Of 19837 5
l A That's correct.
l 8 Q And what was the source or reason for the adoption -
7 of that new procedure? ,
8 A That was a step that was generated from a discussion, 9
I guess the indication by the NCI at some past time that our 10 documentation of this significant or generic correction acticn II needed to be enhanced; and we have gone through a phased meries 12 of steps here to get to this particular process that we are I3 using now.
I4 0 What do you mean by that?
15 A When Duke decided to take or saw the need to take 16 some specific action to be responsive to the NCIs concerning Procedure 01, it was revised to add a step in each NCI to I8
, generate some statement in regards to significance or generic -
- 39 '
corrective action. .
.,o
~
We also formed a Review Team to independently review oi
~
NCIs to see that descriptions placed on all phases of the NCI, a2 the distinction of the discrepancies, the description of the
~
91 specific corrective action and generic corrective action was 24 thorough and left no questions unanswered or was not written 95 in a way that there might be some cuestion as to what was meant.
l EvtLYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA
Crier - Direct 79 1J That team functioned for some period cf time and
'i 2 L that was set up as an interim step to train pecple to better 3 describe and write NCIs. As that team was functioning we i
4 ' determined that it would be best to separate the significant 5 corrective action or generic corrective action review and 6 documentation from the NCI, itself, that they were best ,
- ~
7 handled separately.
8 That culminated in the generation of this new R6 9 Procedure and a revision of the 01 procedure.
10 0 Why did you determine it would be best to handle 11 them separately?
12 A Each NCI is not of the nature that some generic 13 corrective action might need to be taken. With the step on 14 the form, it is requiring that some statement be made about 15 significanco or generic corrective action in addition to the 16 significant corrective action.
17 We found it was difficult to communicate to everyone 18 as to the entire -- there were individuals who were searching ,
19 for a way to develop corrective generic actions that weren't -
20 needed because there was a block on the form that called for 21 that.
22 So we decided that the most efficient way to handle 23 this process in the way that is most responsive to the criteria here 24 would be to have each NCI reviewed to determine if significant 25 or generic corrective action is needed and separate that procesls, EVELYN BERGER ASSOCIATES. STtNOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
Grier - Dircct EG that let that NCI be closed cut in accordance to the specific action, an'd this gener:.c corrective action be carried out 3
separately.
Q All right, in what areas was the NCI being improperly 5
used to use generic corrective action?
0 A Excuse me, it wasn't a sense that it was becoming .
l improperly used. The sense was that where generic corrective ,
i action was not needed, there was some level of activity going 9
on, unnecessary activity, to attempt to generate some unneeded 10 generic corrective actions.
11 And in the activities of NCI review teams and independent managering by Management, we determined that the l 13 cause for this was the fact that we did not clearly separate 14 these two activities.
15 So these procedurcs were to clearly separate those 16 two activities.
17 Q I understand that. What I'm trying to get you to 18
- . tell me is what specific area was that occurring in? Where was -
19 -
the NCI being used, not improperly, but inefficiently?
20 A It was fairly widespread; there were problems 21 generally in every area with a good understanding of the intent v
~~
of that process and procedure.
23 O Did that occur in Welding?
24 A I would suspect that it occurred in Welding as well 25 mm the ramt nf the avamm_
EVELYN SERGER ASSOCIATtt, STENOTYPE REPORTING SERVICS, CMARLOTTE NORTH CAROUNA
Grier - I;irect 81 1
O Other Crafte?
2 A General;y we are talxing about the individual 3 responsibilities for generating the resolutions to NCIs. Those 4
would be people within the Construction, Technical Support 5 organization within Design Engineering and within the Quality
~
6 Assurance Technical Support organization. ,
7 ~
Q Give me a representative or typical example of a 8
situation where that was done with NCIs before.
9 A An example of where some inefficiency occurred in the to generic corrective action?
11 O Yes.
12 A Well, I'm not sure I can come up with a good exanple.
13 I'm not sure I can come up with a specific example; but an NCI 14 might be generated that would only require a resolution of the 15 cpecific discrepancy that was documented on the NCI, and would to not indicate the need for any generic corrective ection.
II It did not appocr to be receptive or of the nature of
- 18 anything other than some isolated instances, and when the ,
19 individual got to the etcp of considering generic corrective -
- 20 cetion, they might, in fact, ettempt some generic corrective 21 netion or make some statement that really wasn't supported by 22 the NCI, itself.
2a That lead to some inefficiency in closing out the 24 NCIs.
" O What kind of corrective actionswould typically be
Grior - L.reat t;2 d
I suggested :1r.: voro inapproprinte? ,
i 2
A Well, rer.lizeperhapstheremightbe,thediscrepabey 3
might be in regard to some e.rection discrepancy on a Hanger, 4
and the generie ccrrective action might be to train the Craft 5
in this activity. ,
8 O And someone would have'to say training of the Craft .
in this area is not needed on the basis of reviewing that NOI?
~
8 A That would be correct. Training is a pretty typical 9
generic resolution that you can put down inappropriately for 10 practically any non-conforming item. That leads to mind, that 11 any time you have a discrepancy that perhaps some training is 12 needed, which in fact, it might have been come isolated mistake 13 by a highly trained individual.
14 0 In the Army they used to say everything was either 30 a training problem or motivation problem. If you can find a 16 prcbic you cr.n Ettcch the generic resolutien of training
'I people or motivating them; hut people ucre trying to fill in I8
, the blank with something when the blank might not need to be .
1 19 '
filled in fer thet particular discrepency?
t . 0
~0 L ntt's correct.
og i
O Give mc a time when this was occurring firct, when no the NRC was indicating to,you that you needed, like you said, 23 to enhance the documentation of generic insignificant corrective 94 actions?
D A I'm not exactly sure when that_ occurred. That occurred'
..<,...............i.-.--
Grier - nirsct c3 I[priortoryassignmentasCorporateQualityAssuranceManager.
,, l isometine in 19E1, I'm not sure exactly when we assigned this 8
team to do this review of the wording, quality of the wording 4
in NCIs.
^
I think about the middle of 1982, and we began l
6
, working on this procedure change that generated Procedure R6
- 1 probably in the spring, May, June time frame of this year, ,
8
, 1983.
9 Subsequently, I'm sorry, I would expect that we began I
t working on that carlier than that, probably February / March 11 time frame; and cubsequently have put that procedure into I2 cffect abcut June cf thic year.
la Q okay, and has the Nuclear Regulatory Commission I4 been informed of the procedure changes that you have implemented so far?
A Yes, we have discussed this with our Recident 17 Incpector at Catawbt..
I
, Q Mr. Van Doorn?
- A That's correct.
"O
~
Q And has he, or any other NRC ctaff mcde this pro-
.i- g cedure change the subject of any review in the form of an Inspection RE. pert?
ol
~
A I'm not aware that that has been a specific subject 94 1
of an Inspection Report. Of course, the implementation of this R6 Procedure and 01 is fairiv recent.
I EVELTN BE RGE R ASSOCIATE S. STENOTYPE REPORTING SERVICE. CNARLOTTE. NORTH CAROUNA
Grior - Din c.t F4 1.
i I
Q Ecw about the original observation of the need to 2
enhance docume..tation of corrective actions? Was that an 8
Inspection Report?
4 A
I would expect it may have been, although I am not s
sure of that. As I say, that occurred before I came into the 6
Quality Assurance Department. 9 7
Q Okay --
8 MR. GIBSON: It is about fifteen, eighteen 8
after noon. Can we find an appropriate breaking to point?
II MR. GUILD: Let's take a lunch break , if we I2 could, I would like to have you make available a la copy of this R6 procedure, if you could try to pull I4 that.
I liR. GISSON: I believe that was made available 16 during an earlier deposition, perhaps Mr. Henry.
Do you want to do that after lunch or do you want to
~
is
, look for one now? .
I" MR. CUILD: If I havo it fine, I don't need
! . o
~o cnother ccpy of it. If I don't have it it m3ght help to pull it over lunch.
MR. GIBSON: We will determine if it was made a1
~
, available; if it wasn't, we will furnish it after 1
1 24 -
l lunch.
l 25 MR. GUILDr Thr nl: vou.
EVfLVN SENGER ASSOCIATES. STSNOTYPS mSPCHtTIMO SSNveCS. CHARLOTTE. h08tfM CAmouMA
Grict - Dirrce E 7,
-i .
I MR. GIBSON: Mr. Guild, talking with Mr. Henry 2
after we gave you the new revi.91on to 01, I think we 3
then got R2 and then R6.
4 MR. GUILD: P2 I remember clearly.
MR. BELL: It is Exhibit Six in Wayne Henry's 6
deposition.
~
- 7 MR. GUILD: R6 is Number Seven to my notes hers ;-
8 you are close, Graham.
9 I
(Whereupon, the deposition adjourned for a II luncheon recess and reconvened at 1:42 p.m.)
12 13 14 15 16 17 BY liR. GUILD:
Q Are we ready, Mr. Grier? Defore the luncheon recess
. you had referred to a newly adopted procedure identified an .
'N1
. ~
Procedure R6 for docurc.cnting cicnificant corrective action; and "I
~
we believe we clarified this procedure has been identified and l 29 l
~
made available during Mr. Henry's deposition and it has been 23 identified as Exhibit Seven to Mr. Henry's deposition.
j Now I understood you to be describing a procedure 25 that documented corrective actions that were taken reflecting EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTS. NORTM CAROUNA
Grior - Dirnet 16
' I non-conforming itemr. of a -- did you say which might recur and 2
for which ccrrective action of a generic or broader scope might 3
be necessary? Is my understanding right?
4 A Tnat's correct.
5 Q I didn't understand you to be limiting your descriptJ.on to 6
items which are significant within the meaning of 10CFR50.55E? ,
were you intending to limit your description of deficiencies to
- 8 50.55E, Significant Deficiencies?
8 A No.
30 0 So .55E, Significant Deficiencies which are report-
" able to the NRC, would simply be a ciasc of deficiencies for 10~
which significant corrective action may be required, accng 13 others?
A That's correct.
15 0 I'm looking now at the scope provision of Procedure 16 RC; it in Paragraph Number Two. Thic procedure applies to all I
QA Non-Conforming Items which rcprencnt significant conditions
. ,g
, adverse to quality. ,
- I"
- 1;ow thtt phrcso is not intended to be synonomous
'o>
with the definition of Significant Deficiencies as you used in
' >t '
the NRC's definition?
A It is not meant to be used as the same definition 23 as that in 50.55E. It is ceant to be the same as the 24 significance used in criterion sixteen.
os
~
l Q How do you understand the difference?
l
.mm = =. . ...ocian.. m wn ==- ==.e.. e .um.. - e. u l
Cricr - Dircet E7 1
A I would look up the provision so we could both look 2 at it. _
3 0 But give me your understanding of the difference.
4 A The definition in 50.55E plus the guidance from NRC 5
cn implementation of that give specific categories of things 6
that are deemed to be significant; and my feeling of the term ,
7 significant in Criterion Sixteen is somewhat broader than that 8
used in 50.55E.
9 0 I will never figure out how to read the Federal W Regulations. We have 50 and SSA; and let's see if we can flad it it. That should be a current volume of the code. I had a 12 Federal Judge tell me one time you have to hire somebody special 13 to figure out hou to cite to the Federal Regulation.
14 Maybe comebody else can find them.
M A Give ne a page at the bottom there so I can find it.
W Q Okay, it is on Page 429. All right, sir, thank you.
17 And there 50.55E , would you read that for the record, what the 38 definition is? .
W
. 7. i'm rccding from Paragraph 50.EEEl, "If the permit 2"
is for the conttructica of a Nuclear Powcr Plant, the holder of 21 the permit ohn11 notify the Commission of each deficiency 22 l found in decign and conctruction, which, were it to have remained l
23 uncorrected, could have effected adversely the safety of 24 l
operations of the Nuclear Power Plant at any time thoughout 25 I the expected- lifetime { of the Plant, and which represents EVELYN SE RGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE, NOstTM CAftOUNA
Grior - Circet as I
(1) a significant brechdown in any portion of the Quality 2
Assurance Program conducted in accordance with the requirements 3
of Appendix E to this part; or (ii) a significant deficiency in 4
g final design as approved and released.for construction such 5
that the design does not conform to the criteria and bases 6
stated in the Safety Analysis Report or the Construction Permite .
7 or (iii) a significant deficiency in construction of or 8
significant' damage to a structure, system, or component which 9
will require extensive evaluation,. extensive redesign, or 10 extensive repair to meet the criteria and bases stated in the II Safety Analysis Report or Construction Permit or to otherwise I2 catablish the adequacy of the structure, system, or component 13 to perform its intended safety function; cr (iv) a significant 34 deviation from performance specifications which will require 15 cxtensive evaluation, extensive redesign, or extensive repair I6 to cctablich the adequacy of a structure, system, or component to meet the criteria and bases stated in the Safety Analysis 18
, Report or Construction Permit or to otherwise establish the .
19 e.dcquncy of the structure, cyctem er cer.ponent to perform its '
no intended safety function.
01
~
And it goes on for four more paragraphs which deal 2
with requirencnts to notify within'a certain period of time 23 and to submit written reports within a certain period of time.
94 Q No, that is fine; it is the definitional provisions 25 I am interested in. Earlier you said that the cuidance, in EVELYM SEnOEM ASSOCtATES. STEMOType NEPORTING SERVICE. CMARLOTTE. NORTH LAROUNA .
G le r - L.. ;t 29 o
b 1 [ additic.. to the 30ccific tornr of CFR50.55E, supported your H
I 2 interpretation of t.' .n t term.
3 h' hat guidance did you have reference to?
4 A I an not cure I understood your question.
5 0 I think I asked the question first is the term .
6 significance synoncmous, as you understood it; and you said -
7 no, you thought that your definition in procedure R6 was .
8 broader.
9 A What I intended to say is that significance, as we m used it in reference to R6 is the same meaning as would be 11 applied to critorien Sixteen which centains the word "significar,t" 12 cc oppcsed to the fairly narrow use of the term " significance,"
13 in those four defining paragraphs in 50.55E.
14 O But you hcd reference to some Commission guidance.
15 A 17 ell, that reference vac to guidance that the M
Ccmmitrion har put out to give more inform:tien in regards to II cpplying cignifican0c in terma of 50.55E. I'm not aware of .
18
. specific guidance in terms of significance as it is used in
- 19 Criterien Si::tcen.
l .
N 2 Ar ycu freiliar with changer in the Commiscien's 21 Quality Assurance Regulations that were effective in March of 22 this year?
23 A I'm aware of some changes, I am not sure exactly 24 when they were effective and what I'm recalling. I don't knew M whether it is what you are referring to or not, is some require-EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SEnytCE. CMARLOTTE. NORTH CAROU80A
cr1er - CLrect *n
==-
I j n:ents that deal wiw. :.otifying the Commission when we change i i
, crgani::ation:; or Quulity Assurance Program.
3 G Yes, that it what I had in mind and wondered if you 4
could tell me what changes and procedures you have notified 5
, the Commission of in light of the testimony earlier today about -
6
. the changes, particularly in terms of construction deficiencies.
7 A We have described in Revision Six or amended Six
- 8 to our Topical Report, our Quality Assurance Program and 9
communicated with the URC to ascertain whether that would I0 satisfy the requirements of an update in the Quality Assurance II Program, and I bolicyc they said that would be sufficient.
19 New there is c requirement to periodically update I3 the URC with changes that are not of a significant nature, and I4 I am not sure exactly of the timing on that update.
I0 0 Ilcc that a=chdment to the Crrnmiccion's regulationc I6 rcsuited in cny cignificant change in your procedure or in your communication to the Imc in the past? -
18 *
. A lio, it hcc not.
l 19 i
~
O Ycu 1.c.d filed cignificant EmEndments to your Tcpice.1 .
no Report provicurlyir ol
~
A We hcd filed a significant change in the Topical 22 Report ct about the s me time that we would have been required
! 0
~'3 i
1 to make acme kind of filing otherwise.
! 24 l 0 What was the source of the guidance from the 25 Commiscion that reeresentc4 acc<m+ aM a en=, n 1 4 7- y*h ah-~~-
SVELYN SERGER ASSOCIATE S. STENOTYPE M8 PORTING SERvH",E. CNAnLOTTE. DeONTN CAnOLINA
Grier - D#rott .-- --..=
91 ,
i I q in 17EC Regulat'c: '
2 A I didn't:- :c the centret, myself, and I'm not exact %y 3
sure who was spohen to ti the Commission. I believe that was a 4
conversation between someone in our Licensing organization and 5
someone responcible fer the review of our Safety Analysis Report .,
6
. 0 And when was the amendment t:cmber Six to your Topicah
- 7 Report issued, as near as you can recall? .
8 ge m 3 not sure exactly of the date; I think it was in 9
the Spring of this year.
10 0 Did it include Procedure RG, a deceription of that?
II A I'n not sure that it did include that.
12 G All right, Mr. Grier; let's turn to the point where la you took on renpensibility as Corporate Quality Assurance Managor.
14 You had an interview with Mr. Owen; in that right?
lb A That's correct.
16 0 And whct did Mr. Owen have to any to you about the 17 pocition or the circumstance of you being offered the position? ,
38
. A As I reccli in the interview, which was my first *
~ .
19 necting with hin, he did not aske an offer; cnd reclly during .
2" the course of thct interview, did not indicate thct he uns 21 interviewing me for the position of Ccrpcrate OA Manager.
oo ithen I say " interview" it was a necting at which he 23 discussed with nc some tcpics cuch as my interest in Quality 24 Assurance, my feelings about how the organization ought to be 3
managed, those types of topics; and there was no real conclusior..
EVELVN SENGE R ASSOCIATE S. STEh0 TYPE REPORTNe4 SERVICE. CHARLOTTE. MORTM CAM
V:. s - '. n e c t 02 S
h i p
~ jl : meen the interview was just obviously icoking back on i t. , it var for him to gather some information to facilitate 3
"' his decision.
i 4
- Q Were you aware at the time there was going to be an i
5 opening in the position? -
6 "
. A No, I wasn't.
, O Did he make you aware of that during the course of -
8 the interview?
9 A Hot during that interview.
10 0 What did you understand was the subject or nature of 11 the interview at that time?
I2 A As 1 indiccted, he was c:gpressing interest in my 13 views about Quality Assurance and about Management, and I really 14 did not ask him the purpose of the interview.
15 0 Whct did you understand the purpose we.:.?
16
~
A Thcre was no s cted purpesc cs I was scheduled to 17 huvc the discuscien with hin.. I was just asked to meet with .
him for a discussion, and there really, I don't recall that he spccifically ctcted t rccccn for the discussien or interview.
20 0 1 underst;nd, but what did you understand the 21 purpose of the meeting to bc?
.w
~~
A It wasn't clear to n.c really at that time the purpose :
93
~
of the interview.
24 Q What did you think?
25 A Unll. T van Awa r,s n# 4- h a s- 4 +-n n + i nn in vn erm erle to avstru ennoan AssoCures sianoTves necoatino seRytCE. CHARLOrrE. NORM e * 'NA
' j Grier - Direct 93 I I l Welding Inspectors at Catawba having brought forth some concerns 2
and it seemed to me in the course of the interview he perhaps 3
was asking my opinion en things as a basis for him deciding 4
or participating in the decision of how to handle those concerno 5
since I had superviscd Administratively Inspectors for nine ,
6 -
. years at McGuire.
I felt like he was just drawing on my experience to ,
8 help him work out the ways to handle that situation.
9 C And this would have been in January of 19827 10 A That's correct, and as I recall it was en a Thursday 11 morning, the lact Thursdcy in January, I thinh.
O What previous inforretion did you have about the 13 Welding Inspector concerns?
14 A Only in my contact with Bob Dick and John Rogers 15 at ct ff mectingc. I w;3 at that time en Mr. Dick's stcff and 16 I cttended ctaff meetingc cnd there wcc scoe discussion, not 17 much, but semo nention of the fact that there had been semt 18
- written concerns turned in by Wclding Inspectort.
l J.lco : Une cwarc of the Rcrolutien of the Pay l
1 00
~
Recourses cc Hunager of Oconec Station Support Division, and 01
~
! I roccived a mcmorandum from Jim Grogan explaining that that
( Eccourse had been settled by the President, and giving me 93
~
l instructions on how to communicate that to my staff and other 24 Supervisors in the Station Support Division.
25 0 And did vou at that time when you were at Oconee avstva esassa associares. sremorves escoarine senwice. cuatores. moarn camouma
i C:ic - Direct 94 I
l l l 1
have persons reporting to you wno interfaced with Inspectors? l 2 A Yes.
I 3 i Q And they were on the operational staff of QA7 4 A Yes , that's correct; there were Maintenance.
i 5 !
. Inspectors in the Operations Division of QA. -
6 Q Now help me understand what your relationship was ,
7
. with Mr. Dick at the time you were on his staff? -
8 A- Well, I was the Manager responsible for the Construc -
O tion organization at Ocones, and I reported directly to Bob 10 Dick.
11 Q And were there Construction Quality Control Inspectors 12 at Oconee at that time?
13 A Nor all the Quality Assurance and Quality Control 14 functions worc carried out by the Operations Division.
15 l 0 There was significant construction going on at that 16 timc?
17 A Well, at that time we were finishing construction ,
. 18 on the stLndby shutdown facility at Oconee. A lot of our 10 activiuies werc involved in modification work within the ,
20 Station; and wc were just beginning construction on the Raid 21 Raised Facility.
9
~2 0 All right, did you understand that Mr. Owen was 23 having similar conversations or interviews with others on the 24 subject of Welding Inspector concerns and how to respond?
A Mo, I wne.n't.
EVELYN $. BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CHARLOTTE. N. C.
Crier - Lirect 55 i
1[ Q IIe didn't n.ake you aware that he was soliciting 2 views from others beside yourself?
I 3 A No, he didn't.
4 And what was the nature of Mr. Owen's questions to Q
5 you or inquiries? What did he want from you or what did he -
6 ask of you? ,'
7
. A As I recall he asked questions about whether we had -
8 had concerns expressed by Inspectors at McGuire. If so, how 9
those were handled. I think he asked some questions in regard 10 to whether I felt that the Quality Control organization was 11 based placed in Quality Assurance or whether it was best placed 12 in Construction.
13 There were socle other topics I'm not sure I can 14 remember.
15 0 Any that you can remember?
16 l A Well, there was the topic of the relationship betwee a 17
, Inspectors and Craftmen was discussed, I can't specifically .
- 18 remember questions in that areas but I feel like we discussed
~
19 that arec. ,
20 Q Did he ask your opinicn as to the reason why the 21 Inspectors were raising these concerns?
22 A lie may have; I can't specifically remember him asking 23 that, but it would seem logical. I can't remember though.
24 Q Do you remember expressing an opinion on the subjectog 25 why?
EvtLYN S. B(RGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE, N. C.
Grior - Dircet 96 1 l. A no, I don't.
2 Q Cid he raise the question in substance whether or 3 lnotthoseexpressionsofconcernshouldbeunderstoodasmerely 4 a reflection of the Pay dispute?
5 A I don't recall him asking or discussing that. .
6 Did.you believe that those concerns were a reflection Q , l 7 of the pay dispute? -
8 A At that time I didn't know specifically what the 9
concerns were. I was just aware that concerns had been 10 expressed; and as I say, the only thing I was aware of in 11 regard to the pay issue was thLt a Recourse had been settled 12 by the President; and I just at that time had not reflected on 13 any relationship there.
14 Q What had you seen or what had been brought to your 15 attention regarding the' matter of the concerns that the 16 Inspectors had exptesced at this time?
17 A I can't recall that any specific concerns were .
18 mentioned.
I think of what I remember was that a number of l
19 Inspectors hau expressed concerns about technical issues; and ,
20 1
I think that is about as far as I heard or knew at that time.
l 21 j Q Had you seen any of the complaints by the Welding 22 Inspectsrs, the written statements by Inspectors?
23 A No, I had not.
24 Q Had you seen any.of the materials, supervising 25 interviews regarding those concerns, for example, an interview EVELYN $. BERGER OFFICIAL COURT REPORTER
Gricr - Direct 97 I
t'
.)
that was made available to Mr. Cven by Ms. Addis in early o
~
' December?
3 A No, I hadn't. I want to be clear that we are talking
{
4 !
iabout up to the point of my interview of Mr. Owen, no, I had not seen them. ~
,' O Many of these things you have seen since? .
- A I have since, but at that time I didn't see any of 8
this material. The only documentation I recall seeing was the 9
- memorandum from Mr. Grogan to me at
- well as the other Managers 10 indicating that the pay issue had been settled by the President 11 and giving us instructions on how to communicate that .
12 O And that related to the reclassification of the 13 Welding Inspector issues?
14 A That's correct.
15 l j O When did it come to your attention technical concerns 16 !
- had been raiced by the Inspectors, concerning specific work-I
, manship and the organization of the Quality Assurance Program -
,at the Company? -
19
. A As I mentioned, the first time I became aware of .
20 that, I believe was in the course of staff meetings with Mr.
21 Dick when Mr. Rogers was present and there was some previous 22 mention.
23 There was no discussion, as I recall, just a mention 24 of the fact that those concerns had come forward. ;
l 25 n ,___.._.._..._m
' " ~ ~
it m m e __ mt_m u_ .__ t_2 24 __..a
~ "#"
EVELYN $. BERGER OFFeCIAL COURT REPORTER U. S. DISTRICT COURT CHARLOTTE, N. C.
.. _ ______________i
1 Crirr - Direct 98 1
, Hr. Owen to f erm a tas). force to review the technical concerns?
<> l
'; A No, I was not.
r 2
Q He did not inform you of that at the meeting?
4 I A I don't recall that he did.
5!
O Had you had experience with concerns by Welding ,
6
[
I Inspectors at McGuire?
o A In the sense that I understood the question from -
8 Mr. Owen, I told him yes, we had had Inspectors who on occasion 9
had questions about the acceptability of certain workmanshipt 10 and the explanation by Supervision that was acceptable, and 11 some disagreament on that point by the Inspector that we had 12 had those situations occur on occasion at McGuire over the 13 years.
14 O And how did you respond to the followup question 15 !
j about how thoce things were handled at McGuire?
i 16 !
l A Wnat I told him, I recall, is that those generally 17 '
. had been resolved. Well, they had been resolved at various .
levels of Supervision, but that on occasion the Resolution
. 1 ,
, occurred in meetings and discussions between the Inspector, ,
20 the Supervinor, myself and the Senior QA Engineer on site, 21 0 Did you discuss that method of resolution as a 22 means of resolving disputes at Catawba?
23 A I don't recall a discussion of using that. One 24 reason perhaps it wasn't discussed is because the organization 25 hmA hman'channaA mba Tnnppermen now were in the Ouality EVELYN $. BERGER OFFICIAL COURT REPORTTR U. S. DISTRICT COURT CN ARLOTTE, M. C.
Grior - Dircet 99 N l 1
i Assurance Department and were not in the Construction Departmen't 2 ' and technically directed out of the Quality Assurance Depart:nont, 3 l'aswasthecasewhenIwasatMcGuireandwewerespeakingof 4
how to handle those types of conflicts there.
5 Q What opinion did you express on the question of the .
. 6 '
relationship between Quality Control and Quality Assurance as ,
. to how the inspection function should be assigned? -
0 A Well, as I recall I told Mr. Owen that I felt it 9
worked, as the organization as we had it set at McGuire when I 10 was there, worked well and that I did not have any experience 11 in how it was working at Catawba with Quality Control in the 12 Quality Assurance Department; but I preferred the organization 13 that we had at McGuire.
14 O And that was with the --
A QC in the Construction Department.
16 O Did you explain why?
1
, A Yes, I believe I used the same reasons that were
- 18 '
used when Quality Assurance was placed or remained Administra-l
, tively 3.n Construction when the Quality Assurance Department ,
90
~
was formed in 1974, that being that there is a scheduling and 21 prcduction function that has to take placer and I feJ.t that the 9
~2 people in the Construction Department were more attuned and 23 used to that type of production planning; and I felt it could 24 be more efficiently carried out in Construction that in 5
Ouality ans:uranne.
EVELYN $ BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE, N C.
Grier - Direct 100 Ii 1
O Hr. Owen, of course, has been recponsible in part I 1
2
- l. for Management decisions to do just the opposite, to put them 3 f under Quality Assurance?
4 I A I would assume so.
5 e O Did he express a view on why the Management decisions-i -
- 6 lhad been made to do it the other way? ,
. A I don't recall him explaining a reason why the 8
change had been made.
9 O Did he respond at all to your expression of opinion 10 about your experience at McGuire?
A I'm really searching here to recall these facts, but 12 I think that he probably, his response was along the lines of 13 yeah, it worked well that way and if we change it back it 14 probably would work well that way, again, some response along 15 lthose lines.
I I
l Q So what was the conclusion of this first interview?
I 1
, A Well, he appeared to run out of the topics that he .
wanted to discuss with me and thanked me for seeing him and 19 said good-by. .
! 00
~
l Q Did he plan any followup or inform you of any 21 l further action that you should expect?
A Not at the time that that interview was held.
23 Early on Thursday morning, as I recall, we started:about 7:30 24 and finished, oh, in about an hour. Of course, I was stationed
_ gt Onnnan and th4e in&mpu(m*f une hmid in Phavin&&m_
(V(LYN $. B(RGER OFFICI AL court R(PORTER U. S. OtSTRfCT COURT CH ARLOTT(. N. C.
Grior - D!. rect 101 l
1 I immediately drove back to oconee and received a 2
ltelephonecallfromMr.DickorMr.Grogan,Idon'tremember 3 !
which one, but one or the other around two o' clock on Thursday 4
afternoon and was told, asked, to be in Mr. Owen's office in 5
- Charlotte the next day on Friday. -
6 I'm not sure, what time, maybe eleven o' clock. ,'
. O And I take it you showed up? -
A I showed up.
Q And what happened then? What did Mr. Owen have to say then?
11 A At that time'he explained what I've explained 1
previously, that INPO was being staffed for Phase Two and that 13 he had decided to make Mr. Wells available for that assignment 14 and he had to fill the Corporate Quality Assurance Manager 15 pocition and wondered or gave me about as much choice as you 10 get in those situations, as to whether I wanted the situation
, or not. .
I took it that I had a choice. -
, O Was anyone else present at that meeting'? .
20 A No.
21 Q What did he tell you, if anything, about your job 22 responsibilities, your duties?
23 A Well, as I recall he expressed his opinion that I 24 knew what the requirements of the Quality Assurance Manager's 25 iob wara anA wha + +h= cann i r===vi += nr nnalftv a==uranen of the
~ EVELYN $. BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CHARLOTTE, N. C.
Crior - Dircet 102
> 3
+ l ,
I
- Company were, so he would not go into those details.
2 He did explain at that time that there was a task 3
l force that had been formed to investigate concerns at Catawba, 4
and that one of my assignments naturally as Corporate Quality 5
. Assurance Manager, would be to put into place the corrective -
, 6 '
action coming out of the task force recommendations. ,
7 *
. Q Did you know of the job requirements at that time?
8 A Yes, I was pretty well versed from my experience at 9
McGuire on the Quality Assurance requirements. He was aware 10 that in 1971 when I was first assigned to McGuire, that was I '
about the time that 10CFR50, Appendix B, came into affect; and 12 one of my primary responsibilities early at McGuire was to 13 develop Quality Assurance procedures that were responsive to the Eighteen Point Criteria.
15 0 What else did Mr. Owen have to say to you, if any-16 thing, about your responsibilities with regard to dealing with I
, the Welding Inspector concerns? .
A I don't recall; I am sure we had more words than 19
- , what I've just said here, but I really don't recall any other .
20 specific information. I'm not sure whether at that meeting or 21 maybe a few days later he made available to me his file in
- regards to both the pay issue and the technical concerns, and 23 as I assumed by responsibilities as Corporate Quality Assurance 24 Manager we kept pretty much in daily contact in regards to this 25 gg , , _, _ _ _ , _ ,,, - % g,
- OFFICIAL COURT RE?ORTER U. S. OlstmiCT COURT CH ARLOTTE N. C.
\
Grior - Diract 103 I .
i i 1 ' as far as getting their activities started, the task force to 2 1 deal with the specific written concerns was put into place 3 ; before I assumed the responsibility as Corporate QA Manager; 4 but it was only a matter of days, I'm not sure how many, perhaps 5 a weeks so they were really just getting started. ,
. 6 So I maintained contact with the Chairman and with [
7 Mr. Owen to keep him informed, and in that process, I'm sure he -
8 made me aware of background information in this area.
9 0 Who is the Chairman of the task force that you had 10 reference to?
11 A Parks Cobb, C-O-B-B. ,
12 Were you made aware at the time of a task force that Q
13 had been organized in early December to review the Welding 14 Inspector concerns?
15 A Yes, I'm not -- I don't think that das in the course 16 of the meeting at which Mr. Owen offered me the position; but 17 very shortly after that I was aware either verbally or by .
. 18 being given a copy of that task force report, one or the other.
19 0 Why was there a second task force? ,
20 A Ucil, as I understand it, both from reading the 21 documentation generated through that period of time and talking 22 with individuals, that task force dealt with the issue that 23 technical concerns had been expressed by Inspectors in a broad 24 sense.
25 chou did not specifically review individual concerns,
~
I EVELYN $. B(RGER OFFICIAL COURT REPORTER
- u. S. DISTRICT COURT CH ARLOTTE, N. C.
l I
l Grier - Direct 104 1
as a catter of fact, when that first task force performed their 2
' actions, I believe what material they had to work with was 3
, Ms. Addis' and Mr. Wells' memos documenting concerns as they 4
,had heard them, plus interviews with the Inspectors.
5
. At that point in time no Inspector had specifically -
. 6 been told to write down individual concerns. At a point in .
7 *
- time fairly early in January there was a realization that the 8
concerns of Inspectors were indeed specific and could be 8
specifically tied to Walder work situations, and at that time 10 each Inspector was asked to write down as specifically as 11 possible what their concern was.
12 That was after the first task force had concluded 13 their report; so the second task force was put into place and 14 charged with the task of recommending actions on each and every 15 specific concern.
l Q Mr. Grier, I want to show you a document that has 17
, been identified by the Company as handwritten notes from QC .
- 18 and QA Inspectors which set forth their specific problems and concerne. It is Item Ten of Attachment One to Letter from .
Counsel of April 12, 1983; and it is part of what I am handing 1
you and it follows behind that cover sheet (indicating.)
22 Can you identify those documents that fall behind there?
A Yes.
24 g y gy, ,,, go,,7 25 7 ,, ,,,, ,,mm414xv uf+h +h==
3 == &hav wave cut anart EvtLYN $. SERGER OFFICIAL court REPORTER U. S. DISTRICT court CHARLOTTE. N. C.
Grior - Dircct 105 1
- and made part of Volume Two of the Welding Inspector Task Force .
- I I 2
Report. !
3 Q Nare those specific concerns that were documented as 4
a result of going back to the Inspectors at the conclusion of the first task force and what we will call Task Force Two?. -
6 A Yes. ,'
a ~
Q And they became identified in late-January early-8 February of 1982; is that right?
9 i
A In reading the documentation, I believe I understand 10 l
that in the course of a meeting between Welding Inspectors and 11 Mr. Larry Davison, it occurred in the second week of January.
12 At that meeting Mr. Davison requested or directed 13 the Inspectors to write their concerns specifically so that we 14 could determine what to do with them at that time.
15 0 Now these Inspectors whose concerns are reflected in 16 Item Ten, again, the list of namco, with a couple of exceptions
. are all of those Inspectors on Mr. Beau Ross' team at Catawba? -
A I really can't answer that from scanning these names ,
10 '
, I believe that a majority of thone, however many there are there,.
20 would have been in Mr. hoss' crew at the time the concerns were 21 expressed.
22 O All right now, were there other Inspectors who 23 expressed concerns?
24 A Beyond those?
25 0 Oth r thr. thi Q :p Q g:7 0FFICIAL Court atP04 ten CHA OTTE. N C
Grier - Direct 106 i
1 A ?!ot that I'm aware of.
2 Q I want to understand your question: At the time i
3 early in January when a request was made for Inspectors to l 4 write down their concerns, were there others other than this 5 list; is that your question?
6 And the answer to that question as you have just -
Q 7 said is not that you are aware of? .
8 g yem not aware of any.
9 0 That is responsive to that, to Mr. Davison's request 10 to the Inspectors on the job, their concerns were put in writing?
I 11 A That's correct.
12 Before that were there other concerns expressed?
Q 13 A Again, I am now aware that Gail Addis in her inter-14 views or investigation of the Step Two Recourse spoke with i 10 Inspectors and was made aware of some technical concerns which 16 i she documented in a memorandum to Mr. Owen.
17 Mr. Wells was also involved in those interviews and j
- 18 also documented some concerns that he heard expressed.
l . _
19 And those wore expressed before the notes that you Q .
l 20 have in front of you that were elicited by Mr. Davison, largely l
21 from Mr. Ross' crew?
22 l A That's correct; and again, I have not specifically 1
23 studied these concerns from the standpoint of tying them to one 24 crew. I have not been interested in doing that particularly, 25 so my impression is that most of them were in Mr. Ross' crew, EVELYN $, BERGER OFFICIAL COURT RIPORTER U S. DISTRICT COURT CHARLOTTE. N. C,
1 Grior - Direct 107 l i.
1
! but I have not specifically set out to see that.
i 2 ! O Lut that is the understanding you came to in whatever i
3 lIprocess you came to that?
4 A I don't know if it is a majority by one or whether 5
. most of them are; I don't know that. -
, 6 "
Q When did you become aware that there were concerns ,
7
. of technical character, as you have used the term, expressed -
8 by persons other than on the list reflected on Item Ten of Attachment One? .
10 A As I say, those have been concerns expressed at the 11 time of, the Step Two Pay Recourser and I got that background 12 information when I took over the position and was aware of that 13 Phase of the concerns.
14 0 And what did you do in response to learning of the 15 concerns of other than those that are now in front us?
16 A I made sure that I understood that the tack force 17
, effort was going to be centered around the concerns turned .
. 18 '
in by the Inspeccors at Mr. Davison's request, whereby he 10
' spoke with every Welding Inspector and said we would like for .
20 you to write specifically your concerns down, backed up by the 21 fact that the task force was going to go back to each and every 22 Inspector and interview them to make sure they understood what 93
~
the concerns in writing meant and that they had no further 24 Concerns.
5 g ,,, 4 , y ,mg,,,4.,,3 7, ,, m, ,,, ,4,33 ,,, ,, ,, ,34, Evrtyn S. BtRotR OFFICIAL COURT RCPORTER U. S. DISTRICT COURT CH ARLOTTE, M C.
i Grior - Dir0ct 108 l
I point the points were Mr. Davison met with these Welding 2 i Inspectors just prior to your accepting the position?
3 A About two weeks I would say.
4 0 So you understood shortly after taking the job that 5
, Mr. Davison had specifically instructed or requested Welding -
6 7
Inspectors to put in Writing their specific concerns?
[
, A correet; I don't believe at that time I took the -
8 position I understood that this had come forth by request from 8
Mr. Davison. I think I learned tIiat later, but I knew there 10 had been a request by someone to have the Inspectors produce 11 those documents.
12 O And that the task force, to understand your last 13 response, the task force was going to address each and every 14 specific concern expressed in writing by Inspectors as a result 15 of the request that you know now came from Mr. Davison.
16 l A That is thrcugh his going and interviewing ecch i
17 Inspector to make sure they understood what the concern meant, .
18 ~
if there was some unclearness in the writing; and to see if they 19 had other concerns that they neglected to write down in this .
20 initial request.
21 0 So there is a followup interview with those Inspecto rs 22 who put something in writing; correct?
23 A That's correct.
24 l Q Now what about the Inspectors who had previously 25 expressed concerna. ci+kar _ in wel+4na ne in an in+=rviaw with EvstvN S. BtRosa CFFICIAL COURT REPORTER U, S. DISTRICT COURT CH ARLOTTE. N. C.
Grier - Dirtat 109 1
Ms. Addis c: with Mr. ells, what chout responding to their 2
concerns, Mr. Grier?
3 A It is my understanding that the task force interviewed I
4 all the Welding Inspectors, which would have included any 5
. Inspectors who happen not to be on this list who have expressed -
- 6 '
concerns to Gail Addis. .
. Q And that was the vehicle for identifying any additional 8
concerns?
9 A Well, that was the vehicle for the concerns to be 10 expressed and reviewed for any recommended action by the task 11 force.
12 O Are you sure, Mr. Grier, that all of the concerns 13 that were expressed had been addressed by the task force?
14 A I'm sure that all of the concerns that came 15 forth had been addressed by the task force, yes.
16 '
O IIow about the concerns that did not come forth in I
, the sense that they were made known to Duke Power Management ,
by Ms. Addis, through Mr. Mc11s, but may not have been repeated
- ~
19 i
'or documented by the tack force? .
90
~
A Well, if there was any general concern that had 21 been expressed to Ms. Addis that did not specifically get 22 written down, that general concern was the subject of the first !
23 task force that was, in fact, constituted to look at the 24 general nature of the concerns and to make some judgment as to 25 the nn+ue. nr +w. -mme..n. .na .--. ..-mm..ma.+4nn.. .n +hn..
' ~ ~ ~ - ~ ~ EvtLvn 1 IRERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT I CwaRt0nt,n. c. !
Gru.r - Direct 110 t .'*
(,
1i vculd have been dealt with by the first task force.
I LI 11ut also the nature of those general concerns was 4
3 lvery similar, if not precisely the same, as the general type 4
jofconcernsthathadbeen,expressedinwritingbytheInspectorp.
5 ' that produced these written concerns. .
. 6 O Are yoS aware of any efforts to identify concerns
- 7 reflected in Ms. Addis' notes of interviews or Mr. Wells' notes -
~
8 of interviers or in notes from anyone else who documented 9 Welding Inspector concerns, any effort to determine whether 10 those had been addressed by the task force? I'
~
11 A ,I believe, well,'I know that the task force, the '
12 second task force was given a copy of the first task force 13 reports and I'm really sure that they were given a copy of 14 Ms. Addis' memorandum indicating ^those concerns.
15 And my recollection is not~all that good on this 16 point, but I am rure that the secon task force used that 17 information to see if there was anything different or unique ,
18 in any of the occumentation from Ms. Addic that was not contained ~
19 inoneofthewrittenconcernsthatwastNrnedin. -.
^
20 'O And was that analysia reflected in the report of
- 21 the secono task ferce?
22 A I don't recall anything'in that.first task force 23 that spoke'to that. e-fit 24 Q The second task force? 5#~
25 A I'm sorry the second task force.
EYtLYN $. BERGER ,, -,
OFFICML COURT REPORTit ,
- u. S. DestatCT COURT "
,, <' / CHARLOTTE, N. C.
i
Gricr - Direct lli 1
0 So you precume that they did thatt you think ther i
2 ' had access to that mmo, but you are not aware of the specific 3 reference having gone through and said this concern is addresseid l
4 at this point?
5 A I'm not aware of any analysis like that in this 6 document. -
7
. 0 All right, how did it come to the understanding of .
8 Duke Management that there were specific hardware concerns that 9
had been identif,ied that needed to be addressed through the 10 vehicle that is now the second task force?
11 A I'm not sure. I believe my understanding is that 12
.just in the course of conversations with some of the Inspectors 13 there was an expression that they had some specific issues, 14 specific questions or concerns about how certain situations 15 with specific welds had been handled, and that they were 16 interested as to whetYtr that was what was handled by the 17 first task force.
18 I believe that there was a realization that the "
19 first task force van handling more general issues and not the 20 specific wcld by weld issues and there was a need to document 21 those types of concerns for resolution.
22 0 The specific concerns, welds?
23 A That's correct. ;
24 0 Who was responsible for commissioning the second 25 task force?
EVELYN $. BERGER OFFICIAL CCURT REPORTER
( U. S. Ot$TatCT COURT
'r, CHARLOTTE. N. C.
__- - . - _ - _ - _ - - _ _ _ - _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ . _-__n
Grict - Direct 112 L l n
/. 1 A Mr. Owen. I 2
- O And what was the means which he did that?
3 A I believe there is a letter, a memorandum written by 4 him doing that; and specifically I am aware of letters from the 5 Chairman to Mr. Owen expressing his views about how to get on 6 with the task. '
7 Q Why was the makeup of the task force changed?
8 A Well, I really did not become aware that there had 9 been a change in that makeup until not many months ago, just 10 in the course of reviewing documentation I became aware that 11 for a very short period of time, not much more than a week, 12 that Mr. Larry Coggins was the Chairman.
13 But shortly after that Mr. Cobb was made Chairman 14 and as I understand it, there was just a situation, that due 15 to the volume of concerns, this task force effort might be 16 l substantial, and that there was .possibly a need for more i
17 ' Senior Management to head the task force effort; and Mr. Cobb R -
, 18 has had more experience, has had higher level Management -
l 19 positions than Mr. Coggins hn? had.
. ~
20 What position had fir. Coggins held as cpposed to Q
21 Mr. Cobb by comparison?
22 A Mr. Coggins was a OA Engineer in our Technical 23 Services organization; and Mr. Cobb was either a Senior or 24 Principal Engineer with the Design Engineering Department.
25 0 was there concern that Mr. Coquins had been involved EV(LYN $. B(RGER OFFICIAL COURT REPORTER U. S. DISTRICT court CHARLOTTE. M. C.
Grier - Direct 113
, I
. 1 i 1 i in resolving Construction deficiencies; and therefore might i i
2 i look somewhat inobjectively on the concerns?
l 3 A reve never heard that expressed.
l 4 O He did, in fact, have responsibility in part for 5 resolving construction deficiencies?
6 A He was responsible, he had been responsible for -
7 reviewing the disposition of non-conforming items, for . example, 8 that were generated in Design Engineering that would relate 9
to deficiencies discovered at the construction site.
10 How about the number of members of the task force, Q
11 vhy was it expanded?
12 A It was expanded to add Mr. Cobb to be Chairman.
13 From the original December task force until just O
14 the second task force?
15 3 geti, yem not clear about your question. The first 16 task force, er I recall, had three members and the second 17 task force had, it seems like there were five, I'm not sure I
. 18 can recall the last number, five members, I would expect, just -
' ~
19 cccc idea of the voluno of ucrk.
20 As you look at the makeup, there was a person from 21 the principal organization groups that are involved in the l
22 There was a member from Quality construction of the Plant.
23 Assurance, a member from Construction, the Chairman was from 24 Design; and there were two other Design members, and I guess 25 the Danien members, there were more Desien members because the EVELYN $. OCRGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE, N. C.
Grior - Dirset 114 l
1! i issues were r.cro technical in nature.
i !
2
- O Who colected the membership in the first task force?
3 l A I would presume that Mr. Owen did; I'm not sure but i
4
' that he had from discussion with Mr. Lee about it, but I really' 5
, don't know. I presume Mr. Owen did. .
6 0 llow about the second task force?
7
. A I presume Mr. Owen also did, and I really don't know. .
8 I have not discussed with anyone exactly how the membership 8
was set.
10 0 Do you know whether or not Mr. Lee was informed and 11 participated in the decision to constitute the second task 12 force?
13 A I don't know for a fact, but just knowing the working 14 relationship between Mr. Owen and Mr. Lee, I'm sure that Mr. Le n 15 was informed.
16 0 Uhen did you first learn that a consultant hcd been 17 involved in recponding to the Helding Inspector concerns? ,
18 A Uithin a matter of days of assuming the responsibility,'
I
( perhaps the fir: t dcy; I don't recall. .
20 Q nea did you icarn that; do you recall?
21 A I would expect Mr. Owen informed me of that.
22 O Uhat did Mr. Owen have to say, to the best of your 23 recollection, about the relationship with the Consultant and 24 his responsibility?
25 ,
t,g 3 7, , , , , , , , % ag ,,,m,, ,,,, ,,,g 3 ,y , ,, y Evrtya S. BERota OFFICIAL COURT REPORTER U. 5. DISTRICT COURT CH ARLOTTE, M. C.
4 Crier - Direc: 115 1
! a letter whien laid out the Consultant's responsibility, but I
2 I in discussion I'm sure he made it clear to me that the consultant 3
was there to independently determine such things, first, that 4
the membership of the task force were technically competent to
. perform the task before them, that they, in fact, had set up .
methods to be sure that all of the concerns that the Inspectors .'
. had were, in fact, going to be brought out and brought forward -
8 and considered.
9 The Consultant was responsible for looking at the 10 technique that the task force would set up to review these 11 concerns, particularly being interested in some back-checking 12 of the recommendations, some independence in those recommenda-13 tions.
14 The Consultant was charged with some independent 15 interviewing, reviewing on his own to ascertain the nature of 16 the concernc; and in this task that the Concultant had, he was
, to report those results to Mr. Owen. ,
O Did you understand that the Consultant was to.be 10 prepared to present evidence as to the validity of the task .
20 force investigation in the Catawba Operating Licensing proceeding?
21 A I beljeve that was in the letter laying out the 22 responsibilities or duties of the Consultant.
23 Q That is where you would have learned that?
l 24 A I believe so; I don't believe there was. any amount of 25 A { c mt e c-----...&h-6 4 nn n _--
&.n. n _t e_ .
OFFICIAL court REPORTER U. S OtSTRICT COURT CH ARLOTTE, N. C.
I
Gra nr ' ; reset 116 I..
I' '
2 102en did you first learn of contacts with anyone L
2 frex the consulting firm?
3 A Within a week or se of assuning my responsibilities.
4 Q What was that contact?
5
. A The Consultant was Mr. Lew, L-E-W, Zwissler; and I ,
6 really cannot recall the first contact, specifically; but I'm [
7 sure that we met each other and he reviewed with me what he -
8 was there to do.
O Did he come to you or did you talk to him by phone?
10 A No, we maintained an office for him in the Quelity 11 Assurance area here at the General Office.
12 Q How long was Mr. Zwissler with you?
13 A He spent a fair amount of time with us, through 14 February and a portion of Mcrch. During that period of time 15 he night have bcen here for a week at a time and gone for 16 several days and back for several days; but a fairly substantial
, amount of tine in that more or less six week period. ,
O Did you understtnd that either Mr. "wissler or his 19
- company had had prior experience in responding to like concerns ? ,
20 A 1 was told that, I wasn't persoaally aware that they 21 had.
22 O And did he tell you that? How did you learn that?
23 A I really can't say how I learned that.
2e Q Uhat did you know of his experience?
l
- M9. n s.n .,e n ,-a s s e n r> -4A.-,knA g o.ma _ 7# 1L'w _ '7t*4 nela r=
EVELYN $. SERGER OFFICIAL COURT REPORTER
-l' U. S. DISTRICT COURT CH ARLOTTE, M. C.
I Grier - DL:cc~. a17
--n i .
i i
1llattachedtotnoproposal,Ibelieve. And as I recall he had I
2 substantial experience in Quality Assurance matters.
3 O Do you recall where he had had that experience?
4 A t;o, I don't specifically recall. Well, it comes to
. mind that he was the Quality Assurance Manager at a National .
Laboratory, I'm not sure which one. ,
Q How about South Texas? -
8 A Well, that is not a laboratory. I became aware 9
somewhere along the line that he, in his company, but perhaps 10 he had been involved in some Quality Assurance Consulting 11 businous at South Texas.
12 O Are you aware that South Texas facilities had had 13 cignificant Quality Assurance breakdowns?
14 A I was aware that there was a discussion by the 15 Utility Manager to discontinue the contract with the Architect 1G Engineer and Construction Manager and retain a new Architect 17
, Engincar and Construction Managor, Constructor. ,
O And Mr. Zwissler camo.in and in some temporary 10 capacity was responsibic for responding to the Quality ,
20 Assurance deficiencies at tnat Plant?
21 A I was not specifically aware and really did not have 22 any discucsions with Mr. Zwissic cn that topic.
23 0 How did You understand Mr. Zwissler to employ the 24 tona " skilled interviewers" with respect to responding to the 25
_ ua_ _,u .,,.,7._t.-.--m.-
.*r--=*"a
.a
" v ' * - * - *
- g-g Of f tCIAL court REPORTER
GriOr - Dircct 118 1 '
A I really don't recall a discussion with.him on that 2 term.
~!
3 l Do you recall that term being used?
Q 4 A I really don't recall that.
5 0 What did Mr. zwissler have to contribute, or anyone ,
6
. else from the Mack Management Analysis Company? -
7 A
. Management Analysis company or Corporation, I don't .
8 remember.
8 0 What did either Mr. zwissler or his firm have to 10 contribute to the approach that the Company took to responcing 11 to the Welding Inspector concerns?
12 A Well, most of those dealings, as a matter of fact, 12 I would say most all of those dealings were between Mr.
14 Zwissler and Mr. Cobb or Mr. Owen; but I recall that Mr.
15 Zwissler reviewed the techniques that Mr. Cobb was employing; 16 and I recall that he had some discussion in regard to how that 17 was going to be documented; but I don't recall any specifics. -
18 0 Was he responsible for designing the structure of
- 19 the interview process?
~
20 A Not that I'm aware of.
21 O Who was?
22 A Well, the Chairman of the task force, I would think.
l 23 0 Mr. Cobb?
24 3 y,,,
25 0 How about the desion of the forms used to record?
EvtWN S. BERGER OFFICIAL COURT REPSmitR U. S. DISTR'CT court CH ARLOTTE. N. C.
Gricr - Dircct 119 i
1 A I believe those were designed by the task force, i
2 itself. ,
i 3 Q Not th . Zwissler?
4 A I don't believe so.
5 0 All right, how about the design of segregating the ,
6 technical from the non-technical concerns as those terms were -
7 used by the task force? Who was responsible for that?
8 A Well, at the time the task force began their efforts 9 they determined that they would identify each concern as a 10 specific item to review and make recommendations on.
11 As they got into that process it was apparent to 12 them that some of those concerns were not technical in nature, 13 but were rather Administrative in nature and they felt that 14 those would be best handled by someone with more expertise 15 in that area.
16 There was a discussion between Mr. Cobb,-myself and 17 Mr. Owen and myself. I don't recall the nature of it, whether -
. 18 we met at one time; but in the course of discussions we -
~
19 determined that the best arrangement would be to segregate out 20 the two types of concerns, to cppoint a task group oriented 21 toward Administrative matters to deal with the non-technical 22 concerns.
23 So I made a recommendation to Mr. Owen as to how 24 to do that and who to appoint as the non-technical task force.
25 He approved that recommendation and I appointed the non-technical EvtLYN $. BtRGER OFFICIAL COURT RtPomTER U. S. DtSTRICT COURT CHARLOTTE,N. C.
4 Grier - DirOct 120 l
i l 1I group.
2 l Q Who was that?
3 A Mr. C. N. Alexander and Mr. Danny Pruill.
4 Q Who is Mr. Pruill?
5
, A Mr. Pruill at that time was the Employer Relations ,
6
- Supervisor at Catawba, and about that time I think he moved
. into the General Office in Construction; but he was an Employer .
8 Relations Supervisor in Construction.
8 Q And his position now, if you know?
10 A He is the Employer Relations, or I'm sorry, he is 11 the Personnel Supervisor -- I'm not sure if that is exactly '
the correct title -- but Personnel Supervisor at the Oconee Station Support Division.
14 0 And Mr. Alexander, his position at the timer do you recall?
A At the time Mr. Alexander was the Personnel Manager
, or Supervisor at the Mt. Holly Station Support Division in the ,
- ~
Construction Department. Presently he is the Manager, QA 1
Manager of the Administrative services Division within the
\ ,
l 20
- Quality Assurance Department.
1 i Q Now what definition was employed of the terms 22
" technical," and "non-technical," Mr. Grier,-for pw. poses of 23 segregating concerns of one character from the other?
24 A Basically issues that dealt with employees' 25 ,;,,,,,,,,,, ,,,, ,,,,,,,,,,34, ,,,,,,, , ,
l - ~
,,3, 4,,,, ,,, ,,,,1,1, l EvtLiN $. BERGER OFFICIAL COURT REPORTER U. S. OstTRICT COUkT CHARLOTTE, N. C.
Grier - Direct 121
., 1 f
I 1 ' work activities, specific tr.spection activities, specific I
2 ; Quality Assurance Procedures -- l 3 O That definition represents what?
4 A Well, those matters that are outside of those 5 specific OA Procedure concerns would be non-technical.
6 O And technical, any further definitional matters .
7 included in what is a technical concern? .
8 A No,'I think that is pretty complete, those things 9 that would relate to a Quality Assurance Procedure to the 10 standards that an Inspector would use in determining acceptability 11 or rejection of work activities.
12 O How do you understand and use the term "harrassment, '
13 Mr. Grier, as it relates to this subject, Welding Inspector 14 concerns?
15 A Well, there is a definition of harrassment in both 16 Corporate Procedure and in our Quality Assurance Department 17 Procedure that speaks of some action detrimental to an
, 18 individual because of their race, religion, these types of .
- ~
19 ' attributes.
20 0 You have reference to the procedures that your 21 Counsel made available this morning, the Departmental Recourse i 22 Procedure on Harrassment?
23 A It is termed "Harrassment," I think. .It is one of 24 the procedures that was made available to you.
2S O All right, sir; I didn't mean to interrupt, but I EVELYN $ B(RGER OFFICIAL COURT REPORTER
l Grier - Direct .
122 1
wanted to get that reference.
2f A My definition, I guess, I would say is a personal 3
' definition or kind of a guideline that I would use to determine 4
that in the nature of an Inspector's work relationship where 5 ' harrassment would be an action or activity whereby an Inspector 6
- would be fearful to perform their required duties because of _'
I
. some threat. -
8 0 I am looking at the procedura you had reference to, 8
Harrassment of Employees effective 7/1/82. How does that 10 procedure relate or describe or define the kind of harrassment 11 i that you .just had reference to material to the relationship of 12 an Inspector to his work or to someone who's work he is 13 inspecting?
14 A well, this is the procedure that an individual would follow if they felt harrassed for any reason.
16 0 Well, doesn't that procedure govern harrassment 17 because of an individual's race, sex,.natio.a1 origin? ,
18
't that the primary thrust of Khat -- race, religion or
, ~
Is
~
cthnic group or sex?
20 A This says that harrassment is "any action which 21 singles out an employee" and it is not limited to race, religica, 22 et cetera.
23 0 I am trying to understand it is the thrust assumed 24 to say quote "harrassment is any action that singles out an 25 ,m,3 ,,,, ,, ,3 , ,,,,,,,,,, ,s4,,,,,, ,, ,,,,,,,,, g,,,,,, ,, 3, ,
. .-a -- -
l 0FFICIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE. N C.
Grier - Dircct 123 y' I j !
I not linited to inate personal characteristics," and it coes on l 2
with r.atters that are not particularly material , but it is 3
harrassment because of sone feature or character of the 4
individual harrassed. Isn't that what that definition focuses 5
, on, Mr. Grier? - ...
6 A That is the focus of that sentence therer but this 7
. procedure is the procedure that would be used if an employee -
8 felt harrassed for any reason.
8 Q So that did not help us define the type of harrassment 10 we are talking about here.
11 A No, that was a personal definition.
12 O Is there a procedure that providcs the definition 13 of harrassment as it relates to an Inspector's job?
14 A No.
15 Q Is there a policy about the kind of harrassment 16 defined that is making a person fearful to perform required 17 duties because of a threat?
18 g 1.m not aware of any written policy along those lines.*
19 0 All right now, focusing on the definition that is 20 material to an Inspector performing his job, what kinds of 21 threats would fall within your understanding and use of the 2
term?
23 A Well, any threat that made an Inspector or any person 24 fearful of performing their assigned activity.
5
__ O Phyniem1 +hvent?
EvtLYN $. StRGER OFFICI AL COURT REPORTER U. S. DISThsCT COURT CHARLOTTE, N. C.
Griar - Direct 124 1
A Physical threat.
O Threat of physical violence?
3 A Yes that certainly would be one.
4 Q Verbal threat? Abusive language?
5
. A Well, language, language in itself probably would .
O not make a person fearful of carrying out their activity. That ,'
would obviously be the individual's feelings; but -- -
8 Q Is the important thing what the perception of the --
9 if we are talking about verbal threat or verbal harrassment --
10 it is the perception of the hearer that mattars then?
11 A I would certainly think so, yes.
12 Q Itow about a threat of adverse action with respectn .o 13 cmployment?
14 A Yes, that could make a person fearful.
15 Q Firing, demotions?
16 '
! A Yec.
1
, Q Adverse action with respect to pay, working conditions,?
- ~
A Those certainly would be in that category.
19 Q And in that, this definition that you have used, ,
20 you have expressed as your personal definition, is that defini-9
~1 tion consirtent with the way you understand the term "harrass-
- 2
~
ment" to have been used by the Welding Inspectors and their 23 expressions of concern?
24 A No.
25 ,, ,,, ,, ,,,,,,,
~ n ,,33 EvtLYN $. BERGER OFFICIAL COURT REPORTER U. S. ..STRtCT COURT CN ARLOTTE. N C.
. l
GriGr - Dircct 125 1
l A Well, I believe that the term was used by the 2 ~
, Inspectors more as an expression of arguments that had ensued l
3 between the Inspector and the Craftsmen.
4 In other words, their term encompassed a broader 5
, scope of adverse human relationship than the definition I gave ,
6 *
- you.
. O All right, sir, and broader why, Mr. Grier? ,
A Well, because of my reading of some of the concerns 9
that were turned in, they seemed to express situations that 10 involved some argument, undoubtedly loud conversation, perhaps 11 '
some obsenities, whatever, that had taken place between 12 Inspectors and Craftsment but apparently did not deter the 13 Inspector from carrying out h5.s assigned task.
14 0 Is the operative distinction then that the harrass-15 ment that was characterized by the Welding Inspectors and 10 their concerna did not make them fearful to perform their required dutics? Pearful, 10 that the operative distinction?
A Yes, anything that would, in fact, be detrirnental ~
to the Quality Assurance Program in a sense of not carrying 20 out the tasks that we are responsible for carrying out.
21 Q And there again, as earlier, is it not primarily 22 Jear in the hearing of the hearer, fear in the sense of how 23 the person who is the recipient of the threat or verbal 24 exchange perceives that threat or verbal exchange? Is that 25
. the hey?
Evcun s. a:RocR OFFICIAL COURT REPORTER U. S. DesTRICT COURT CH ARLOTTc, M. C.
Grior - Dircct 126 l
1 i
A I'm not sure I followed your train right there, but 2 lIthinkIagree. Would you mind --
3 O Sure, is the distinction that the act of physical or 4
shall we say the acts of verbal abuse, use of profanity, 5
, argument, in the example of a Welding Supervisor or Craftsman 6
- to a Welding Inspector, did not, in fact, make the Welding
. Inspector fearful to perform his required duties? .
A Yes, that is the distinction. Yes, in my mind there 9
is a distinction between a situation where a person is fearful 10 of performing his tack and thereby not, in fact, able to per-11 form that task in a situation where there is some uncomfortable I
disagreement in a working relationship.
13 0 Why did you reach the conclusion in the instance of 14 the Welding Inspectors they were not fearful of performing their required dutics?
10 f A They continued to perform their duties.
17 O Mr. Grior, don't you think that just practically
- ~
speaking, that put someone in a position where the more the thich skinned, the more superlative, the more outstanding you .
"O are in resisting threct, the less protection yo- get from the 21 throat in the first instance?
22 A Not at all, I don't condone those disagreenents.
'3
~
I make the distinction between harrassment and those disagree-24 ments because harrassment, as we define it in Duke Power is 25 nortn m mna enn ro ma
- i n +arwin=*4nn <r = 'n.*enn in rmma i EvtLYN S. BERCER 0FFICIAL COURT REPORTER U S. OlstRICT COURT CHARLofit. N C.
_ _ _ . . _ _ .___.____.________._a
Grier - Dircct 127
/ 1 guilty of harrassing another individual, whereas a disagreement, 2
l those are to be resolved.
I I
3 I don't condone those, they are adverse to good 4
working relationships. They are adverse to productive ly carrying 5
on the task; so although..I make the distinction between the _
6
. harrassment and these disagreements, I don't condone either -
7
. one. .
8 0 In your terms of seriousness or a measure of serious -
9 ness we can agree that no instances of harrassment identified 10 by the Welding Inspectors lead to termination of anyone.
11 Do you know of any instances where the paramoter of an act in 12 what was characterized as harrassment resulted in termination?
13 A In our Quality Assurance Procedure we have a 14 graduated scale of disciplinary actions, depending on the 15 ccale of the harrassment.
19
- O That is the same at in the Construction'Harrassment 17 Procedure?
18 3 7,m not sure, but I believe there has been some -
19 '
disciplinary actionc taken an a result of come harrassmdnt 20 investigations in the past.. I'm not perfectly sure about that.
21 O Involving concerno expressed by the Welding 22 Inspectors?
23 A I'm not sure whether a Welding Inspector or some 24 other Inspector.
25 0 Uriner vnnr vnrkiner arfinitinn of meriousness, and
~~
EvtLYN $. BERGER OFHCIAL court REPORTER U. S. DISTRICT court CH ARLOTTE, N C.
m
Grior - Dircct 128 l
. 'l 1 j I understood you to say Duke does take it seriously and it is 2 a firing offense if it is serious--
3 ; A Of the most serious nature, there is a graduated 4 scale of discipline, but the most serious harrassment, if 5 proven, would result in termination.
6 0 I want to understand, do any of the concerns .
7 expressed by the Welding Inspectors represent harrassment in 8 the sense that it produced disciplinary action of that definition, 9 termination?
10 A Mo, there were not terminations as a result.
11 O How about the instance where a Craftsman pointed a 12 rific at a Helding Inspector?
13 A Well, I believe that had occurred some period of 14 time before the concern was expressed. As I recall the informa -
15 tion that I've gotten on that particular inctance, I've learned 16 of several factorc.
17 one is that the Craftsman who allegedly, I'll say
, 18 pointed a rifle at a vehicle off the job, was pointing a' .
19 rifle at a vehicle that contained ncme number of folks, and 20 included in that vnhicle was a Welding Inspector.
21 There was some supposition that because of some 22 inter-relationship between those two individuals on the job, 23 that the Welding Inspector might have been .the person involved.
l 24 That is one piece of information that I've learned.
25 Another is that an investication of harrassment was EVELYN $. B(RGER OFFICIAL COURT REPORTER U. $. OlSTRICT court CMARLOTTE, N. C,
Grier - Dirset 129 l
l intended to proceed on that instanoe, but the individual alleged to have pointed the rifle turned in his noticer and, 3 h in face, quit the next day, so there was no, the Company was 4 i not able to pursue that investigation.
5 !
- Did the Welding Inspector bring the incident to the,t
. Q I
6 I
~
' attention of Managemant promptly?
- A Uell, since my understanding is that an investiga- .
8 tion was to proceed the next day, I would presume that someone 9
did. I frankly don't know whether it was the Inspector involved 10 or someone else in the automobile.
11 Q Who were the individuals involved? .
12 A The Inspector involved was Mr. Bill Deaton. I 13 don't know the name-of the Craft person or the names of the 14 other individuals in the automobile.
15 0 Uac that determined, do you know the identity of 16 I the individual?
, A I would suspect so, I just don't happen to know. .
MR. GUILD: Do you want to take a break,
- 19 .
I .
ten minutes?
20 (Wacreupon, the deposition adjourned for a 21 brief recess, after which the following proceedings 22 were had:)
23 24 BY MR. GUILD:
A, -ter- - - N4
- --aw , - - - -h -at.
An seru, --
i s s= 4 m w ar e- a ,s A anA
- - - - - - - - - - -- - .n -ai ns, 4= h m l OFFICIAL COURT REPOR7tm U. S. DISTRICT COURT CM Amt0 Tit, N. C,
l l
Gria- - Direct 110 l
! 1 1
term " falsification" as related to the Welding Inspector 2 i concerns?
3 A That would be the conscious action by an employee 4
to represent something that was not factual.
5
. 0 And in your opinion is that the way in which the ,t 6 -
Welding Inspectors employed that term in expressing a concern?
. A No, it is not. .
8 Q How does it differ in the way that you used it?
9 A I think their use of the term was related to the 10 direction by their Supervision to assign an inspection step 11 that the Supervisor had determined was correct and should be 12 signed off; but when the Inspector had some question about, 13 did not understand or was not given an explanation as to why 14 the inspection step should be signed off or was correct.
10 And thereby, they were signing for something they 16 g uere not sure was correct.
I 17
, Q For example, directing an Inspector to check the accept block on a-Weld Procesc Centrol Form where the Inspector did not actucil inspect or find the wcid Ecceptable.7 Would .
20 that be included?
21 A Well, the latter part of your statement I think was 22 general, the nature of the use of the term by the Inspectors i 23 that it was something they had inspected, had a question about e 24 had raised that question with their Supervisor. I 25 g,,,,,,,,,,a ,,
% 4 ,c,,p,m. % ,w,, y,,
,,,,7 3 ,wi,1 EVELYN S. BERGER i
l OFFICIAL COURT REPORTER i
U. S. DISTRICT COURT CH ARLOTTE, N. C.
Gricr - Dircct 131 it I
1 :
and directed the Inspector to sign it off but had not convinced 2 ltheInspectorthatitwasacceptable. ~
l 3 And that does not represent falsification of that Q
4 inspection document?
5 A No. ,
6
. 0 Is that occurrence consistent with policy with -
7
. respect to inspection at Catawba? ,
8 A It is not censistent with our policy at that parti-8 cular time. It is our policy that no one will sign off an 10 inspection step that they are not personally convinced is 11 acceptable.
12 O Was that consistent, that practice consistent, with 10 your policy at any former time?
14 A I really cannot speak to the policy that was in 15 place at Catawba prior to rebruary of 1982. It is generally 10 not consistent of my understanding of the most prudent Quality i
17 Assurance practice.
18 O Did it occur as a matter of custom or practice at -
~
1 Catawbc?
~
20 A I'm not aware of the occurrence except as it relateE 21 tothe concerns of the Welding Inspectors expressed.
9
~2 O Did they express that concern any?
23 A I believe that is documented in some of their 24 concerns that they were directed by their Supervisor to sign 25
_ , _ _ something off that they were not personally --
had not been EYE LYN $. BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTL, N. C.
l l
Grior - Direct 132 j i
i 1
explained to them why the step was acceptable.
2 O Did you understand that it actually occurred?
3 A I read that it did occur in the concerns that were 4
turned in.
5
, 0 Well, those concerns are the same concerns that ,,_
6
. 7.ve seen and we are talking about, the same documents. What- -
I
. I want to understand is not whether they are contained in ,
8 those writings because I think we can accept that they are.
9 I want to understand what you, George Grier, believe r.
10 Did you actually believe that it did occur at Catawba?
11 A I believe that it did; it is based on what the 12 Inspectors wrote.
13 Q Is that consistent with prudent practice in your 14 opinion?
15 A In my opinion 7 16 O And the practice has been changed to clarify that 17 it is not policy at present?
18 A That's correct. -
19 ~
O Do you know whether or not it was policy at any point in the past?
21 A I'm not aware that there has been a policy that 22 allowed that activity of directing someone to sign something
- 3 0
off that they are not personally convinced of.
24 Q Did you ever discuss that subject with Mr. Davison?
25 A van. the nature of discunnions was to be sure we EYCLYN $ BERGER OFFICIAL COURT REPORTER
- u. S. DISTRICT COURT CHARLOTTE, N. C.
Grior - Dircct 133 t ,
I l were clear that that was, that that practice was not acceptable:,
2 and in fact, would not be our policy.
3 O Did you ask him whether he ever instructed a Welding 4
Inspector or through the Welding Inspector's first level 5
. Supervisor, to sign approval that the Welding Inspector had ,.
6
- not personally agreed to?
A We have had some discussions along those lines. .
8 As I recall his feeling is that, and we were discussing the 9
issues that were raised by the Welding Inspectors, not the 10 issue in general, but my understanding of his feeling on this 11 subject is that he felt that any interpretation by an Inspector 12 of what he may have said and what his belief is in regard to 13 what a Supervisor may have said would have been somewhat a 14 misunderstanding or a situation of poor communications between 15 himself and the Incpector.
And, in fact, the Supervicor, Mr. Davison, was II
, convinced that the activity was acceptable and apparently
. 18
- felt that the Inspector agreed with that at that time.
10 0 Did Mr. Davison either admit or deny having 20 instructed an Inspector to approve a piece of work that the 21 Inspector did not agree with?
l 22 A I think Mr. Davison, in understanding the specific l
23 concerns expressed, is generally aware of the specific 24 instances involved; and as I say, describes the situation 1
~ as nna srharm & harm s,m a annavan&1v a hvem1rArywn in r=nmmunication0
~ EVELYN $. BinGER orescia6 C0unt atr0ntra W. S. Di$talCT COURT CH A Rt0 Tit, N. C.
Gricr - Direct 134 t
( 1 l between himself and the Supervisor and/or Inspector.
2 '
Generally Mr. Davison continued to see that the 3
specific direction given was technically correct.
4 Q I guess I don't think that is responsive to the 5
. question. i .
6 A Would you repeat it, please? _'
O Surer did Mr. Davison admit to having instructed an .
Inspector to initial his acceptance of work that the Inspector 9
did not agree with?
10 A I didn't specifically ask him to admit to that one 11 way or the other.-
12 O Did he deny it?
A I didn't ask him to deny it.
14 0 Did he say I didn't do it or it happened that way?
15 What I'm trying to learn is what you icarned from Mr. Davison, 16
! regardless of whether you put it one way or the other?
, A Right, well, the sense of the conversation, I've ,
l already told you the sense of the conversation and the terms i
g .
I admit or deny really were not directly discussed, as I recall. ,
90
~
Q You just. don't know whether he did or didn't do it?
21 You just expressed these senses as you did a moment ago?
l 22 Let me see if I can be a little clearer; I'm not sure you i
I 23 understood what I said.
l 24 I think there is no question in his understanding A
- 5 of t_ha epas484n 4n=6mnn=c_ um 4e numre nr 6hm = pan 474n EvtLYN $, BERGER OFFICIAL COURT REPORitR U. S. DISTRICT COURT CHARLOTTE. N. C.
Grier - Direct its j 1
! instances that are described by the Inspectors and recalled i,
o!
- ! discussions as to the acceptability of those things, recalls 8
that an Inspector was to go accept the situation.
l 4
Generally I believe his recollection is the 5
.. Inspector did not express a concern at that time in regards ,
to the issue.
O So I think generally he was not aware that the .
8 Inspector had the concern that now apparently was in the 9
Inspector's mind; and how about your understanding and use of 10 the terms " pressure to approve faulty workmanship"?
11 A Well, that would be essentially the same as falsifi-12 cation, same sense. As a matter of fact, I think that that is 13 a term that Palmetto Alliance has used in their contention.
14 0 I seem to recall seeing it there, too. Mr. Grier, 15 I'm looking at a memo to file to that. Let me see if I can I
identify it, dated April.27, 1983.
, A Yes, I am familiar with that memo.
- ~
~
O You wretc that memo?
9 -
A Yes.
20 MR. GIBSON: Excuse me, would you put a clear 21 identification in the Record of what that is?
22 MR. GUILD: Sure, let's see if we can identify 23 it. First let's have it the next Exhibit to Mr.
24 Grier's deposition; and this is a memo regarding a 25
" ~
! EvELYN $. BERGER '
l OFFICIAL COURT REPORTER l
U. S. DISTRICT COURT CHARLOTTE. N. C.
l Gricr - Direct 136 I l
i a r 1 I THE WITNESS: That's correct, and Art Allum.
2 (Uhereupon, the document referred to as Memo {
3 to File dated 4/27/83 was mW ked and received by the J
4 Court Reporter as Grier Exhibit One and entered into 5
the Record.) x 6 ,
7
. BY MR. GUILD: .
8 Q Mr. Allum was then Mr. Ross' Supervisor?
A That's correct.
10 Q On the second page with regard to the terms that 11 we have just been discussing, "We need to be clear on the 12 aignificance on those concerns and in particular will have to 13 be clear en the meaning of terms like ' intimidation', threats, '
14 ofalsification' and ' pressure to approve faulty workmanship.'
15 These are words that are used in the concerns and could be i 16 used to describe very extrene circumstances."
17 And what I am trying to understand, Mr. Grier, is 18 ;
what you think should be intended, what you think those terms I '
4 should be understood- to mean both in your mind and the way 20 l those terns were used by the Welding Inspectors; and that in i 21 what you have been telling me?
A That's correct.
"3 Q The last of those terms " pressure to approve faulty 24 workmanship," that is a term used in Palmetto? Alliance's '
25 -,.s.
ee.e... . .s. ..s....- ms... 4. ,.-..,4.
EvtLvm S. BERotR -
O*FICIAL COURT REPORTER U. S. DISTRICT COURT CHARLOTTE. M. C.
, .,. - , _ , . . . . . . _ .~. . . .
Grior - Direct 137 l
l 1
l concerns expressed by Welding Inspectors.
1 1
2 A Well, I think that I probably picked that term out 3
as a phrase used in the Palmetto Alliance contention rather 4
than Welding Inspector concerns.
I wrote that memo without benefit of going through ,
the concerns or the Palmetto Alliance contentions but I was -
. recalling some terms that are used. ,
8 O And you were discussing the subject with Mr. Ross?
9 A That's correct.
10 0 What was the tenor of your discussion when you inikod 11 about the term, the phrase " pressure to approve faulty work-1 manship"? What did you sayr do you want to look at the memo?
13 A Sure, I wrote the memorandum following my discussion 14 with Mr. Ross, and that list was a list of terms, the sense of 15 which I was discussing with Mr. Ross. I really am not sure I 16 cpecifically used the phrase " pressure to approve faulty I
workr.anship," in my discussions with Mr. Ross.
l8 But thct discussion with him was to discuss the -
~
issue of using terma, that of using terms without properly 20 defining those terms.
O Such as the terms you have just defined here?
22 A Yes.
23 Q Well, the introduction to that memo, this parti-24 cular portion of the memo was in anticipation of the hearings.
25 ,,4,, ,
~
73, 3,,, ,,,3,4,,, ,, , , , , , ,,, ,, ,,,34, ,,,3, ,,,1g EvtLvm S. BERotR' OFFICIAL COURT REPORTER U. S. DiStp:CT COURT CH ARLOTTE. h. C.
) a
- +-
G;;iot'- Direct -
138 i
1 be to put the terms expressed by Welding Inspectors in perspec-
~
~
2 tive because the Intervene.rs would be characterizing those 3v concerns in the worst possible light.
4 "We need to be clear on the significance of those 5
, concerns, and in particular will have to be clear on th'e meaning 6
of terms like . . . " and ther. you go on.
- I '
- A Tpat'sright. ,
8 ^
Q And you were addressing the subject o" how to 0
respond to Palmetbo Alliance's Quality Assurance contention?.
10 A g hotspecifically,no;Iwasdiscussingwithhimthe 11 importance of being' clear on the definition of_ terms that have 12 or can have some significant meaning in the mi os of various 13 i
}
individuals that sco'those terms used in other arenas..l J 14 0 Yes, but it was in the contention of responding to 15 Palmetto Allianceh concerns reflected >in our contention, t
16 l questions about the adequacy of Quality Assurance at Catawba. '
17 I
, wasn't the nature of your discussion?
18 g y,m not sure what you mean by "in the nature of
- 19 -
responding to our contention."
Q I want you to tell me what you talked about with 21 l Mr. Ross that is the subject of this line of questioning, and i 22 when I read my words on a piece of paper to mean what they 23 say again, it is a question of defining terms; and when you 24 say ' bur big task would be to put the concerns expressed by We1M4nn Tnenar+nem 4n&n ar# mnm e+ 4 sem _ p van .. + m 11e 4 nn ahnnt EvtLv5 S. Breece 0FFICIAL Count ALPORTER U. S. OtSTRICT COURT CM ARLOTTE, M. C.
Grict - Dircct 139 l
, i 1' in the contention of a hearing where Palmetto raised those 2 questions.
3 A Okay, I was somehow on the track of responding to 4
interrogatories. The discussion was along the lines of being 5
, 'sure that all of us that might be involved in the hearing ,
6
. process are careful to define the terms such as those that we- -
7
- use in our discussions in regard to the contention. ,
8 Those discussions might take place in preparation for hearings, they possibly might take place with media 10 representatives; but that was the nature of my discussion, to 11 nake sure the terms are defined and when they are to be used.
12 O All right, did you discuss Mr. Ross' participation 13 in the hearings?
14 A I may have reiterated to him what was already, what 15 had ciready boon told to him; that he might, in fact, play a 16 l role in the henringa cither in deposition or in the nature of i
17 ! some testimony at the hearings.
18 This had been communicated to him previously.
- 19 0 1That did you ca.y thout the cucction of testinony? .
20 A The only thing I would have said was what I just 21 said. He as well as many others riight be involved in testi-22 mony or deposition.
23 0 Did you talk to him about whether he would testify?
A Ho.
25 O Did you nrk him whei har ha tmn1M + mat li'y?
EVELYN $. BERGER OFFICI AL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE. N C.
Grior - Direct 140 l
r 1 A No.
O Did you talk to him about cooperation with Palmetto 3
Alliance or other Intervenors? l l
A I don't believe I talked to him at that time. He
, had been in more than one meeting at which we have laid out ,
our instructions to Supervisors and to individuals in regard 7
- to cooperation with Intervanors. ,
4 Q Had you talked to him about that subject?
9 A I have been at meetings at which I' e' addressed 10 Supervision, and he had been in those meetings.
11 Q When were those?
12 A I'm not sure of the exact dates. We had some 13 meetings in late April I believe on site where I know we 14 spoke to the Inspectors and Supervisors about that issue.
15 O Did you speak to the Inspectors and Supervisors 16 together?
A Ua had at least one meeting.with Supervisors, and
~
18 then had each employee in QA at Catawba come in in groups and
- not with them; their Supervisors were with them, I believe.
20 Q When was the meeting with just the Supervisors?
21 A I'n not sure, I would expect that it would have beer 22 in March, March, April.
23 0 Do you recall a meeting at which Mr. McGarry was 24 l
present, Mr. Carr was present?
25 ,
" ~~'
EVELYN S. BERetR OFFICIAL COURT RtPORTER
[ U. S. DISTheCT COURT
Crier - Direct 141 I
1 1[ O And you?
f 2[ F A Yes.
3 O And you addressed all of the QA people about Catawba 4 in groups?
5 A
, That's correct.
6
- 0 was the meeting with Supervision before or after 7
- that? .
8 A Before that. .
D 0 And who was present at the meeting with Supervision?
10 A Well, I was present at at least one of the meetings, 11 cnd I'm not sure -- I don't believe anyone from the Legal 12 Department was present at that meeting. I may be wrong, but I 13 just don't recall.
14 O So who in Supervision was in attendance?
15 A All Supervisors in Quality Accurance at Cataubt.
I j 16 l 0 How many Supervisors would that be?
17 ;
A
, Twenty.
. 18
- O And Mr. Rocs was at that meeting, too?
10 A Yoc.
20 0 1-Thtt wac discussed at that meeting that wac i
j 21 different in any substance from the subjects discussed at the 22 meeting with all OA people?
- j 23 A Essentially nothing. 'I believe at that meeting we 24 explained to the Supervisors that each person in'Ouality 25 Assurance would be receivina' a letter that would indicate that EvtLYN S. St#0ER OFFICIAL COURT REPORTER U. S. DesTRtCT COURT CHARLOTTE. N. C.
4 Gr!er - Direct 242 l l
11 their nece, address and telephone number an:' that sert of l t
2 data had been released to the Interveners and read the letter 3 to them and gave them an opportunity to discuss any questions 4
I they might have about that issue.
5 ! I think at the same meeting, that was where we 6 i discussed the Supervisors t o bring forward or get out of their 7
files any notes or documentation they might have regarding ,
8 concerns or disagreements between Inspectors or Supervisors or 8
Management.
10 0 That letter went out over your signature, Mr. Griert 11 A That's correct.
12 O To all present and former QA Supervisors at Catawbat 13 A That's (orrect.
14 O Did you write that letter?
15 A That wan drafted in the Legal Department, I believe.
16 i O Who drafted it?
t 17
, A I'm not sure, I think Mr. Al Carr may have drafted
- 10 , that letter. *
. l' .
18 O Did you get"any response to that letter from any of 20 the recipients?
21 A Mell, I recall receiving a telephone call from a 22 former employce, !!r. Edwards, who was wondering why he had 23 receiveu the letter and what the issue ~was and some explanatior 24 of what had been turned over.
25 Actually there was annthne lattav that indientsd EvtLva S. BERctR OrreCIAL COURT REPORTER U. S. DISTRICT COURT CW4RLOTTE, M C.
Grier - Direct 143 2 __
1 i that sece docum$ntt.tice with thr.t persont name had actually 2
been turned over. r
! t '.id. threre were two separate letters ,
3 i one dealing with the 'act thet telephone numbers had been 4
released, and then another for specific individuals who were 5
. named in documents that had been turned over. ,
6
- Q For lir. Edwards it was the document? ,
A Yeah, I believe that was an exit interview that .
8 had been turned over in discovery.
8 0 All right, did Mr. Ross ask any questions about 10 participation in the hearings or related process?
11
, A I don't recall any specific questions from Mr. Ross.
I Q Nothing at all?
13 A I know he has asked his Supervision on site some 14 questions. I don't recall him asking me any specific questions ..
15 0 Who has he csked?
16
, A I believe he hn:: hcd discuscions or had questionc 17
, that related to those matters with Mr. Allum, !!r. Willis , ,
6 Mr. Davison. '
19 O IIow do you understand that?
20 A From reports frcm tir. Davison to me.
~1 0 What doea Mr. Davison report to you?
"2 l A He was just keeping me advised of what the nature l
23 of what Mr. Ross had reported, that being that, in fact, there 24 had been some contact between Palmetto Alliance and himself, 25 gnggygg,,3, 4 3,, , 4 ,,4 , ,, ,,3,,,, , 3 ,,, ,, g,4,,, ,4,3 ,3 3, _ ,,,
EvrtyN S. Brnotn 0FFICIAL court ntPORTER i U, S. DISTRICT COURT l
CH ARLOTTE. M C.
' der - Dir:ct 144 6
i 1k h. acif, members of the media and himscif s as well as some n ,
l :is pectors .
3
. O Inspectors contacting him?
4 A As well as those individuals I've just named 5
3 . j contacting Inspectors, and those Inspectors reporting then to I
6 l '
Mr. Ross. ,
, O And how did Mr. Davison communicate or report these ,
0 'i contacts to you)
)
8 A verbally. .
10 Q Did you document that?
II
, A No, I don't believe so.
12 O Did Mr. Davison document that?
13 A I don't know, but I don't think he did.
14 Q Why not?
A Well, it is just a matter of getting a report of 16 that contact to be something significant to doeur.cnt.
17
, 0 chry,:h:t tre the disgr=== that you have reference
- 18
- to, Mr. Grier, in your mcmo regcrding your meeting with Mr.
I Rocs?
20 A Those were just some discussions that I drew on a 21 chalk board in the process of some discussions with Beau.
- O What were they?
23 A As I recall it was just a horizontal line that I 24 drew to aid the discussion to help Beau visualize what I was 25 talkine ahnne- and +ba knvi*no*ai 14na van *===n+=d enn e + rnnti ne -
EvtLYN $. B(RGER OffsCIAL COURT REPORTER U. S Dis 7RICT COURT CMARLOTTE. N. C.
Crie.: - Direct 145 I
1 [! well, the quality of conctruction work. l l
[ One end of the line would be work that was deficienk 3
l to the extent that it would, in fact, fail in service and 4
result in danger to the safety and health of the public.
5
- The other end of the line was absolutely perfect ,
work with no discernable defects. And I explained to Mr. ,"
Ross that somewhere on that line would be the point at which .
8 I the workmanship would be acceptable to the Design Criteria, 9
that that point would not be at the end that represented 10 workmanship that had no discernable defects, and that somewhere 11 between the line, the mark on that line that represented work 12 acceptable to Design specifications, between that point and 13 perfect workmanship would be the point where we had set our 14 specifications as meeting the Quality Assurance requirements.
15 That was an aid to make sure that I was communicat-16 !
I ing well uith Mr. Ross. I feel like he was well aware of what 17 A I was discussing, but that that diagram helped us both mako ,
sure that we were properly communicating and the discussion 19 I -
centered around the fact that there were defects or deficiencies .
20 that would fall between our acceptable standcrd and the Design 21 Specification Requirements, and those might be justified.
22 Likewise, there were defects that fell between the 23 l perfect workmanship and of the line and the point where work-man" U- would be acceptable to our standards; and because our 25
=ter.derdearewrittenin,y,g,4fgggg,jer;_ubj;;tt; int:rpretat-c?_ , i 0F8tCIAL Count REPORTER U. S OllfAiCT COURT CH ARLOTTE N. C.
Grier - Dircet 146
- h. :
1 there is a gray area around that point on the line, and some i
2 I things that sorce Inspector might interpret as not sceting our 3 requirementa, and, in fact, would.
4 So that was that line as just an aid in our dis-5 lcussions. ,
l 6 If you would reproduce that line for me, Mr. Grier? -
. O 7
. (h"nereupon, the k'itness drew a diagram as ,
8 requented by Counsel.)
9 10 gy gg, gg7tp, 11 0 All right, sir, if you can pacs that across the 12 tabic.
13 MR. GIDSON: Can we mark that as Exhibit Two, 14 Mr. Guild?
15
!!R. GUILD: Yes, let's do.
16 (Phercupon, the document referred to ac 17
, Diagree by Mr. Grier was marked and received by
- 18 the Court Reporter as Grier Er.hibit Two and entered
- 19 into the Eccord.)
l .
20 21 BY MR. GUILD:
22 O hll right, sir, now the point between the points on 23 the line that you have labeled meets Design s'>ecifications and i
24 OA acceptanco standard; is that the point where judgment would 25 permit the accentance of an item falline 3ess 'than OA acceptante EVELYN $. B(RGER OFFICIAL COURT R(PORTER U. 5. DISTRICT court CH ARLOTTE. A. C.
f
Gricr - Direct 147 i !
3 i standards? j 2
l A That is correct judgnent, that is the area where a 1
3 judgment by the appropriate individuals could result in 4
acceptance.
5
. 0 All right, judgment by the Inspector? ,
6 g go, .
O Judgment by whom? ,
8 A That would generally be judgment by the Design 9
Engineering Personnel.
10 Q Judgment by the Design Engineer, say in the example 11 used earlier this morning on the Inspection Team?
12 A Yes.
13 O How about Engineering judgment beyond that of the 14 Design Engineer on the Inspection Team to accept something 15 that is otherwise not up to GA Acceptance Standards?
16 A There are situations I can imagine uhcre the
. Design specification is very clear in the requirements, and for some reason the Oh Acceptance Standard ic more stringent
- han chat.
l .
"O If it is very clear that perhaps soneone in Quality 21 Assurance or the Technical support, Quality Assurance Technical l Support organization might accept something that falls in 23 between those criteria.
24 0 And where on this contiuum do you consider Mr. Ross 1
95
~
ghnnld ba tha 'n m v e en the Tnnpactnen8 ave-efna of judorent?
EvtLYN $. BERGER ofreciaL count acronita
- u. s. oistnict count cwAntotit. N. C.
i
_ Grier Ii.m._e_ 148
! l 1' 1. L the crea juct around this hypothetica? peint on 2' this line t!.:t gives the level of quality that is pointed out 3 That it not, in fact, a sharp
, on our OA Acceptance Standard.
4 l point on a line, or, in fact, a sharp definition.
i 5
Those OA Acceptance Standardc are generally words '
l 6
. that are written and have to be set out against individual -
7
. Itangers, individual uelds that have scme differences. ,
8 0 All right, in your memo to file you say "I explained 9
that one of his tasks," again, Mr. Ross as a Supervisor, "is 10 to use his judgment to ansuor employcos' questions in such r.
U way that we will not exceed standards to a great degree."
12 Again, with reference to this diagram if it in 13 uneful, how do you mean that observation?
14 A Well, just as I said, not to interpret, not to allow 15 an Inspector to reject neceptance criteria much above the OA 16 l Acceptanco Standarde, thereby rejecting work that, in fact, 17 should not be rejected.
18 0 Why not? -
19 ~
A Ucll, it is nocdicss to reject work that is, in 20 fact, acceptabic. It requires time and attention to correct something that doca not need correcting.
22 O Dut why not better than simply acceptabic?
l 23
( A There is no necessity to produce work that is i
l 24 better than acceptable.
25 n , 1,n n f- r mic1 err vl e t. Mr. crfcr?
~ "
l EVELYN $. BERGER OFFICIAL COURT REPORTER U. S. DISTRtCT court CH ARLOTTE. N. C.
1 Crior - Dirce- 14P l
1
- . I 1)
A r; . c i- : ; :r - '_ - t .
2 O Were there er.y other diagrams that you used in this 3 l discussion with Mr. Roas?
I 4 I A No, I believe that is the diagram here.
t 5
, 0 That is the diagram you had reference,to in the j 6
- discussions reflected on the first page, which is the second 7
topic, Workmanship and also the diagram that,you have .
8 reference to on your left area, which is in regard to the 9
hearings?
10 A That's right, the same sense of degree of defini-11 tions that is laid out on that diagram.
12 Q " Beau did express a desire to make a change.and is 13 particularly interested in going into operations QA." What 14 kind of change?
15 A Hell, he expressed to ne that he would be interested 16 in a Supervisory position in the operctions Quality Assurance 17
, area. I belicyc he was speaking of the group at Catawha, the
- 10 Operations Q7. Grcup at Catawba.
- Q I.nd is that the transfer of Construction OA to 20 Operations, something that is generally pending at this time?
21 A We are in the process of staffing the Operations 22 QA Group at Catewha now.
23 Q And you are seiceting individuals to make that 24 transfer?
25 y, g,,,
_ 3 , ,, 3 ,, ,,g g _ % ,, g,4 g,, g , , , , , %,, _ , ,
EVELYN $. BERG (R l OFFICIAL court REPORTER i
U. S. DISTRICT COURT
[ CH ARLOTTE. N. C.
Grior - Dircct ISO ,
i i 1 !cft to celect.
2 O Imd who of the individuals who de not transfer from 3 Construction QA to Operations, what work will be for them?
i I
4 , A Well, we expect that we are going to have to 5 expand our staff generally in Operations OA Division to take l
6 care of the In-Service Inspection work, as we have seven -
7 Nuclear Plants operating interfaced with the prospect undoubtedly, 8 of having at least one of those units down for refueling 8 outage continually at some point in time.
One will always be down, we expect to have so=c 11 expansion in that area. We expect to have come Nuclear 12 construction work beginning and will need to staff and 13 supervise Inspectors in those areas.
14 We intend to have Quality Assurance and Quality 15 Control functions at those ncn-nuclear construction facilities.
16 In addition there are studies going en in regards to upgrading 17 both fossil and nucicar stations for major work activities.
. 18 There we likely will have some Quality Assurance -
19 function or activity. We are perforcing for ther departmentt "O
of the Company, Inspcotions , Ucn-Destructivo "xaminations ,
21 that have in the pact been given to outside agencies.
22 We crpect that role to expand; and lastly, we are 23 intercated in contacts with~ companies outside Duke Power 24 Company to utill:e personnel so there are a number of areas 25 where we expret to be able to use certain1v the Sunervisors l EY(LYN $, S(RG(R
! OmCIAL COURT R(PORT (R I U. S. DISTRICT COURT CHARLOTT(. M. C.
Grior - Dircet 151 I i ,
,~ !
l and hopefully a large number of the Inspectors that are t
2 currently at Catawba.
3 O Do you anticipate the need to lay off QC Personnel 4
upon completion of Catawba?
. A Yes. ,
O Do you know how many people you are going to need ,
to lay off? .
8 A I don't know at this time, it depends on the 9
studies in the areas that I have described.
10 0 Have you selected the Supervisory Personnel who 11 will make the transfer for Operations?
12 A Not totally.
13 O Have you selected amongst the Supervising Technicians 14 now at Catawba, persons who would be transferred to Operations 15 QA?
16 l A No, we have not made an investigation. We have not 17
, gone through a process of selecting any of those individuals to go or not to go.
19 O Have any of those individuals applied for transfer?
20 A We do not have a process by which a Supervisor 21 would apply for a transfer from one division of OA to another 22 and remain in essentially the same job.
i 23 I
The selections for Supervision are made by Manage-24 ment.
, A.
T 7 at . Anne nna if ene 4e 4n&cwne&c/
- ~ ~
' ~
Anme nnn Evttva s.~ ~stacia ~ ~
OFFtCIAL COURT REPORTER U. S. DisTRtCT court CHARLOTTE, N C.
Grior - Dir:ct 152
/ 1 lexpressaninterest? l 2j A Yes, it is perfectly acceptable for someone to 3 express an interest, but that is not really a factor in the 4 selection of a Supervisor. We review ell the qualified 5 candidates, select the most qualified,offerthe position to that s
6 most qualified candidate, and they either accept it or notr .
. 7 and if they don't we go to the next most qualified.
8 O Did you discuss such a transfer with Mr. Ross?
9 A As I noted in my memo, he expressed that to me and 10 I was acknowledging that I understood that he was interested 11 in that, but certainly nade no commitments or remark to 12 indicate I will expect that.
13 I reiterated to him what he already knew, that I 14 heard his interest and the selection process would be such as 15 I have just stated.
16 0 You did not communicate any view as to his 17 candidacy for a transfer?
. 18 A No. .
19 0 What van the circumstance of Mr. Ross ' meetina with
- 20 you on April 27, Mr. Grier?
21 A I was aware that he was concerned with the 22 Performance Evaluation that he had received, and since I had 23 been involved in approving that Performance Evaluation and l
! 24 since I am interested in him and his Suoervisory potential as I l l l
! 25 well as the other Suoervisors, I told Mr. Davison if Mr. Ross .
Evrtyn S. BtRate OrFICIAL COURT REPORTER
- u. S. Disf RICT COURT CHARLOTTE. N C.
Grier - Dir:ct 133 l
l l
( 1
' ~
felt it uculd be helpful to meet with me and discuss the o
situation, that I would be gl'ad to do that; and Mr. Ross 3
indicated he would like to do that and we had the meeting.
4 0 What step was this in Mr. Ross' Recourse?
5
. A Well, this occurred during the total. Step one as ,
6 had been discussed with Ms. Addis. This was Step ~0ne with him, internal within the Quality Assurance Department. .
8 O There is also a Step Two and a Stcp Three?
9 A Step One is within the Department. Step Two is 10 with the Corporate Personnel and Step Three is with the 11 P7esident. Within the Quality Assurance Department there are 12 cueps that a person goes through befcre they exhaust the 13 S?.ep One Departmental Recourse.
14 In fact, there is a new procedure that takes the 15 l Place or the Recource Procedure that Ms. Addis referred to, i
16 end that is to try to resolve recourses within the department 17
, and provides for a number of steps within the Department.
- 1
- It dcac not take the place, it explains the Step 19 I One Phase within the Qut.lity Assuranco Depart: tent.
9
~0 Q Ulthin the Departmant what step are you?
21 A I am the last stop.
22 O Step Threc7 23 A Well, it depends on how many Supervisors an 24 individual has, but I'm the last step.
25 Allum n . . _ re cc 1,.. e t .e , 54, <... . .4c ._ t.
EVELYN $. BERGER OFFICIAL court REPORTER W, S. OtSTRICT COURT CHARLOTTE,N. C.
Grier - Direct 154
/' I and then Mr. Allum's Supervisor, Mr. Willie; is that right?
2 i 7. That's correct.
l 3' You are the third step beyond that, are you not, or O
4 Mr. Davison la beyond Mr. Willis and you are beyond Mr.
5
, Davison? ,
6
. A That's correct. '
7 Q Before Mr. Davison res olved Step Three, Mr. Ross ,
8 was meeting with you and you are Step Four.
O A I believe my meeting occurred before Mr. Davison 10 in it occurred before Mr. Davison submitted his answer to 11 g7, 3033, y,m not sure whether Mr. Ross had submitted his 12 Recourse Letter or not to Mr. Davison before or after I met 13 with him.
14 0 I guess my question is it seems to me on its face 15 that you did some leap-frogging in there. You agreed to meet 16 l with Mr. Rocs and did ncet with him and discucced the 17 ~
, substance of his concerns before tha persen who ic next below
, 18 you in the chain had completed his Resolution of the Recourse.
- 19 .
A That'c correct.
9
- 0 O hhy is that?
21 A In this particular cacc the Recourse concerned 22 Mr. Ross' performance evaluatien, and I, in fact, approved 23 that performance evaluation. He know that I had approved it, 24 and therefore, I was, in fact, involved in the case.
l 25 7, ty y ,,, ,, 4, T kna one knen inenivaa ana ehorefcee l
EVELYN S. BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CHARLOTTE. M. C.
i l
l Gric r -
- n. 155 l
~
i l l r 1 was becoming ! nyc; '-d for tne fi;est time. That was my 2
reasoning as to it being prefer in this instance to have this 3
meeting.
4 I also was very interest.ed that Mr. Ross understand 5
. his recent performance icvel and not be polarized by the over ,
6
- all annual performance rating that he had been given in rela-tion to his recent performance; and thereby become confused ,
8 as to whether his recent performance vns at a lower level or 9
exactly what level that recent performance was.
10 0 Uhat icvel was it?
11 A I believe his performance was discussed with him 1
in April of uhis year, late April or early ?!ay, I believe it 13 in late April; and for sorae nunber of months preceding his 14 performance, his annual performance revieu, his performance 15 was satisfactory; or rather let m put it in terms of the 16 levels we une in our perfornance, hic perfornance was corpotone.
17
. O Is !!r. Ross in any danger of adverse personnel l
- 18
- action because of hin performance?
~
A linclutely not.
20 0 Any dangor of loss of his supervisory po.:iticn' as 21 a result of hia perfornance?
22 75 l'o .
23 0 That in not the opinion that his immediate Super-24 visor who performed his evaluation, Mr. Allum, held; is it?
25 ,,_,,,UW, 3 ,.3 , , y. - , 3 3 ,r , _,,, ,* k n l e' anv different EvtLYN $. BIRotR f 0FFICIAL COURT REPORTER u S. C STRICT COURT l CH ARLOTTE, N C.
Grier - Direct 156 1
i 1
opinien.
2 O You are not?
3 'l A No.
I 41 O You are not aware of Mr. Allum expressing the view i
5
, if Mr. Ross' performance did not improve he would not be suiteyl 6
- for continuing Supervisory responsibility? -
- 7 A I believe Mr. Allum would be speaking about a ,
8 period of time some number of months ago, in fact, a period 0
of time likely around April, May, June of 1982 and not the 10 current period of timer and that is what I was very interested 11 in that Mr. Ross understand that his performance in recent I
months was competent.
13 0 You understood, didn't you, that Mr. Allum expressetl 14 the contrary position as recently as January of 19837 A I am not sure I amaaware of that.
O You are aware of the complaint that Mr. Ross had 17
, concerning Mr. Allum's treatment of him?
A I am aware of the nature >f his Recourse.
- 10 O And that it related to conduct by Mr. Allum?
20 A As I understood it, it related to the miscommunica-l 21 tions with Mr. Allum, yes.
22 O Were you aware of complaints of anyone, including 23 Mr. Ross, of Mr. Allum's lack of qualifications to perform 24 his Supervisory job?
25 T nan'+ apacifiem11y reen11.a complaint of that nat ure.
A EvtLYN $. BERGER OFFICIAL court REPORTER U. S. DISTRICT court CH ARLOTTE, N. C.
Grior - Direct 157 1 Q well, aside from, you know, name, date, time and 2 specifics, are you aware of any complaint made concerning 3 Mr. Allum's qualifications?
4 A I really cannot bring to mind --
5 0 The answer is no?
6 A No, I am not aware of any. -
i .
. 7 Q Mr. Allum is no longer Mr. Ross' Supervisor?
8 A That's correct.
9 Q Why not?
l 10 A Again, this centers around availability of Superviston 11 for McGuire. Recently a second level divisional NDE Supervisor i 12 became available from McGuire. We moved the Supervisor to 13 Catawba and rearranged the reporting relationships in that 14 area.
l 15 O Is that Mr. Bulgin?
! 16 A Yes, that is correct.
l 17 Q Is Mr. Bulgin more qualified for that position than
. 18 Mr. Allum? -
19 A No, I wouldn't say so.
20 0 Equal qualifications?
l 21 A Yes.
22 O How about from Supervising visual inspections?
23 A I would say they are both well cpalified. Mr. Bulgin 24 has a background that is more oriented for the visual inspections 25 than Mr. Allum. Mr. Allum is more oriented toward Non-Destructive EVELYN $. BERGER OFFsciAL COURT REPORTER U. S. Disf RICT COURT CHARLOTTE. M. C.
Grior - Dirset 158 i
1i examination. Mr. Bulgin, was, in fact, a Welding Craftsman 2 at a point in time and was a Welding Inspector, a first level 1
3 i Welding Inspector Supervisor prior to being promoted to a i
4 second level Supervisory position. l 1
5 0 Is Mr. Bulgin more qualified to rapervise visual 6 inspections of welds than Mr. Allum? .
. 7 A Well, they are both qualified to do it. I've stated 8 the background Mr. Bulgin has. He is more oriented toward 9 visual inspections.
10 0 What I am asking, they are both well qualified.
11 I want you to compare the two, and if you have to compare, 12 and sometimes you have to do that, is Mr. Bulgin more qualified 13 to perform that Supervisory function than Mr. Allum?
14 A Let me answer it this way: If I had two areas to 15 Supervise, one visual inspections and non-destructive examina-16 tion, I would put Mr. Bulgin over visual inspection and 17 Mr. Allum in non-destructive examination area.
. 18 That would be my preference. Both are well qualifi<ed .
19 for both.
~
~
20 0 Are you aware of concerns by Welding Inspectors that 21 Supervision does not have adequate experience in supervising.
22 the visual inspections of Welding?.
23 A I believe concerns of that nature were expressed 24 in the written concerns used by the Welding Inspectors. That n, 25 and I have those documents, too.
a recourse EVELYN $. BERCER OFFICIAL COURT REPORTER u, S. DISTRICT COURT CHARLOTTE, M C.
Crior - Dircet 159 i ,
l t l
l '
1 But are you aware of that?
O l
2 A Yes, as I say, out of those written concerns there
~
l 3 is a concern of that nature expressed. I cannot specifically 4 quote which concern.
5
. 0 I am not asking you to, but the answer is yes, ,
- 6 you are aware of that concern being expressed? -
. 7 y,,,
3 .
8 Are you aware of the cencern expressed that those O
0 whose experience was limited to NDE who have less qualifica-10 tions to supervise the visual inspections of welds than those 11 with either experience in visual inspection or experience in 12 actual welding?
13 A I really have not heard the concern expressed that 14 y,y, 15 0 nave you heard that substance of concern, that 16 concern in cubstance, laying acide the specific vay I phrased 17 it or the words I used, Mr. Grier?
. 18 A What I recall is that concern was expressed about
- 19 Mr. Bulgin, who happano to be more 6riented toward NDE,.so I 20 really have not made that connection. I really had thought 21 the connection was just to the person and not particularly 22 towards the orientation towards~NDE or visual, but I suspect 23 that could be the nature of the concern.
24 O How was Mr. Ross' Recourse resolved?
l 25 A An answer to his letter that he presented to EvtLYN S. BEnGin l omCiaL Count neronfan U. S. oisintCT court l CManLoTTE. M. C.
(
Grier - Direct 100 1 :
1 Mr. Davison was given to him. I believe Mr. Davison discussed 2
- it with him and that was the resolution to his Recourse.
3 i
! O And the terms of that resolution are fully reflected 4
in the correspondence that has been provided?
. A That's correct.
Q Did you consult with any higher Management in ,'
. 7 reviewing Mr. Ross' Recourse or the resolution of that Recourse?.
8 A No, I made Mr. Owen aware that Mr. Ross had initiated 9
the Recourse process, but I did not discuss the resolution of 10 it with Mr. Owen.
11 Q Any other Management?
12 A Ho.
13 0 You supplied Mr. Owen with copies of your memo to 14 file concerning your meeting with Mr. Ross?
15 A Yes, I did.
16 i O All right, did he also receive copies of other l
17
. documentation regarding Mr. Ross' Recourse?
A I don't believe so.
- 19 ~
, O As far as you know this was the only thing that ,
20 he received?
21 A That was the only communication in writing.
22 Q Did you talk to him about it? .
23 A As I stated, I informed Mr. Owen that he had 24 initiated the Recourse process.
25 , ,,, ___ ,_,___ ,_ _ __ , _ _ __ _,___ ,_ _,
. --- -...v-2-- g,.it%"s."81 Rot R """" ^" '"'"
0FFICIAL court REPORTER i
- u. S. DISTRICT COURT CwaRt0Ttt, w c.
)
i
Grier - Direct 163
=
6
+
l 1 . process, meeting witr. hin be* fond the matter that is copied 2 '
here?
I 3 A I think the memo was my communication with hin that j
i 4
l I had met with Mr. Ross.
5 I What did Mr. Owen say to you when you told him that
. O 6 -
. Mr. Ross had filed a Recourse?
. 7 A I don't recall specifically, I think the nature was ,
8 just some acknowledgement, and his instructions to be sure 9
we handled it correctly, some statement of that nature.
10 0 l'.r. Ross complained that his personnel evaluatior.
11 and other treatment by Allum,, his Supervisor, was retalitory 12 for his having expressed concerns, both technical and non-13 technical, regarding Welding Inspections at Catawba; is that 14 right?
15 A I believe that is the sense of some of the statements 16 in his Recourse, not ctatementc, I got that scnce from his 17 Recourse.
. 18 And did you investigate that complaint?
O -
~
19 A Well, an ! say, I was involved in the evaluation 20 process for Mr. Ross, and I'm involve'd in the evaluation 21 process for all Supervisors at that level; so I was well aware 22 that, in fact, the evaluation was based on his attributes as a 1
23 Supervisor, and in no way was the evaluation retalitory.
24 l 0 Your action was not retalitory; correct?
25 'The answer centered around his perfomance evaluation.
A EVELYN $. BERGER OFFICI AL COURT REPORTim
- u. 5. District COURT CHARLOTTE. N. C.
l Crjer - Dir;ct . 162 i
li Ih Q Let rae see if I can isclate this, Mr. Grier; that P
2 e.
is motive and I will ask you to speak to your own, and I'm 3
asking you whether or not your action , Mr. Grier, was retalitory in response to his having expressed concerns?
A No, it was not. .
6 .
O All right, and do you know whether or not the .
- 7 actions by others, Mr. Allum, and Mr. Davison, were retalitory? -
8 A To the best of my knowledge they were not. The 9
process of evaluation for Mr. Ross was presented to me, and 10 the reasons for the evaluation; and they'seemed correct in 11 the framework of the evaluation process that we have.
12 O And that is the basis for your conclusion about 13 the motives of the other two gentlemen I mentioned?
14 A That's correct.
15 0 All right, sir; the May 11, 1983 letter, memo to 16 l file, from Mr. Davison; you received a copy of it, I believe.
t
. Can you identify that, Mr. Grier (indicating)? ,
A Yes.
19
. O And you did get a. copy of that? ,
20 A That is true.
21 O All right, this reflects the resolution of Mr.
22 Ross' Recourse?
23 l A No, if I scanned it correctly I believe that is a l 24 l document whereby Mr. Davison, well, it is not a letter, it is 25
.____m. ,,2_. t ..m si 2 _--__m_ _ 2 4 _ _. . _ _ 4 .. u_ s.2 .4.x
"" ***~'
i
[V(LYN $, BERGER
( OFFICIAL COURT REPORTER l W. S. DISTRICT COURT CuaRt0TTr. a. C.
l
Gricr - Direct 163 1 !
Mr. Ross to tak Mr. Ross if he, in fact, was satisfied with 2 i the response he had gotten from Mr. Willis; and if not, then 3
he should carry his Recourse to the next step.
4 Q So it reflects the resolution of his Recourse at 5
. the step below Mr. Davison, Mr. Willis? ,
0
- A Well, I think no, it really is a document that indicates that Mr. Davison had a discussion with Mr. Ross and ,
8 said if you are not satisfied, be sure to take it to the next 9
step.
10 0 The memo to file from Mr. Davison, he indicated to 11 me that he felt better about his evaluation after the answer from Joe, that is Mr. Willis?
13 A That's correct.
14 O And subsequent conversations with Joe, Art Al]um 15 and George Grier, that he felt the evaluation was retaliation 16 I tgainst him for aching questions. You understand that such 17
. retaliation is prohibited by Federal law?
- 18 A Yes. *
~
O And on the 12th Mr. Ross to Mr. Davison, after 20 the meeting reflected in that memo,"I think the fact that i 21 seven out of the nine yecra as a Supervisor I have received 22 competent and then I got the worst rating I have ever received.
23 "This should tell me something. This tells me 24 retaliation, pay back and discrimination. This fact coupled
'S with &hm Fac& T'v? ==Am an =# Fart &n he mnve 14 harm 1 in mv EVELYN $, BERGER OFFICIAL COURT REPOR7tR U S. DistRtCT COURT CH ARL0 Tit. M. C.
Grior - Dir ct 164 1
interpretation to avoid conflicts and the fact that nothing 2 i was said during so-called"-- ry copy is poor -- it appears to i
3
- be ' unsatisfactory period, tells me irregardless of what I did 4
I was going to got a bad ratinge 5
. I will skip down, "I feel I.have been unduly ,
" ~
pressured and illegally treated, and I would like to submit _
the above concerns. I feel that my resolution would be a ,
8 transfer to operations Group and a fresh start with Management who hopefully are not already prejudiced against me. I feel
~0 1
this is the case. G. E. Ross, 5/29/83."
11 A Those were responded to by Mr. Davison in his l'~
letter.
13 O Did you recognize whether or not these were valid?
14 A Those were investigated at the stage of Recourse 15 with Mr. Davison.
0
, O The que tion of harrancment and rotaliation?
I I
, A I'm sorry, did you ack a question?
- 18
. 0 Yes, did you invectigate those? *
=
gg .
A No, I didn't invectigate thoact that was the step 20 at which Mr. Davicon did his investi 7ation.
1 O Now, May 26, 1933, is this the concluding response l '
- 2 to Mr. ROss' Recournc?'
~3 A That's correct.
24 O And that is from Mr. Davison?-
_ R ThPF'n entranF_
EvtLvM S. 8tRotR OFFICIAL COURT REPORTER U. S. DISTRICT COURT CHARLOTTE. M. C.
Grier - Direct lES 1 O lad that document reflects the full terms of the I
2 i resolution of Mr. Ross' Recourse?
l 3 A That's correct.
4 0 Have you met with Mr. Ross since the Resolution 5 of his Recourse?
6 A No. -
. 7 O Had you met with Mr. Ross before the meeting that 8 is reflected in your memo to file?
9 A I'm not sure what you mean by " met with," in 10 reference to his Recourse?
11 O Mo, in relation to the concerns that he expressed 12 about Welding Inspection at Catawba and relation to Quality 13 Assurance at Catawba, his work?
14 A I have not had a specific meeting in the matter of 15 the meeting that I documented in my memo with Mr. Ross. It 16 j is my practice to be on site frecuently, and I make it a point i
17 of seeing and meeting, let me say, socing in the work place,
. 18 as many Supervisors as possible. .
19 And I've reen Mr. Ross on a number of occasions
! 20 ahd discussed various topics and discussiens with him.
21 Q !!ow about including his concerns of Welding 22 Inspections?
23 A I have not seen him and specifically discussed with 24 him the concerns that he turned in. We have had general i
25 discussions in reeard to Weldine Inspector concerns , the conduc<:
l _
i EvtLYN $ BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CHARLOTTE, N. C.
i I
Grior - Dircet 166 i !
- i 1 ' of the Oualitv Assurance program in regards to Welding and 2 Welding Inspection at Catawba.
3 MR. GUILD: Okay.
4 MR. GIBSON: Mr. Guild, I believe it is 5 five o' clock. Is there any prospect that in a few 6 more minutes you would finish Mr. Grier? .
- 7 MR. GUILD: Ho, I think not.
8 MR. GIBSON: Let's resume in the morning then.
9 FURTHER THE DEPONENT SAITH NOT.
10 11 (Whereupon the deposition adjourned at five 12 o' clock p.m. to be continued the morning of July 7, 13 1983, at eight o' clock a.m.)
14 15 16 l
17 o
. 18 19 .
20 21 22 23 24 25 EvtLYN $. BERGER OFF4Cl&L COURT REPORTER U. S. DISTRICT COURT CHARLOTTE, M. C.
Grier - Dire ct 167 t
1h (The depecitien of Mr. George Grier was t '
2~ reconvened at 6:20 a.m. on July 7, 1983, and the 3 following proceedings were hads) 4 5 BY MR. GUILD:
6 0 Good morning, Mr. Grier. .
~
- 7 A Good morning.
8 O Let me show you a document that is dated December 9 20, 1982: and it is a memo to your file (indicating) . Can you 10 identify that?
11 A Yes, there is a handwritte 4 note on the attachment 12 that I am not familiar with. Other than that --
13 MR. GUILD: This was in the form that was 14 presented to me. I understood it was from your 15 files. Counsel, do you have idea where the hand-16 writing conce from?
17 lin. GIBSON: I have no idea.
. 18 ,
19 ny nn, GUILor
- 20 0 Otherwise, with that exception can you deceribe the 21 document, please?
22 A Yes, that is a December 20, 1982, memo to file that 23 I wrote about a meeting that I had with Kim VanDoorn, the NRC 24 Resident Inspector at Catawba, in which we discussed his 25 synopsis of corments concerning the Welding Inspector concerns <
EVELYN $. BERCER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CHARLOTTE, M. C.
GriOr - Dir3ct 168 E
V 1
Q All right, and describe the circumstances of the 2hmeetingswi*.hMr.VanDoorn,plear.e.
3 ! A As I recall Mr. VanDoorn scheduled that meeting with 4
me, said that he was concludinainterviews with the Inspectors 5
. and wanted to come discuss his findings or his conclusions or 6
information that he had gained with those interviews with me; -
. 7 and he scheduled that meeting and he gave me a typed write-up ,
8 of that information that he gained from those interviews. .
8 0 Did he discuss in any more detail the interviews I
that he had?
11 A There was some discussion and I documented that 12 discussion in my memorandum to file.
13 0 What is your understanding of what Mr. VenDoorn 14 had done with respect to the Welding Inspector concerns?
15 A Well, I knou that he had begun well, first,we had 16 kept him apprised as we went through our task force investiga-17
, tion and recommendations and corrective action in implementa-
, 18 tion phase. -
19 4
I Ue had kept him advised of what we were doing.
l .
~0 There ware some meetings that we had on site with Suoervision 21 and Quality Assurance and Welding Inspectors that he sat in on 22 some of these meetings, I am not sure he sat in on all of them.
"3 Around August I believe he started his independent 24 investigation of the task force report recommendations and 25 correctiva a* inn- ana *k=* n Wina nr *4ma T vn w k. nnant Evrtyri S. BERa R
~
OF'ICIAL COURT REPORTER U. S. DISTRICT CCURT CH ARLOTTE, N. C.
1 3 Gri<e - Care:t 169 i i t i I f 1 some period of time with Mr. Bradley going over the task force i
2 j report and filen in regard to that cubject.
3 He independently looked at some, I'm not sure whether i 4 he looked at all, but some of the specific. concerns and 5 determined whether he thought the recommendations made by the 6 task force were adequate recommendations or not. -
- 7 O Let me stop you right there. When you say " looked 8 at some of the specific concerns," what was the source that he 9 relied on, if you know?
10 A We made available to him copies of the handwritten i
11 concerns. In fact, we made available to him Volume One and 12 Volume Two of the Task Force Report which contained, Volume 13 Two contains the facsimile of the handwritten reports.
14 0 Those were the documents he had available to him 15 as far as you know?
16 A Also he had access to the backup files that Mr.
17 Bradley naintained.
. 18 O Do you know what was in there as far as the .
19 reflection of the concerns, the Welding Incpector concerns 20 beyond the tesk force Volunes One and Two?
! 21 A I am not sure I understand your question.
22 O What I'm trying to understand, or to the extent you 23 know, or understand, what Mr. VanDoorn relied on; and if you 24 say that he reviewed some of the concerns, try.to understand 25 what the source document was that he had available to him, and EVELYN $. BERGER OFFICIAL COURT REPORTER U. S. DISTR 4! 00URT CHARLOTTE, N. C.
Grier - Direct 170 l
. l 1
1 if it is Volume One and Two of the task force that helps.
2[ If there is something beyond that we were talking 3 about other materials that you had available.
4 A Mr. VanDoorn also had access to the Hon-Technical 5
Task Force Report and the. concerns that had been classified 6 -
as non-technical. Those are the only documents that I recall'
= 7 that he had access to, and I know that Welding Inspectors had 8
talked to him at the same period of time that they had brought 9
forth the concerns to Duke Management; and I would expect that 10 he had notes of thos conversations.
11 O All right, sir --
12 A There was one other thing that I know he did and tha.t 13 was to interview Welding Inspectors between August and 14 December 20, I don't know exactly when those interviews 15 took place.
16 O Did you understand that Mr. VanDoorn had requested 17
, support or participation from the Nuclear Regulatory Co:rnission
- 18 Office of Investigation?
- 19 I
A Well, during the meeting we had on, I believe the 20 meeting was on December 20, I don't recall any conversation 21 about that type of assistance. I do recall two other things:
22 When he began his investigation in August sometime around that i
23 period of time I recall that he indicated that he possibly l
24 1 would have some assistance in doing the interviews, and those l 25 interviews ponnihty wnisla ha imA. a=+h.
EVELYN $. BC AGER !
OFFICIAL COURT REPORTER l l
U. S. DISTRICT COURT l l CHARLOTTE. M. C. J l
Grier - Direct 171 L
I 1
- I told him that I would like for him to keep me i !
2 '
informed; and as I recall I told him that iftthe interviews were 3 going to be under oath, I would like for our Legal Depart-4 l ment to be aware of that and have any discussions with him l
5
. l they thought was appropriate.
6 -
Dut as it turned out, he never indicated that the ,
7 interviews would be under oath and that he had any assistance ,
8 in 671ng interviews.
8 0 Enen you and he spoke about that assistance and the 10 format for the interviews in August, did you bring that pol.nh 11 to the attention of the Legal Dayartment?
12 A I may have, I don't specifically recall whether I 13 did or not.
14 O Do you remember whether you consulted anyone?
15 Do you know if Mr. VanDoorn consulted with the Legal Department?
16 l A I can't specifically reenll, I feel I probably l
. would have; but I can't specifically remember doing that or
. 18 I am not awarc of anyone else that did.
- 10 Q 11 hen he talked about potential assistance in
. 20 conducting the interviews, did you understand that to reflect 21 poscible participation by the Office of Investigation?
22 A I am not sure I really understood at that time what 23 the Office of Investigation was. As I recall he mentioned 24 that there were Investigators within the Region Two Office, 25
~
and that thnnn nntennnal t-f nh* ha +-h a nnan n = = f a +- f n n in 4-ha EvEdN $ BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CH A A& 3TTE, N. C.
Grier - Dir:ct 172 l
b s i
( 1 !! interviews.
2 l O Did Mr. VanDoorn relate how the decision as to how 3
to proceed would be made?
l 4
A No, he did not.
5
, 0 And did he subsequently, as you requested, inform ,
6 '
you about how he intended to proceed?-
. 7 A I really don't recall a specific conversation with ,
8 him. My recollection is that the interviews proceeded and he 9
did not get back to me and indicate they would be under oath 10 or that he would have any outside assistance.
11 I really don't recall him specifically telling me 12 that he was beginning the interviews.
MR. GIBSON: Mr. Guild, while there is a brief pause here I had Mr. Bell pull from the 15 documents the December 20 nemo which does not have 16 l tmy handwritten comments,-if you would like to mark I
. this as an Exhibit I suggest we use this copy since l Mr. Grier is not familiar with those handwritten -
~
notes.
20 If you want to look at this, this is the 21 document that was in the Document Room.
~
MR. GUIID: It is probably not critical.
23 This is obviously from somebody'else's file, it is 24 not my copy and not my notes, and this was what was 25 ,,g, m.,,,,s3, ,,,,s ,s, ,,,,,,,3, ,,,_ y,; n 4,,_
EvtLYN $ BERGER OFFICI AL COURf REPORTER U. S. DISTRICT COURT CH ARLOTTE N. C.
Grier Direct 173 1
' MR. CBSE Ar you point out, it is not e 1 ,
l 2 l eritical thing. It could be that is the Xerox that 3 has gene through several hands, but in any event, 4 do you want this marked and we will have a copy made?
5 (Whereupon, the document referred to en
, 6 Memo dated December 20 was marked and received by .
7 the Court Reporter as Grier Exhibit Four. ~and 8 entered into the Record.)
9 10 BY MR. GUILD:
11 O In your notec reficcting the December 20 converca-12 tien with Mr. VanDoorn you indicate you talked about Inspectors ;
13 perceiving recrimination for having spoken to the NRC.
14 What did Mr. VanDoorn tell you in that area?
15 A Let ne look at that?
16 0 It is in that cingle-spaced paragraph there 17 (indicating.)
. 18 A As I recall Mr. VanDoorn felt that he was being ,
19 told by some of the Inspectors that if they went to the NRC, -
l 20 that there reight be some negative comments frem their peers 21 in regard to their conversations with NRC; but it was clear to 22 Mr. VanDoorn that that would not deter any of those Inspectors 23 from going to him with information or concerns.
I
! 24 O Look on Page Two of Mr. VanDoorn's typewritten 25 notes of interviews, Mr. Grier. How do you understand the use l EVELYN $. BERGEP OFFICIAL COURT REPORTER U. S.* DISTRICT COURT CHARLOTTE, N. C.
l
Grier - Direct 174 i:
I.! o.' the term "RT and Cavender used, override Inspectors, not to 2i override Inspector call." Do you see that?
3 A Yes, I do. RT would be the abbreviation for 4
Radiography, non-destructive exanination techniques -of 5
. lexaminingwelds;andCavenderisJohnCavender. He is the Level Three ASN, the Certified Level Three Radiographer.
Q Is ASN the American Society of Non-Destructive ,
8 Testing?
9 A Yes.
10 0 And he is the Level Three what?
11 A Level Three Radiographer.
Q Did you understand that comment by the Inspector?
13 A I understood that comment to be speaking of using 14 the Level Three Inspector. Well, let me put it this way:
15 These Inspectors would be talking about some apparent defect i
16 that they would seu visually, and I would take this to mean 17
. that we would use a radiography technique to inspect that weld
- 18 and then use the Level Three Radiographer to determine whether -
that defect was, in fact, rejectable or not.
And if it was found to be acceptable, the perception 21 by the Inspectors is that they were being overriden, or, in 22 f act, told that they were incorrect rather than doing the same 23 thing, I take it, that they are not saying that the radiography 24 and the Level Three should not be used, but rather it shoul'd 25 l
ha ennehad in +a-me af +achnical annan**nca vn+har than EVELYN $. BERGER CFFICIAL COURT REPORTER U. S. DISTRICT COURT CHARLOTTC, N. C.
l l
r.rter - Direcu 175 I N-,
1 i cverriding the Inspectors. ,
2 0 All right, is Mr. Cavender still employed in that l
3 position 7 ,
4 A Yes, he is.
5 And is it consistent with present procedure for a 0
6 weld that is rejected on the basis of a visual inspection to .
- 7 be radicqraphed subsequently?
8 A That is not the normal sequence of activities.
9 l Normally if a weld is rejected visually, that rejectable 10 defect is repaired and then if the weld is to be subject to 11 radiography, the radiography is subsequently done.
12 Is the radiography generally done first and --
Q 15 A No, visual first and then radiography.
14 Is it consistent with present procedure to t'3e Q
15 radiography as a check en visual rejection?
l 16 A It is not incenristent when there is some defect, 17 spptrent defect that is difficult to evaluate, to use various 18 non-destructive testing techniques to further evaluate the ,
19 -
current defcet.
20 would the use of the radiography in that circum-0 21 stance be documented?
22 A Yes, it would.
23 IIow would it be documented?
Q l
j 24 A It would be documented on the process control for 25 that weld.
EVELYN $ BERGER OFFICIAL COURT REPORTER U, S. D.tTRICT COURT CHARLOTTE, N. C.
Grior - Direct 176 I
Q Would it be docunented on the process control if 2 '
the weld did not otherwise call for radiographic examination?
3
, A Yes, it would.
4 O How do ycu understand the comment, the next down, 5
, "still need improvements in the R2 program and resolution 6
feedback." -
A I believe that that comment points to the fact that 8
the revision to the R2 program and NCI program that has been 9
discussed in my deposition and previous depositions was 10 relatively new at that time; and it was a change from the 11 practice that had been going on previously, and there was stil:. l 1~9 some rough cdges to work out as far as the implementation of 13 those changes, and this was a comment by six Inspectors, 14 apparently, that there was a need for improvement, and I 15 think that independently wo, QA !!anagement on site, had seen 16 that there wcc ntill a need to cducate people on the proper 17
, use of the R2 versus HCI program, and that was taking place.
O What was the nature of the rough edges at that time? -
I ~
A Ucil, I think we were still in uhe process of 20 making sure we were communicating well, the concept of uhen 21 to use an NCI, when to use an R2A, when to take care of tho
- 2 documentation and correction of a defect on pracess control.
23 t
'fnat was one aspect. I think the other aspect was 24 l as is stated there, feedback to the Inspectors _as to what 5
beenna n* &hn- km '- k a "mni n+ 4 nn was m rica one on an l EVELYN $, BERGER I
ob1CIAL COURT REPORTER U. S. OtSTRICT COURT CN ARLOTTE, N. C.
Gra : - :a re n t 177 1
P2A in recard te temc defect that they had recorded on en R27..!
2' O Ecv ht*ce these rough edges been emoothed out or :
3 g probleer correrted? l
[
4 !! A With training sessions with Ouality Assurance i.t 5 ;
Supervision end Incpectors and Technical Fupport Personnel
. 6 ! who process n2As, and well, I'm not sure, but Craft Personnel .
7 has been trained in these procedures also.
8 O All right, and the following comments concernef 9 whether R2A vercus NCI is adequate to handle problems.
10 A Right, that was a comment by four Inspectore, 11 apparently. I think the concern there wts the fact that an 12 NCI hos and still does receive nere reduced steps for various 13 programatic- requirements than an R2A does; anG I believe that 14 was tn expression of a view that an NCI receiving those 15 toditional review stcre, fer eranele, reviewing for reportability i
16 lun6er50.55Fcnorivnificcrtecrrectiveaction,eswehcve 17 discursed Uhether cr E2A that 6oes not receive those types of
. 18 I steps would be neequate to handle the type of defects that .
19 they veuld be reccrdirq cn n275.
20 Arcit, I think that points to the fact thtt e.t that 21
~
period of time we still were needing to further educate-22 Incoectore as well as Supervisicn and Construction on the 23 concept of F2As cnd NOIs es we were putting in at the place. .
24 O At the bottom of the page, second to the last 25 courtent, Craft (PUN) is abusing the weighted value system, EVELYN $, OERGIR OFFICIAL COURT REPORTER
- u. S. DISYRICT COURT CHARLOTTE,N. C,
Grier - Direct 17S I i 1
etc. T1rnt who ic PMP?
2i A That would be Powerhouse Mechanics; that is a 1
3 classification in construction.
4 l Q And what did you understand that comment to 5
, represent?
6
. A Well, again, this is a singular comment. I take -
7 that to be a comment by one Inspector that was interviewed.
8 The statement is " Craft Powerhouse Mechanic is abusing the 0
weighted .value system to get a weighted .valu.e credit."
- 10 Weighted value is that commodity that we spoke 11 thout ecrlier. That is a measure of productivity for 12 welding, and I'm not real sure exactly what the meaning of that.
13 g,,
14 Generally it seems to be a comment that somehow the 15 Craft are s*tting up joints that they sr.y are mirlocated. I i
16 l would tche that to mean that they would have to redo in order I
to get further production credit. It'seems to be a comment 18 centered arcund some activities that would show more -
19 ~
production than should be chown.
20 0 All right, and aside from whether or not that 21 **1"* ;ystem hcppens, would it be consistent with the weighted 22 for a craftsman to get credit for s*tting up.a joint once 93 and then s etting it up again if it needed to be corrected?.
~
24 g- No, that is not consistent. The way the weighted 25 value is emmtaA is by welA 4 Aant4 4r4 en& 4 nn . anA ==eh wm1A in EvtLYN $ SERGER OFFICIAL Coup REPORTER U. S. DISTRICT COURT CHARLOTTT, N. C.
Grier - Direct 17D i
f 1
i iden~.ified by a unique number and yet can only be received 2[ once reardless of how many times the $cint is fit or repairede 3
- O Only once per numbered weld?
4 ! A That's correct.
l 5
l 0 Mr. Grier, there were a series of documents made 6
available to me prior to your deposition, I believe in conjune- ,-
I tion with production from your files. Can you identify those? ,
8 MR. GIBSON: Just for clarity, Mr. Guild, I 9
believe those were presented just prior to Mr.
Davison's deposition.
11 THE WITNESS: Yes, these are notices that are 1
posted on our bulletir; boards that generally deal 13 with the subject of availability of NRC Residents 14 or other Officers of the NRC to any employee at the 15 Catawba Nuclear Station so they may have access to l
16 l the URO to voice any concern or complainto that l
17 '
. they might have.
~
. 18 ,
BY MR. GUILD:
20 0 Where are those posted on the job?
21 A Bulletin boards in variour prominent locations l
throughout the joL.
23 0 How many locations?
24 A I don't know for sure, I can guess probably a half l
25 dozen.
EvtLYN $. BERGER OFFICIAL COURT REPORTER U. S. Di$fRICT COURT CHARLOTit, N C.
l Grior - Direct i!0 l
i 1 j 0 Where would those' locations be? ;
A Well, I know that there is one in the main passage- '
2 3
way of the Construction Office. That happens to be right near, 4
the ladies and men's restroom, a prominent location. There is 5
a Bulletin Board in the Quality Assurance office area in a 6 passageway that is heavily travelled. ,
7 There is a Bulletin Board with this material posted 8 on the side of the building that contains the NRC Resident 9 Inspector's c"fice. That building is located out on the 10 project near the Unit 05toTurbine building.
11 I believe there is a Bulletin Board at the rear 12 entrance to the Construction office with this material posted; 13 and some others., but I can't recall the locations offhand. ,
14 O Are there any of those notices posted within the 15 actual station buildings?
16 l A I believe there are some bulletin boards in the 17 building. I really cannot recall exact locations. I thinh
. 18 there is one in the Unit Two Turbinebuilding area where the 19 j vending machines are located; but I'm not absolutely certain -
20 f that.
21 O .Now let me see, we have ,four pages in front of you.
22 Would you start on the right and identify that?
23 A All right, this 16 the Nuclear Regulatory Commissior t 24 Notice to Employees.
25 Q Is there a Form Letter Number on there?
EvtLYN $. BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CHARLOTTE. N. C.
Gri2r - Direct 181 t
1 A NRC Form 368 in parentheses.
2 O And that Notice is posted on the bulletin board?
l 3 A That's correct.
4 0 How long has that Notice been posted?
5 A I really am not sure how long it's been posted.
6
. 0 It has been posted essentially since it was required -
7 to be posted?
8 A It has been I think several years but I'm not sure. ,
9 Q All right, and then the next page?
10 A This is an April 25, 1977 letter from R. L. Dick, 11 Vice President, Ccnstruction. Part of it is short, I can read 1
12 it, "We expect our employees to express any concerns they may /
13 have about the quality of work to their Supervisors or any 14 level of Company Management.
15 In addition we have voluntarily agreed to post the 16 l following Nuclear Regulatory communications." Down at the 17
, bottom of the letter is some information that indicates that
. 18 any Nucicar industry worker who has cor. erns or questions .
19 about nuclear safety may bring these matters to the attention 20 of the NRC Inspector or nee est NRC Offico.
21 There is a telephone number apparently'of the 22 Region Two office in Atlanta.
23 0 How long has that notice been posted?
24 A I would say since April of 1977. This does say at 25 the bottom "These chances will be reflected in a revised NRC D Evttvn S. BERotR OFFICIAL COURT REPORTER I U. S. DISTRICT COURT CHARLOTTE. N. C.
Grior - Direct 182 t
l 1 forre pested to meet requirements of NRC 19 and 21."
2 : would take it this form revision was posted 3 shortly after.
4 All right, sir; and the third document?
Q 5
A This is headed " Energy Reorganistcion Act of 1974, ,
6 And it speaks about any Director or
, Section 20G, compliance." _
7 officer of a firm engaged in activities pursuant to the Atomic ,
8 Energy Act, basically it indicates their requirement to report 9
defects to the Commission.
10 All right, sirr how long has that notice been posted?
Q 11 g 7.m really not sure, several years.
12 Does it have a blank space at the bottom some place O
13 that is filled out?
14 g, ,
3 15 O What does that indicate?
16 A This says "Regulaticas establish necessary proceduret
. and requirements for the implementation of Section 206 of the
. 18 Reorganization Act of 1974, Federal Regulations, Part 21, -
~
Reporting of Defects and Noncompliance. Implementing procedure s O
for," and there is a-blank " Duke Power QA Department" is filled 21 in, "has been established as follows procedure QA 121 (QA) and 22 further a copy of 10CFR, Part 21 may be examined and reports 3
of defects and noncompliance may_ be made by contact," and 24 there it is filled in "R..A. Morgan" a-blank that.is filled 25 in "aw+.nninn un. "
EvtLYN $. BERGER OFFICIAL COURT REPORTER
- u. S. DISTR'CT COURT CHARLOTTE. N. C.
Grior - Direct 183 I
1' C What is CA 121 (QA) mean? ! l 2i A That would the Quality Assurance Manual and Procedurle 3 l 121 of the Quality Assurance Procedure that deals with reporting i <
4 items in compliance with Part 21.
5 0 All right, sir; and the last is a three page 6 document which is Federal Statute Section 210 of the Energy .
7 Reorganization Act. rYou do not need to read that, I will 8 have that identified so you do not need to read it or para-9 phrase it, Mr. Grier, ,
10 A Is that sufficient identification?
11 0 Yec. Mr. Grier, how long has that document been 12 posted?
13 A This has been posted for several months, I'm not i
14 sure exactly when, but sometime perhaps in May of this year 15 it was posted.
i 16 j O All right, let's see if we can mark those together 17 EE a package, Exhibit rour.
~
, 18 MR. GIBSON: Is that your only copy? ,
19 MR. GUILD: Yes it is. -
20 MR. GIBSOM: I think during the break we will 21 either make some or find some. I believe I have 22 extra copies of that pack of material.
23 MR. GUILD: Thank you.
24 (Whereupon, the documents referred to as l
25 Packet of Documents posted on QA Bulleting Boards EV(LYN $ BERGER OFFICIAL court REPORTER U. S. DISTRICT COURT CHARLOTTE, N. C.
, Gricr - Dircct 184 1
l 4
was marked and received as Grier Exhibit FiV* and 2
entered into the Record.)
3 4
BY MR. GUILD:
5
!, 0 All right, Mr. Grier, I want to show you a December l 1
6 l . 31st, 1982 document. It is Applicant's Responses to Palmetto'
- I i s y
- Alliance's First Set of Interrogatories (indicating). Can g '
l l you identify that?
4 9 I A Yes, I've seen this document.; i 10 Q Now that in part is responding to Interrogatories 11
- and Request to Produce regarding Palmetto Alliance's Contention 12 i Six; is it not?
i 13
.i A Yes.
14 1
0 It is Duke Power Company's Response?
- A Yes, it is.
16 i O Did you participate in preparing th'a responses to 17 !
!, Interrogatories and Requests on that Contention?
~
18 A Yes, I did. -
19 .
i O Would you describe your roic in that Response?
9
~0 i
A When the Interrogatories were rec'eived our Legal i
Department contacted QA and we appointed a Coordinator in this 22 j
area, Mr. Henry; and as I recall there were some meetings with 23 members of the Legal Department as well as myself and members 24 of my staff in which the Interrogatories were discussed, the
. elen e manninn, af +ha T=+=**aa=+a-4==
=-
A=*===4m=A anA OFFICIAL COURT REPORTES j
- u. S. DISTRICT COURT CHA4LOTTE. N. C.
Grier - Dirser 185 I'
. ansignments were made in regard to who would deal with the 2[f. Interrogatories.
3 There were drafts made of Responses to Interroga-I 4
f tories by certain personnel and in meetings with the Legal
. Department and myself and members of my staff, we reviewed
- ~
those drafts and turned that information over to the Legal _
=
q Department for incorporation in the Answers. ,
8 0 What was your responsibility with regard to 9
responding.
10 A My responsibility was to determine that the Responsos 11 that were produced from the Quality Assurance Department were 12 .
acec ;a.e.
13 0 And you reviewed each of those Responses as they 14 related to the Quality Assurance Department?
15 A Yes, I reviewed the drafts as they were presented 16 l to the Legal Department.
t
. O Now you understand, Mr. Grier, that the Interrcga-
- 18 tories were coupled with Requests to Produce Documents,
- 19 .
, documents that were identified in responding to those 20 '
Interrogatorics?
21 A Yes.
22 O And what was your role in identifying -those d'ocuments 23 and responding to the Requests to Produce those documents?
l A Again, through meetings with members of the Legal 25 l - n,,m +.---+ .- 2-a- i--> -- 2 - --- a. -- a s - - s .A -
- m... - - ,,. 4 ,,, ,
Evstym S. 8tRotR "
0FFINAL COURT REPORTER U. S. DISTRICT COURT CHARLOTTt, N. C.
Grier - Direct 186
(
1 -
1 to the documentation requests; and after gaining that under-2 standing we proceeded to give the appropriate individuals that 3 would likely have those types of documents and have those 4 collected and forwarded to the Legal Department.
5 rhat was your specific role in that identification?
. 0 6 Well, I had my files searched to d.etermine what
- A .
7 documents I had that would be responsive. I communicated to 8
my staff the understanding of what types of documents were 9
responsive.
10 I also participated in meetings wit.h Supervision 11 and employees at the Catawba Nuclear Station, at which time 12 they were requested to produce documents that would be 13 responsive.
14 O And when did all this happenr when did you search 15 your files, first?
16 A I can't recall exactly, but it was sometime during i
17
. the latter part of 1982, I believe.
18 0 You understand that those Interrogatories and ,
19
- Requects were filed in the Spring of 1982?
20 A I recall that frcm reading this .(indicating) .
21 O Do you recall having met, you met in the Spring 22 0f ,827 23 A Yes, sir; we had some meetings in the Spring of '82 .
24 Q And you had prepared draft responsas in the Sprin?
25 of .,82?
EvtLYN $. S(RGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE, N. C.
Grier - Direct 187 1
A I believe we had.
2 l i
Q Did you identify documents in the Spring of '827 3
A I believe that we began to collect some documents 4
together, but I really don't recall whether we turned any 5
- documents over to the Legal Department in the Spring of '82 or 6
y not.
0 Now am I clear in.' understanding that you are not 8
indicating anywhere in that document as having participated 9
in any manner in preparing those responses?
10 A Ity name or initials are not in the documents.
11 Q There is no Affidavit reflecting your participation 12 in responses?
13 A That's correct.
14 Q Now I direct your attention to Page 41, and there 15 appears the first of two pages of a Response to Interrogatories 16 l 23 and 25. Take a look at those questionsr and do you recall i
I those Interrogatories?
18
. A Yes, I do. .
I '
Q All right, the Quality Assurance Department unc 20 l
i responsible for preparing the Responses to thoco Interrogatorie s?
l 21 1
A The Quality Assurance Department was responsible 22 for collecting the documents together from the Quality-Assuranc e 23 area. I don't recall that we actually wrote the words that 24 appear here in the Response. l l
25 n W M A *> j EVELYN $. BERGER OFFictAL COURT REPORTER 4 U. S. DISTRICT COURT '
l CHARLOTTE, M. C.
Grier - Oire rt 108 L i
^
1 A I'r. not sure, I feel that maybe someone in the Legal 2
Department actually wrote those words.
3 O Did you review a draft of that answer?
4
! A I don't recall whether I did or not.
5 i
. ! O Then this may be an exception to your general statement that you reviewed the drafts of answers that related -
to the Quality Assurance area? .
8 A well, not reallyr what I stated is I reviewed 9
drafts of answers that were produced by Quality Assurance.
10 0 Yes?
11 A And as I said, I don't think these words were 12 actually produced by Quality Assurance.
13 O Mr. Grier, those questions relate to the subject of 14 disagreements and disputes between OC Inspectors and their 15 l
Supervision and pressuroon Inspectors to prove faulty work-16 i
! manship correct?
17
. A Yes. ~
18 i ~
I Q Generally if that does not relate to Quality -
19 .
, Assurance, whose area of responsibility does it relate to; and, 20 .
in f act, who did respond to that area if it wasn't Quality 21 Assurance?
22 A The documents are what is responsive to the 23 Request. The words here are just explanatory words in regard 24 to the documents that were produced.
25 . , _ , _
n , _t m ,_m._ m_,u _t--_. mt_ n _ _4.
== ==aa **T**=a =r **gg(pN BERGER OFFICIAL court REPOR7tR U. S. DISTRICT COURT CHARLOTTE. M. C
Grier - Dircet 189 l
l 1
i l On Page fourty-two there s a list of a few docu-2 l! ments. Help me understand from April to December of 1982 you I
i 3 i identified only seven, nine documents responsive to .those 4 Requests.
5
. As I recall those were the documents that could be 6
. found in files that reflected disputes End disagreements -
7 between Inspectors and Supervision or Management.
8 A I think, I am not sure but I believe in this 9
Response we indicated this was not a complete list and at 10 that time that these documents had been gathered together 11 we had not requested individual employees to search their 12 files, 13 O Had you searched your file?
14 A Yes, I believe so.
15 O Mr. Grier, where did all the rest of the stuff.
16 come fram that came from your file that is not one of these i
17 ' nine documents, sir?
18
. A Well, the material that I've produced from my file .
19 relate to documents that are licted here. The material that 20 I produced relates to the Welding Inspector Task Force Report.
21 O I am sure it does, but do you have any further 22 response to the question? Have you identified materials 23 beyond the nine documents that are listed there, Mr. Grier, 24 at that time?
I 25 A No, we haven't identified material that we understood Ev[ LYN S. BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT -
CHARLOTTE, N C.
Grior - Direct 190 l
i 1 i was responsive to this Request at that time and material that i
2
- I produced, some of it was generated at dates after this I
' 3 Response.
4 O What I want to understand is this, Mr. Grier Many
. documents that are not amongst those nine were subsequently
- ident3'ied and produced in response to those two questions.
7 Now I want to understand is it Mr. Grier who was ,
8 sitting on those documents all that time, or did you go through 9
, your file and identify documents, for example, all of the j documents regarding each of these Inspector concerne, includinir i 11 your followup, the memo to your file regarding talking to 12 Mr. VanDoorn, etc., etc.
13 Had you identified those at that time and someone 14
- else at the Company determined they were not responsive to i 15 the Interrogatory? I want to understand what your role was
! 16 I lctthetimeofthisanswer.
17 I' ME.GIBSON: Objection to the fom of the
{ .
18 1 question. Use of the phrase "who was sitting on -
I 19 .
those documents." Mr. Grier can continue to 20 .
testify about his involvement, documents he produced d
21 l and what he did as responsive to your question.
I 22 MR. GUILD: I will be' happy to rephrase it. l 23 I l
24 BY MR. GUILD: 1 1 25
, n m_ .._....._2__m_2 s. s . _ a. -, _.,..4_ u ,.
m "" J""
EVELYN $. B(RGER 0FFICIAL COURT REPORTER U. S. DISTRICT COURT '
CHARLOTTI. N. C.
Grier - Direct 191 F
1 i; Grier?
2 A I believe I do.
I 3
O Can you answer it?
4 A Well, for example, that memorandum of December 20, 5
. I am not sure it was in existence at the time these documents 6
, ,,,,' turned over to the Legal Department; but at that time -
7 thoca documents were turned over it was our understanding that ,
8 we were responsive in giving'the documents that related to O
the concerns and related to our course of action to correct 10 the concerns.
11 At that t.me some of the detailed documents that 12 have subsequently have been produced were net considered to 13 be necessarily responsive.
14 O By you?
15 I A I am not sure that as I recall I may have concurred i
16 in that decision or that understanding.
17 O Let me ask you more directly: Do you believe that?
10 Is it your position, George Grier, that those documents listed -
I ~
there were responsive and represented the full range of docu-20 .
ments responsive to that Interrogatory?
21 A At the time that those were produced I felt that 22 they were responsive.
23 Q All right, sir.
24 A As I indicated, I believe in here we said that there 25 ,,, ,,,,,,,7 ,et
- te e _ . g= g=,_=g t= = , t= ;_,,gvy ,,;=3 EvtLYN S. BERGER OFFICIAL court ptPORTER U. S. DISTRICT COURT CH ARLOTTE, N. C.
Grier - nirect 192 i
l-f 1l employees yet to ask them to produce any documents in their 2 !
- files.
3 ,
- O Well, more specifically, Applicants do not now 4
l represent that this list is complete?
I 5 i
. ! A Applicants are continuing their search to determine 6
. whether there are additional documents within scope of -
7 Interrogatories 23 and 25.
8 Q What I want to understand, Mr. Grier, in plain and 9
simple t.erms, am I to read that language as it appears to 10 call for fair reading and that is these are the product of 11 l searching at that time and that the search that identified 12 later documents had not yet been performed?
13 A I am not sure exactly the timing of turning those 14 documents over to the Legal Department in relation to when 15 we began our request to individual employees *to search their l 16 ;
- i file.
! 17
!. O I want to talk about you and your knowledge.
18 -
Had you searched your file, George Grier's file, and had you -
I 19 ,
l ,
turned over the contents of your file to anybody else?
20 -
Should I understand this answer to be reflective of the status 21 of the search as it relates to George Grier's file at that 22 time?
23 A Well, as I said at the time the information in my i 24 file that related, as we understood it.then to be. responsive 25 to "' 6 Keque i. La" L-uggggyyg,jg, M quouily h.
h.t.= ]
0FFICIAL COURT REPORTER U. S. DISTRICT COURT I CHARLOTTE. N. C. l m ,,,m - m. --a y, ,m- 3-. y- --r -+ -w- snw,*=p- * ' '
t I
Grier - Direct 193
' 1 ;
4 search we produced more background documentation, and that 2
documentation was turned over I believe in a followup response.
Q Yes, we will get there, too. I am still having a 4
l hard time getting what I understand to be responsive answers, 5 i l Mr. Grier. Let me make one more effort to try to rephrase the 6
- question: I want to know what you did, what documents you -
. 1 7
! identified. Can you tell from that list what documents came ,
8 from your file or any other documents you have available to 9
you?
10 I want to understand what of those documents were 11 from Mr. Grier's files.
12 A I believe Technical Recourse relating to this NCI 13 14816 would have been from my files. I believe that was the 14 Technical Recourse. I am not absolutely sure, but I think that is the Technical Recource relating to a concern Mr. IDY had 16 that I was involJed in.
i 17
. O Imything else?
18 n I can't identify anything else from my files from -
- I 19 .
, that list.
2 O Did your search of your file identify any other 21 documents that you were then excluded from the list of nine 22 by anyone else, Mr. Grier?
23 A No, not that I recall.
24 O So you excluded the other documentar, it was your 25 u.
s _ -______ - -
. . -. . , w & & w " '
Evrtyn s. BtRotR OFFICIAL COURT REPORTER U. $. DISTRICT COURT CH ARLOTTr. N. C.
l t .-
Grier - Oirect 194 i
i i 1 !
A I produced from my files what I considered to be l
2 , responsive at the time.
3 o All right, sir; you read those questions and you 4 examined your files and you made the decision of what was 5 responsive from your filest correct?
6 ! A That is essentially correct. -
I 7 0 If I miss anything, tell me.
8 A well, my files were searched by mv secretary in 9 addition to my review.
10 0 And you reviewed the product of her search of y:ur 11 files?
12 A That is correct.
13 O And you read documents?
14 A Well, as I recall that document that was produced 15 l there was the one that came forth that seemed to be responsive 16 cc a document relating to a disagreement between an Inspector 17 cnd Supervision or Management.
. 18 0 February 28th Supplemental Responses, can you identify ,
. I 19 that document (indicating)?
- 20 A Yes, I've seen this, 21 Q All right, sir; and that contains further responses 22 with regard to Contention Six Interrogatories and Raouests to 23 Produce?
24 A Yes, it does.
25 O Did you participate in the same session in respondirig EVELYN $, OERGER OFFICIAL COURT REPORTER U. S. DISTRICY court CHARLOTTE. N. C.
m . .
l Grior - Direct 195 I
' i l .
1 l to those further responses, producing those further responses? ' I i
2 i A Yes, I did.
1 3 Turn to Page 29, please. There is a further Q
4 response to Interrogatory 23 and 25.
5 MR. GIBSON: Page 28 or 297 6
MR. GUILD: 29. .
7 Yes, there is.
THE WITNESS:
8 9 ~
BY MR. GUILD:
10 0 Pid you prepare that response?
11 A I didn't personally prepare the response.
12 C Who did?
13 A I believe that would have been drafted in part by 14 Mr. Glenn Bell, but I am not certain of that.
15 0 I will have to represent the testimony of Mr. Bell 16 was that he carried docunents from the Quality Assurance II Department to the Legal Department, and that you did not do 18 ~
. any writing on the answers. ,
19 Do you know who did if he diddt? -
20 ~
A No, I don't.
21 l O It wasn't you though?
22 A Mo, it wasn't.
23 O Anybody under Supervision besides Mr. Bell that 24 you know of?
25 Well, the o+har nernon that nerhans would heve A
EVELYN $, B(RGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE. M. C.
Gr!.cr - Direct 196 L
' h 1l partAcipated in the draft would have been Mr. Henry.
2 O Why was the response to Interrogatories 23 and 25 3
limited as follows: " Incidents which had not been resolved 4
as between the Supervisor and the Inspector and, too, the I
5
, l complaints or suggestions by workers within the scope of Interro-6
. gatory 25 known to Duke Power Company Management," and quote. -
7 A I believe that was intended to indicate that at the .
8 time we had not requested as individual employees that they 8
produce documents responsive to 23 or 25 from their flies.
10 0 What about the first aspects why was it limited 11 to disputes that h.id not been resolved as described there?
12 A Well, again, I believe that was because we had not 13 gone to individual Inspectors and asked them to produce any 14 documents that they might have that would be responsive 15 to that Interrogatory.
16
! O Who vould you have gone to?
i 17 A Well, I'm not sure about the time frame at that 18 time that we had not gene to individual enployces; and I'm .
19 not sure whether we had gene to first line Supervisers at 20 Catavbc or not.
21 O Where would you have gone before you went to first 22 line Supervisors?
23 A To Management level employees.
24 O Who would they be?
l l 25 py, n,y,yn, 3 ,,. c,,,,ys,_
! EVELYN S. SERGER
! OFFICIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE, N. C.
Grier - Sirect 197 1
i Q At that level and below?
2 A I'n not clear as to the time frame when we went to 3 ; Supervision below that level.
4 But the initial beyond the search that identified Q
5 l the documents that were in the December Response, the next step i
6
- would have been goine to the Management level that Mr. Davison .
7 represented?
8 A No, the search that produced the documents in the 9
December Response included documents that would have been 10 produced from that level.
11 O Frc= Mr. Davison?
12 A That's correct.
13 O And subsequently' documents to the level of 14 !
Supervision below Mr. Davison?
15 A Yec, as I recall there were three steps we went 16 l cfter the firct etcp.
We went to the first level Supervicion 17 I! or all Supervicion, tnd then a subsequent step requestina all 18 *
, empicyees to produce documents frem their filer. ,
19 i O All in the OA Department? -
20 A All OA cnployecc at Catawba Nuclear Station.
21 O And your name or Affidavit or initials do not 22 appear in identifying you. participation in that Response; 23 do they?
24 A That's correct.
25 0 All richt. sir; and the March 25th resnonne to EVELYN $. BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE. N. C.
.j
Crior - Dircct 199 t,
i
( 1 I
to follovup Interrogatcries, can you identify that document?
2 A Yes, I've seen this document.
i 3 I O Do you have a similar participation in those 4 Responses?
5 A Yes, I did.
6
, 0 Was your participation indicated in any way by -
7 your Affidavit or initials or name on that document?
8 A No, it is not.
9 0 All right, sir; on Page 22 and 23 is a Response to 10 the followup Interrogatories, Number 9, did you participate 11 in preparing that Response?
12 A Yes, I did.
13 to that document responsive to that 0 It relates 14 Interrogatory which basically asks for background materials 15 behind the Welding Incpector Task Force; correct, "will be 16 l identified and produced at a later.timc"?
I 17 A 1ec, it indicates documents responsive will be
. 18 identified and nede available by March 30 of '83.
~
19 i 0 All richt, tell ne rhet you know about the identi-
- 20 ficatien of those documente, Mr. Grier.
21 A Well, first I think this is the point in tire 22 where background remorandum and documents that relate to the 23 l pay concern were gathered from ny files as well as other 24 files and made available to the Legal Department, and in that 25 time frame prior to nakine those docunents available wes the EVELYN S. BERCER i 0FFICIAL COURT REPORTER U. S. DISTRICT COURT f CHARLOTTE M. C.
Grier - Direct Icq 1 t i
i time that we had cone to all en.nleyee and asked for them to g 2 , produce any documents that they had that would be indicative 1
3 l of disputes or disacreements between any exployees and Super-4 ! vision er Mananenent in OA.
~
5 ! O All right, how did you communicate with those i
6 employees, any manner besides the meetinos that you have .
7 deceribed?
8 A Fo, I don't believe so.
9 O Did you write a memo or letter or note to those 10 employees or anyene elce as far as you know?
11 A I den't recall a written memo.
12 O Ihy did you write a letter to employees informing 13 them about their names havine been communicated to Intervenors 14 but net write a meno or n Intter to exployees asking that they 15 identifv docurente, Mr. Grier?
16 t re a ; ;" cannot S t." . I felt it vnc core important l
17 for ecch crnleyec to underrtand that personal information in 18 regard to them had been niven out, and some of the reasons or
. i 19 ' tre reasons for rd"ing that infermntien out.
- 20 0 Lesn innortent than individuti documente responsive 21 to those Interrogatories?
22 y no, 23 0 Uhy not put that in a written form to be clear, 24 Mr. Grier?
25 A It seemed entirely sufficient to have each emnleyee EVELYN $. BERGER OFFICIAL court REPORTER
- u. S. DISTRICT COURT l
CH ARLOTTE. M. C.
Grier - 'irect 200 I
4 3 '
come into a ecnference room, explain what we were askinc for, have Management or Quality Assurance as well as representativen i
3 j from the Legal Department present to make that explanation to 4 I give each employee ample opportunity to ask any questions they
. might have about the production of those documents.
There had- been meetings with Supervision before the ,
7 meetings with employees to explain the same thing to them, .
8 so after those meetings the employees could ask their Super-9 visors any questions.
10 0 Tcll me as much as you can recall about what 11 request was cc=municated to employees with regard to identity 12 of these matters?
13 A As I recall we asked them to produce any documenta-14 ltionthattheyhadthatwouldrelatetoanywaytoedispute 15 or a disagreement that they or any other employee of OA had 16 l had with Supervisory Mcnagement.
t 17
. O Hou were they to do that?
18 -
A They were to bring that information to the Employee -
19 .
, j F.clatienc Ascistant" at Catawba, who-would make a ccpy of that 20 informatien, give the original back to the employee who pro-21 duced the information; and that information was then forwarded 22 to Mr. Glenn Campbell who transmitted it to the Legal Department.
O And what did you tell them about the reason for that 24 identification?
25 , ,.. . . . , . . . , - a.- - - - . , . . . . - - a. s as . . ~.,,,,s.
~-v==*"-'- ~"~ " ~ " "
EvELYN $. SERGkR 0FFICIAL court REPORTER U. 8 DISTRICT COURT CH ARLOTTE M. C.
Grier - Direct 201 l
i i
! i 1 in the course of 9.iscovery of the Intervenors, and explained i 2 to them somevhet the procese of Interrogatories and that we I
3 ! were required te be responsive to those Interrogatories.
4 'Who gave that explanation?
Q 5 A I believe the actual initial explanation was g'.ven 6 by Mr. A1. Carr, and each session I believe I amplified that
- I request and the need to be responsive to that request.
8 0 And were there any questions concernine the 9
instructions?
10 A Yes, there vere some questions fren individual 11 empic7,c37 12 tihat vere they?
O l
13 A I can't recall c.11 the questions, I think more than 14 one, but not many asked the question do we have to do that; 15 cnd the answer ver yec.
16 n gg, ched thet?
l 17 1. I don't reccll any narec of any employees.
. 18 o Oc you know vhether they did produce documents from .
l . l
- 19 ; spc f31c77 20 A Yet, cmployees did produce doeurents.
21 Do you know whether they produced cll the documentsi l 0 22 A I can't he absolutely certain the.t they produced 23 They were requested to produce all the all the documents.
24 docurents that were' responsive, and we got quite a number of 25 documents tit.ned im EVELYN S. B(RGER OFFICIAL COURT REPORTER U. S. District COURT CH ARLOTTE, M C.
Grier - Dir:ct 202 i
l 1
, O Were any documents turned in that were r.3t produced' 2 '
for Palmetto Alliance?
3 l A No, not that I am at,'are of.
4 0 would you know?
5
, A I believe I would.
6
. O Why were your documents regarding Mr. Ross' '
7 Recourse and evaluation not produced until just the other day, 8
Mr. Crier?
9 A- That Recourse had not been concluded and we felt I
10 l that it was proper to wait until that Recourse was ccncluded 11 to produce ,those docunentc.
c 0 Uho fcit it was proper?
13 A I felt that was appropriate and I believe I dis-14 cussed that with members of our Legal Department.
15 O Mho did you discucs it with?
(
16 I. I think that Mr. Gitson and perhaps Mr. Carr end I
. I had some conversctions about that subject.
Q Mr. McGarry7 ,
19 -
- 1. I d.ct't recLll; he might have been prectnt in the roon when a couple c'onversations on that cubject took place.
21 O Had they scen the documents?
22 A I am not sure that they had scen the documents at 23 the time we first discussed the fact that there was a Recourse 24 pending.
25 m tr r, A ..r.,
"~~
-m e - +. m ,= .- w. ,s~...,-.,e s -- - , ,m , , ,. rs3m
~
EVELYN $. B(RGER OFFICIAL COURT REPORTER U. S. OlsTRICT court CHARLOTTE, N. C,
Grier - Dir*>ct 203 i
1 ref2ectino your docunentary infernetion recarding Mr. Posn' 2 , Recourse to the Legel Departrent?
l 3 ,
A Shortly after the Recourse documentation package 4 j that vas presented to Palmetto Alliance, shortly after that 5 was complete that package was presented to the Legal Depart-6 ment. .
7 O Ecr about before it was complete?
8 7. I don't recall thet that had been produced prior 9 to the completion of that Recourse.
10 0 Ee you did not produce it? You, Georco Grier, 11 did net make it available to the Legal Department until after 12 the Icst deted docunent in this package. Is that your 13 tcctirony?
14 A Yes.
15 0 That vould have been June?
16 : 7 I belic"e thct's correct.
l 17 O They verc et,cre of it Scfore then?
. 18 7. I don't knew whether they would hcVe been aware, ,
. I 19 t cil, I belic"c perhepr they vere evare that a Focourse was
- e 20 in Drogrecc crier to June, perbz!ps in Mry.
21 O You revieved and cpproved Mr. Pons' evaluation 22 March 17, 1983?
23 A That's correct.
24 O Did you review Mr. Ross' comments regarding that 25 evaluation? Their comments appear to be dated the 15th of April, EVELYN $. BERGER OFFICIAL COURT REPORTER U S. DISTRICT COURT CHARLOTTE. N. C.
l
Grior - Direct 204 1 , 1993?
1 I 2 A tio, I did not review those documents.
3 O All right, how about the P. M. Reep harrassment i
4 complaint'doeunent dated April 6,1983, from Mr. Alexander?
5 Why wasn't that identified and produced until just recently?
6 A I'm not sure exactly when that was made available .
7 to the Legal Department, but it has been some period of time, 8 I am not sure how long.
9 0 was it nade available to them in April?
10 A I don't kner for sure.
11 e t,'ho made it available to them?
12 A Either Mr. Davison or perhaps Mr. Alencnocr.
13 0 All right, and John Rockholt's complaints concerning 14 nr, Idlum when did you nahe that available to legal?
15 A tiell, this set of documents that you've shown re 16 vhich decc not hrve a recoranden I vrote en it, that natcrial 17 I believe van rade availabic by Mr. Davisen shortly after it 18 was produced; and after I rcccived it en June 24 1 vrote a
~
~
.' 19 rcrorendum en June 27 in regere to thrt, end I believe the
- 20
- p e;.e ay or the nes
- t dcy, I rato a cepy evcilabic te the Legcl 21 Department.
22 O
! All right, sir; that is your initial that appocrs l
23 on the top of the first page?
24 A Yes, that is my initial; this seems to be the copy 25 without my menorandum attached.
l Evrtyn S. BtRotR OFFICIAL COURT REPORTER U. S. DISTRICT COURT CHARLOTTt, M. C.
1
Grier - Direct 20f I
1
(
MR. GIBSCN: Yecterday, Mr. Grier, or at the l
2 beginning of his deposition, we produced the memo 3
he wrote in respcase to those documents, and 4 }
attached the same memo to the documents for 5
. completeness.
MR. GUILD: Right, that indicates you received -
that on the 24th of June. .
MR. GIBSON: That's correct, of 1983.
9 MR. GUILD: Let's take about a five minute 10 break.
11 (Whereupon, the deposition recessed at 9:43 and reconvened at 10:02 a.m.)
13 14 BY MR. GUILD:
15 I Q Mr. Grier, the Catawba Welding Inspector concerns I
were divided into Technical and Non-Technical concerns for i
1
. purposes of investigation and corrective action.
I understand that different organizations and ,
19 ! -
' Duke personnel were responsible for handling the responses l 20 ,
I to those concerns in either area. Give ne a summary of who 21 was responsible for which and how the response was organized 22 for each of those areas.
23 A Let me see if I'm clear about your question: Is 24 your question about who actually reviewed the written concerns i 33 &nenmA In anA Am&meminmA mannemanAm&4mne?
! EVf LYN $, 8(RGER OFFICIAL COURT R(PORTER U. S. OsSTRICT COURT CHARLOTTE, N. C.
Grior - Direct 206 t-i:
1 it O Yes, I want to talk in detail about the task force 2l and that task force reviewed what has been characterized as 3
the technical concerns.
4 l A Yes, and I believe I described earlier the appoint-5
. ment of Mr. Alexander and Mr. Powell as the Non-Technical 6
. Task'Torce, and described how we divided the concerns into -
7 Technical and Non-Technicair and those two gentlemen investi-8 gated those concerns in a similar manner to that that the 8
Technical Task Force ,used and presented recommendations as 10 to what to do in regards to corrective action.
11 O rad who was responsible for monitoring the imple-12 mentation of first the Technical and then the Non-Technical 13 concerns?
14 A Mr. Bill Bradley was responsible for monitoring 15 I the Technical Task Force implementation, and Mr. Neal Alexander 16 l was rerpensibic for nonitoring the Non-Technical Task Force i
17 I
. implementation.
- 18 Q And had the implementation of those recommendations -
19 l in both areas been completed?
20 A Implementation had been completed on specific 21 actions that were to be taken and implementation has begun simultaneously on any type of programmatic corrective action 23 as was the case with programmatic corrective action, that is 24 something that continues to develop as time goes by.
25 o ehme in in hnth avame. hnth the emehniem1 and the EvtLYN $. BERGER OFFICIAL court REPGRTER .
U. S. DISTRICT COURT l CH ARLOTTE, N. C.
I Gricr - Direct 2C7 t ,
l
'I' l 1 Non-Technict1? g 2 A Yes, I would say primarily in the Non-Technical are 3
- where recommendations involved items.such as improvements in i
4 l communications, those types of things that require training, 5 and as I think I indicated in some documents that were produced ,
6 some of our training plans are scheduled out through 1987. -
7 Q All right, sir; what in your judgment is the most 8 significant recommendation in the Non-Technical area that 9 remains pending or to be implemented?
10 A Well, there is no recommendation that has not been 11 implemented; and when I say that, implementation continues.
12 What I mean, for example, is a training plan has not been 13 fully carried out.
14 That is a plan that goes over several years, but 15 cach and every recommendation, the implementation has taken 16 lplaceandiscontinuing.
17 0 What is the most significant area or recommendation
, 18 which remains pending? '
19 i A Well, I guess I would say tnat our plan for training ~
l .
j 20 which is laid out in our training plan is possibly a significan t l
21 area that we are in the procese of carrying out.
22 Q That is training for whom?
23 A For both Supervisors and employees.
24 O In Quality Control?
l 25 A In the Ouality Assurance Department.
EVtLYN $, BERGI A 0FFICIAL Count REPORit A U. S. DISTRICT COURT CHARL0 fit, M C.
l
\ _ . -
GriCr - Direct 208 1 i; e
O So it is training for Quality Assurance people?
23 A Yes, that is correct.
3 MR. GUILD: Okay, thank you very much, Mr.
4 Grier.
5 6
. CROSS-EXAMINATION '
7 BY MR. GIBSON:
8 Q One question, Mr. Grier Are you aware of anything 9
that would cause you to question whether the Catawba Nuclear 10 Station is safely built?
11 A No, I'm not.
12 TURTEUR THE DEPONENT SAITH NCFr.
1 13 (Whereupon, the deposition was concluded at 14 10:09 a.m.)
15 16 I, George W. Grier, hereby certify that I have 17 ! read and understand the foregoing transcript, and believe it to
, 18 be a true, accurate and complete transcript of my testimony.
- 19 -
20 GEORGE W. GRIER 21 22 This Deposition was signed in my presence by 23 George W. Grier on the day of 1983.
l 24 25 go,xpy ,urnic EvtLT* S. BERota CFFictAL COURT REPORTER
- u. S. DISTRICT COURT CHARLOTTE. M. C.
209 l
1 CERTIFICATE 2 STATE OF NORTH CAROLINA 3
COUNTY OF MECKLENBURG ,
I 4 I, Lynn B. Gilliam, do hereby certify that the I 5 !
, Deposition of George W. Grier, III, was by me reduced to 6
. machine shorthand in the presence of the Witness, afterwards -
transcribed upon a typewriter under my directions and that the 8
foregoing is a true and correct transcript of the proceedings.
8 I further certify that these proceedings were taken 10 at the time and place in the foregoing caption specified. I 11 further certify that I am not a relative, counsel or attorney for either party or otherwise interested in the outcome of this action.
14 IN WITNESS WHEREOF, I have hereunto set my hand at 15 Charlotte, North Carolina, on this the day of July, 16 ygg3, 17
, 18 -
18 LYNN B. GILLIAM '
1:otary Public 20
- 1 My comission e::pires: May 12, 1988.
22 23 24 25 EvtLYN $ HERG [R OFFICIAL COURT REPORitR U. S. Disf RICT COURT CH ARLOTTE, N. C.
1 '
\?
- DEFENDANT'S CONTIDENTIAL _
EXHIBIT l l
. fzur) (
April 27, 1983 MEMO TO FILE
Subject:
Meeting with Beau Ross April 27, 1983 _-
I =et with Beau Ross and Art Allum as a follow-up to Beau's concerns -
regarding his evaluation for the period ending April 1,1983. Beau has expressed concern in a written recourse to Joe Willis in regards to his evaluation rating which was two (2). In my discussion with Beau I outlined several items for him.
First, I discussed my idea of his responsibility as a supervisor. I explained that he =ust represent the company to his employees and at the same time he must hold his employees' interest in mind. We discussed the balance a supervisor must have on these two matters. We also discussed the fact that a large part of a supervisor's task will be answering employees questions and the fact that a supervisor must determine when he can answer the quest.ons and when questions must be referred to higher supervision for response. I suggested that Beau had not been answering as many questions as he really had the training and judgement to answer.
The second area of discussion dealt with my philosophy in regards to the QA Program, work =anship, and following procedures. We discussed the fact that many questions and concerns raised by inspectors and others do not deal with the issue as to whether or not something will meet the requirements, but rather deal with degrees of judgement. I explained that one of his tasks as a supervisor is to use his judgement to answer employees questions in such a way that we will not exceed standards to a great degree. I used some -
diagrams to explain my point on this matter. There seemed to be a good
- appreciation of this issue in Beau's mind. .'
A third topic that I covered was the exe=pt salary program and a performance -
l distribution required by that program. I also discussed with Beau and Art my expectations in regards to administration of the Performance Management Progran. I told then that lexpected that in course of their periodic reviews, notes would be written on th tr performance worksheets which would aid in their understanding of expectations on objectives. I also explained to both I
of them that I expected their communications in regards to performance to improve.
$$ e
- I
'~
CONFIDENTIAL Pac.c B Fers /7JG 4/2?/f3 1
l The las: area I discussed was in regards to the hearings. I explained to Beau that one of our big task's would be to put the concerns expressed by velding inspectors into perspective. The intervenors will be chcrac:erizing these concerns in the worse possible light. We need to be clear on the significance of those concerns and in particular will have to be clear on the meaning of terms like " intimidation", " threats",
1
" falsification" and " pressure to approve faulty workmanship". These are
- words that were used in the concerns and could be used to describe very '
extreme circumstances. Again, using the diagrams I believe that there was a mutual understanding that the majority of concerns expressed dealt
- in terms of different degrees of judgement and that the intent of the program was being carried out.
Beau expressed his dedication to trying to do a good job. He said thac in the past he may have been taking the job too seriously, which I took to mean that he had been making big issues of things that were relatively minor in nature. He indicated that in the past, the big problem was in the nature of the way his concerns were handled and the attitudes of people both in Quality Assurance and in Construction. He indicated that there has been in improvement in both areas over the past year. Beau did express a desire to make a change and is particularly interested in going into Operations-QA. My discussion with him indicates that a change is not vital at this time but would be desirable if the opportunity presents i itself.
f I recommend that we carefully follow the Performance Management Program with Beau but that we take no extraordinary steps in doing so. It is important that Art closely observes the performance of all of the welding i inspection supervisors in his area in order to get a good comparison of performance.
- In summary I believe that Beau is sincere when he says that he understands the areas that he needs to improve in and that he is dedicated to make that- ,
improvement. I expect that we will have to reinferce the ideas that I ,
. expressed to him today in regards to supervisory repsonsibilities and ad=1aistration of the QA Program. We need to look carefully for.the .
signs thar indicate the need for that reinforcement. ,
i , x .
G Corporate QA Manager GWG/ph cc: W H Owen, C N Alexander, L R Davison e
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- DEFINDAIF5
- 39) R. n h Decemcer 23, 1962 2bf-MEMO TO F!LE I
Subj ect : Catawea Welding Inspector Concern 4
s Attached are notes f rom Kim VanDoorn, Resident NRC inspector-Catawba Nuclear Station. From his interviews with welding inspectors and super- ,
. vision in regards to the concerns submitted by a portion of these welding .
. Inspectors Kim's summary remarks are that all of the inspectors and -
supervisors interviewed believed the installations at Catawba are technically Edequate. He also found that no supervisor had intended to overtly falsi- .
fy any record or to 'cause anyone to falsify any record, inspectors interviewed concurred in this assessment. There was a feeling that Judgements involved may not have been entirely proper in some cases but that no falsification occurred and no inspector felt that they were asked to falsify any document.
Kim will be recommending that no further interviewing is necessary in regards to this matter. He will be following up on corrective action completion.
The following specifics were discussed in regards to his synopsis:
There is still a need to communicate better the workings of the Task Force and the Management Corrective Action, both with super-vision and with insoectors. The pressure in regards to the recourse procedure may be pressure to answer or satisfy the inspector rather than pressure not to use the recourse procedure. In regards to tre inspector comments, those who felt that the Task Force effort was inadequate may not understand that programmatic action was taken in regards to their specific concern. This again, points out the need
, to connunicate the completion of our management action. The inspectors perception of indirect recrimination as a result of talking to the NRC is undoubtedly the feeling that they might be looked down on for talking with the NRC. All indicated that they would go to the NRC.
Several comments indicated that the inspectors do not like going through
, the chair of command for answers and like the situation that existed previously where they could access the QA Technical Support Group more -
di rectly. ,
/
GWG er
( x Corporate QA Manager _
GWG/ph cc: W H Bradley W 0 Hen ry ~/
L R Davison
l rocember 2C, '952 i
Synopsis of Cc=ments Concerning Welding Inspector Concerns:
Interviewees censisted cf 9 supervisors and 19 inspectors.
Supervisors were asked questions cencerning adequacy cf the task force effert, ruppcrt cf inspec crs, falsification, and speci-fic concerns (as applicable).
Inspectors were asked questions concerning adequacy of the task force effert, supper: cf inspectors, knowledge of any tech-nically inadequate ins:Ellatien at Catawba, ability to talk to '
the NRC without recrim nation, falsification, and specific con-cerns (as applicable). '[
Superviser Co=ments:
~
Task feree effort was adequate and support (or perceived support) has improved (all).
Effort incomplete in that supervision (especially Baldwin) was not allowed to defend their position, little feedback to supervision as to whether they made inappropriate judgements or had com=unicated poorly (2).
Still need improvements in implementation of R2 program and resolution feedback (3 first line supervisors).
No overt f alsification occurred but misjudgements may have been =ade by second and third line supervision (2).
Need better communications with QA; QA personnel than some QC supervisors (1)get better answers from Still have problems with certain craft crews; e.g. quality of work, attitude, and craft taking items to a different in-spector to get item accepted (1).
There is pressure not to use the recourse procedure (2).
Some items are argued about for 3 days that would take 30 seconds to fix (1)..
Different inspector crews are interpreting procedures differently. 1 Inspector Comments:
k Task force effort was adequate (13). ~
Task force effert was inadequate (1).
Support for inspectors has improved and is now generally -
adequate (all except one N/A, yes with' comments provided _ con-cerning needed improvements).
No technically inadequate installations.
No recrimination would occur if I talk to- NRC (10).
l Some recrimination would result from talking to NRC'(9-i mostly indirect recrimination).
No overt falsification identified (all).
Signed holdpoints for items I did not inspect or did not l
l L
i
~.
, agree with (5).
Task force feedback was inec=plete (tetal results net un-ders:ccc or appreciated - 6).
- Specific cencerns not adequately addressed (7).
( lifferent inspecter crews intertreting procedures differently; need meetings with all inspectors (1).
Feel pressure net to use reccurse; less open ec==unica:icn, such as with ;i, than before (8).
Reccurse takes too long (2).
RT and Cavender used Ic override inspectors; should be used te fustify technical acceptance no: to everride inspecter call (3).
Still need i=:reve=ent in i=plementation of R2 progra= and resolution feedback (6).
' Concerned whether R2A (vs. NC:) is adequate to handle pro-ble=s (1). '
? roble =s are still encountered with specific craft crews (3).
- Still sc=e construction leaning, e.g. inadequate answer frc=
T/S (3) .
Singular Co==ents:
Need ;A T/S group.
A si=ple UT wall thickness gage would alleviate =any questions concerning underwall conditions.
Need direct contact with person resolving concerns; if the question goes through more than one person, the original question doesn't get( ?EM's Craft fully) answered.
is abusing the weighted valge syste=, e.g.
fitting up joints that they know are mislocated to get weighted value credit.
Feel downgraded and have lower motivatien.
Personnel cc==ents.
9 e
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s i This federal statute, Section 210 of the Energy' l Reorganization Act (4 2 U.S.C.55851) (1978), provides that ;
no employer (including an NRC licensee, an applicant for an NRC license, or a contractor or subcontractor thereof) g may discharge any employee or otherwise discriminate against
, an employee because of the employee's participation on behalf ;
of any party in an NRC proceeding. More specifically, no employer may take any action against an employee because the a=ployee (1) has commenced, caused to be' commenced, or is about to commence a proceeding under the Atomic Energy Act of 1954 (i.e. , an NRC proceeding) ;
(2) testifies or is about to testify in an NRC proceeding; or (3) assists or participates in any way in an NRC proceeding.
Any employee who believes that he has been discharced or otherwise discriminated against by his e=ployer for one i
of the reascns listed above may file a ecmplaint with the U. S. Department of Labor within 30 davs of the occurrence of the event. The Labor Department will then investigate '
w the charges and, if it deter =ines that this type of unlawful discrimination has occurred, will order the e=ployer to J
stop the unlawful discrimination and reinstate the employee to his former position along with hack, pay, terms, conditions and privileges of employment. Compensatory damages and expenses related to bringing the complaint may also be awarded to the employee.
I
+
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)
4215851 NEUC EEALTE AND WELFARE 2D6 I us1. Emo ner= premales
~
w Desnmissess asamm amehree No empisyur, lasteding a Commimmes Esemme, as appnammt for a t'h Emsman, er a anneremer er a sensestrastar of a Commamise Inseesse er apphumas, may
! s discharge any suspiereeir otherwise duurtainste agesus any emphryee with aspest to we r - =rw tansa, ==-a- er prminges of empieynest hemmens the empieyes (er say peruse acting purosamt to a request of the esipisyes)-
(1) ========d emmend to be h er is ahmet to ammmense er ename is :4 he ese nsesed a - "ag under this shapear er the Atomie Amt of .
O 196d, as ammaded h UAC.A. t 2011 et seq. , er a presseding for the ties er enfargenset et any requbement )mpamed seder this ahnpear er the i
A.amic Energy Ast of ISH, as ====a-d '
4 G) u=e+hd or is akset to testify la any such preussag er:
.l G) asustad a?partampated er le about to assist er partiesyste is any manner la
- seek a pressedias er in any other mammer la mesh a premmedag er la any other
- acties to earry out the perpenas of this er the Aasmas Emergy Aas et leed, as ansaded [4R UAC.A. I W11 et seq.
M Camehims, mas and esenestse G) Aay who believes that he has base essharged er otherwies dimarieb marad ignisse ser ponen la dilatism of -- (a) of this semise mar, withis thirty days after such vielsties ensure, fDs (or have any persas !De en his behalt) s seaplaist with the Secretary of Laher (hereinattar la this submastasa referred to es ths "Seentary) aDeging :ach discharge er disertamatasa. Upse remopt et seah a
, ameptaist, the Secretarr shad saify the paresa an==8 la the r'== et the fning i of the enrapiaint and the Commismse.
l G)(A) Upon resept et a seaplaint f5ed ender paragraph Ok the Sesretary shaR eendast as tsvestigatise of the violaties aDeged is the - --T ' ^ Withis thirty of the rossipt of each esepiaiot, the 5serstary shad esspieta such invutigatisa shad estify in writing the semplaint (and any perses acting la him behalf) and the peruse a5eged to have Jostaitted seeh violaties of the resette of the t'evestigatans N esaducted pursuant to this subparag sph. Withis aiesty days of the russipt el such v .
soeplaint the 5eentary shad, unisse the pneending en the esempiaint is termamated by the Secretary se the hemis of a settjement estared inte by the Seerstary and the person aneged ta have eeramitted such velatism, issue sa order either prevuin'ag the .
relief preser bed by subparsgraph (3) er denying the esoplaims. Aa order og the 5.cntary sha:: be made en the ruard after notase and opportunity for public hamnas. .
The Secretary may ast estar isto a settjement terminating a prommoding as a i ocep'aint without the partac:pation and seasset of the esmplaimant. i -
(B) If, is response to a complaint ! Led under perngraph (1k the Secretary estar-mines that a violaties of subeseties (a) of this smetass has assurred, the 5seretary t o sha3 order the person who seramitted such violatlan te (I) take affirmative assise is -
I abate the vielstieu, and (B) reinstate the ,'+--^ to his former pestise tagether with the esapensat!es (laciudlag back pa ), terme, eseditises, and privGages of kh ..
employeret, and the Secretary may nah perses to prmis asapammtsry * .. ,
, damages to the complainaat. If as order is immend under this peregraph, the 1 Secre , at the reqoset of the complainaat shall asemos agalast the perosa agnisst order is :ssued a sua equal to the aggregste anseat of aD aussa and 4 '
whom erposess (las!ading atterevys' and erpart witanus foss) reasonably laserred, as detarmined by the Secretary, by the -pl=h==e far, er la ====m with, the -
he.nging of the esmpletat apes which the order was innaad.
(s) Bertow j
, .i l 0) Asy peroes affected er aggrweed by an order immed unde shamssise
' review of the enior is the United States esart of o (b) of ths - 6== may appeals for the circuit is which the vielsties, with respost to whndi the arder was issued, aDegedly oorstred. The petitles for review must he fDed withis shrty from the a==e of the Sesretarx'Is arder. Review sha!! esafenn to shapte T
~
Title L The es---- -- t of pressedlags ender this O -- - ,.l. abaB ass, unius enlared by the esen, operate as a stay er the Seestery's order.
G) As order et the Sesretary with respost to whisk review eseld .have hase '
obtained under paragraph 0) shall est he sehjest to judamal es%se la aar minimal er ether dvs pressettes. .
, ==
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l 3rt ;*rustrC EALTH AND WI2JARE 42 5 5851 hets 3 5 to Jutumselme Whenever a pense has fa3ed to esoply with as order issued ender -h OXD et this aestian, the Secre.ary may fas a ava assion in the United States dimenst eeurs for the duenct in which the vindstion was foemd to escar to enteres each order.
(
- la actions teseght nader this subescJoe, the distnet esorts shad have jensdscties to grant aE appregnate relief insinding, het not ! bared te, injunctive rehaf, esapeame-88'7. and esemplary damagen.
We et assian G) Amy perums se whose heks2f na order was usoed ander paragraph (M of sahmactisa @) et this section may commenee a civQ assise against the pareas to whoss each order was isoned to rautaire ansplianes with ensk order. De appropriate Ushed
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, dascnet anert itsH have jenedictaos, wt'. hest regard to the ameest La eastro-versy er the *==1 V of the pamma, to enfores ask order.
G) The smart, in imming any !!aal order ander this ' % may averd esses ef It"gsties (lactedtag ma asserney and scuart wizaeus fees) 1e any party whenever *.be emers detsnames sock award is appropriese.
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Amy duty herpened by this smetJoe shad he enferoemble he a saadamme preensear est ander sectue last of nJe z.
(as Desh-eas weimsimme Subsectice (a) of this aseties shaB not apply with respect to any esaployee who, ac.a cwithwt diree/on from his or her empierer (or the empierer e aseast ducher.
stely enases a vuistaes of any airement of this chapter er af the Atomic Emersy Act of 1964, as amended [42 U.S 5 Ell et seq.}
(Pahl es-a. % U. I sia, an aded Pah.L ss-et, t 14,18.. e, tsu. ut Fiat. 3s3.)
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1 April 25, 1977 L'e expect our e.mployees to express any concerns they rnay have about 'the quality of work to their supervisor or any level of Company management.
In addition, we have voluntarily agreed to post the following Nuclear Regulatory Commissica ccer :nication. .
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R L Dick -
- Vice President, Construction
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Any nuclear industry worker who has concerns or questions about the nuclear * .
safety of any facility or activity licensed by the Nuclear Regulatory Comission may bring these matters to the attention of an NRC inspector or the nearest NRC Regicnal Office If they cannot be resolved directly with his or her e picyer. The NRC will treat the Iden Ity of a workers as a confidential scurce if the worker requests that his identity not be disclosed.
In order to improve channels of co--unication between NRC and Nuclear Industry workers, the NRC is eaking two proctJural changes:
- 1. NRC frseectors will soon be wearing identifiction badges and, in sc e cases saf ety nats identifyino Item as NRC iascectors.
- 2. NRC Regicnal Offices will acceot collect teleo}cne calls from nuclear industry w=rkers wee wise to sceak witn an N AC recre-I sentative concernine cuality of wo.-k, radicleeical safety or_
- 4 safeguards oecole s. Tne tele:ncne nu.oer of tne a=crcoriate h;C Regicnal Office for tnis oroject is 404-221-.4503.
These changes will be reflected in a revised NRC Form 3 posted to meet require.ents of 10 CFR Part 19 and a revision of preposed 10 CFR Part 21 l (both of which are in preparation). IJntil these revisions are published, l all workers at NRC-licensed facilities or activities should be aware of these improved channels of ce= unication with inspectors. -
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- ENERGY REORGANIZATION ACT OF 1974 Act of October 11.1974(PublicLaw93-438)
Section 206 NONCOMFLIANCE (a) Any individual director, or responsible officer of a firm construct-in;, owning , operating, or supplying the components of any facility or activity which is licensed or otherwise regulated pursuant to the Atomic Energy Act of
- 1954 as amended, or pursuant to this Act, who obtains information reasonably s
indicating that such facility or activity or basic components supplied to such facility or activity--
g (1) fails to comply with the Atomic Energy Act of 1954 as amended,
! or any applicable rule, regulation, order, or license of the Comission relating to substantial safety hazards, or d_
(2) contains a defect which would create a substantial safety hazard, as defined by regulations which the Comission shall promulgate.
shall innediately notify the Comission of such fai1ure to comply, or o' such defect, unless such person has actual knowledge that the Comission has oeen
- adequately informed of such defect or failure to comply.
~
(b) Any person who knowingly and consciously fails to provide the notice required by subsection (a) of this section shall be subject to a civil penalty ,
in an amount equal to the amount provided by section 234 of the Atomic Energy Act of 1954, as amended.
(c) The requirements of this section shall be prominently posted on the premises of any facility licensed or otherwise regulated pursuant to the Atomic Energy Comissicn Act of 1954, as amended.
(d) The C mission is authorized to conduct such reasonable ins;ections and other enforcement activities as needed to insure compliance with.the pro-visiens of this section.
e .......................................
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,f Regulations establishing procedures and requirements for the implementation of a
~1 Section 206 of the Energy Reorganization Act of 1974 have been promulgated by the Naclear Regulatory Comission in Title 10. Code of Federal Regulations, q{
Part 21 - Reporting of Defects and Noncompliance. Pursuant to 10CFR Part 21, implementing procedures for 1DoeE P o w r it C . (4 . h s P 4 27 M6:47 : ,
have been established as fol' ows:
D rec.c.J - e Q A -til [ /D A M 3, i
A copy of 10CFR Part 21 and the above listed procedures may be examined and
}
reports of defects and noncompliance may be made by contacting:
R . A . h3 c R. G A r4 at e d. 3 2 0 .
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