ML20082C147
| ML20082C147 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/13/1983 |
| From: | Davison L DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20082C119 | List: |
| References | |
| FOIA-83-434 NUDOCS 8311210479 | |
| Download: ML20082C147 (147) | |
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( NIT ED FTATES OF A MERIC A NLCLEAR REGULATORY C O M MIS SIO N BEFORE THE AT O MIC SAFETY AND LIC E NSIN G SOAR D
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DUKE P O V. E R COM PA NY, et al.) Docket Nos. 50-413
) 50-414 (Catawba Nuclear S t a ti o n, )
Units 1 and 2) )
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.:: . .= : :~.:.=- JULY 13, 1983 8:32 A.M.
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. 'l s l l D E POSITIO N OF:
LARRY B. D AVISON l
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l f7f 8311210479 030825 l'tel)n licrger Associates PDR FOIA "* * "*"""""'""**
AHLERS83-434 PDR ".'C.
P D O X 19444 CHARLOTTE NORTH CAROLIN A 28219
2 1 .4 F F E n n A N C E F .
2 7. o r,E n T CL IL D, CSc. ;
, C ol u m bia, S. C, 3
Coun s el on !!ehalf of Intervenor, Palmetto 4 Alliance Corporation 5 RONALD L. CIDS O N, ES O, C ha rlott e, N. C.
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') C oun s el on Gehalf of A p plic a n t. Duke
,L 7 Power Company
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8 Also P r e s en t:
9 Roger Q u e lle t t e Duke Power Company 10 Glenn H. C e ll 11 Duke Power Company 12 %ayne Henry Duke Power Company 13 Micha el F. Lowe 14 Palmetto A llia n c e IS Phil Jos Palmetto /. l l i a n c e 16 "etry Le vits a II C c r olina E n vi r o n m e n tal F udy Group 19 I N D E. X 20 t ITNESS DIR E CT CROc5
l Larry R. D e vi s on 3 122 i
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- E Y H I B I T S '
0 NU M B ER DEFCRIDTION PACE i, i
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- 4 ' D avis on Exhibit H a n dwritt en notes dated F
, a 2/5/S2 5 l
' - E I D a vir e n Exhibit Letter da te d 1/13/82, i 6 ;B f ro m Rockholt to q
l iq ;' Bradley 56 i.
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4 7 h l pDavison Exhibit Six page note of Larry l 2 E C D a vis on dated 12/28/81 67 F i
D a v i e o r. Exhibit Typewritten version of I l .D comments to Mr. Lells 123 l' ic '. f.
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.; D avi s on Exhibit
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) Qu e s ti on s concerning j tt L E Mr. Bryant 123 J h 10 , D 4.
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H LYNN B. GILLI AM j! $TENOGR APM REPORTER ii
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! I i i 1 The f ou rth r e sum ption of the D e p o sition ofj i
1 2ll Larry E. Devison is taken at t r. e corporate of fice s 3 of I; u k e Power C o m p a n y, Charlotte, N o rth C a rolina, 4 on this the 13th day of July, 1983, in the presence o f 5 R obert Guild, Attorney for the Intervenor; and Ronal i g '
6 f L. Gibson, Attorney for the A p plic an t.
l 7 All f o r m a li tie s as to c a ption, c e rtifi c a t e
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8 l and tr ans mis sion are waived. It is agreed that Lynr I
9 B. Gillia m, Notary Public in and for the State of 10 North C a r olina , may tche caid D e po si tion in ma c hine 11 I s ho rthand and t r an s c ribe the name to t yp ew ritin g.
l 12 i F ald D e po sition is ta ke n subject alone to 13 te s timony f o r c o mp e t e nc y, relevancy and m r. t e r i a l i t y :
14 and a ll obj e c tion s , save as to the f o r rn of qu e s tio n e 15 athed, are rererved u n til the H e a rin g.
16 L is r. R Y D. D A VIS ON, 17 ' h a vin g been previourly sworn to tell the truth, w t. c
.g 18 e xa mi ne d end te s tifi ed ne followr at S:32'a.m.
19 20 MR. GIBSON: h: r. G uil d, this is the 21 r e s u m ptio n of M r. Davison'c D epo sition, 22 he is a vaila ble for que s tion e .
23 24 DIR E C T E X A M IN ATION 25 BY MR. GUILD:
Evrtvm S. BERotn
. OFFtCIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE. M. C.
Davison - Diroct 4 1 C Ccod mo rnin g, M r. Da vi s on.
i 2 A Goud mo rnin g.
3 i O Y ou have been previously sworn and you I
4 !are und e r oa th.
I l
5 r. Yes.
l 6 Q I want to show you a document and tell l 7
you this was made a v a ila bl e to us in Discovery. It 4
8 is represented to me to be the handwritten note s of 9 Mr. Z wis sle r.
10 Did M r. Zwis sle r in te rview in th e course 11 of r e vie wi n g the Task Force work?
12 A Yee, air.
13 O V, o u l d that have been a p p ro xi m a t ely the la 5th of February, 1982, to the be st of your r e c oll e c ti on?
15 A I couldn't r e c a ll the s pe cific date.
16 C 1 want to direct your a tt ention to c om e 17 c pe cific parts of t ha t. Take a moment and look 18 through it.
19 It begine with your c r e d e n tial c , fir c t.
20 Have you seen those notes b ef o r e ?-
21 i N o.
22 C V. e are g oin g to go through those, Ron.
23 It might be helpf ul if he could use your copy and he 24 would have one in front of him.
25 MR. GIBSON: Do you intend for this Evrtyn S. Brearm
.. OFFICIAL court REPORTER
- u. S. DistalCT court CHARLOTTE. N. C.
Davison - Direct 5 1 d o c u m e r. t to be a tt ac hed, Iob? It was at 2 the bottom of the stack.
3 ; 4R. GUILD: No, I'll get to that in 4 a minute.
5 l
0, 6 SY MR. GUILD:
7 Q M r. D avis on, hand that back to me, please ,
~ l 8 and we will ma rk this as the next Exhibit to f4 r .
9 D avi s o n 's D e po sition.
10 ( W h e r eupon, the handw ritten note s 11 dated 2/5/82, were marke d and 12 received by the Cou rt R e po rte r as 13 Da vis o n Exhibit A and entered into 14 the R e co rd. )
15 10 EY $2L. GUILD:
17 C h: r . Davison, I know you cannot r e c a ll the
, 18 date exa c tly, but given the time f rame w h e. n the Tas h 19 Force w s. e d oi n ;; ito rork and when Mr. Z wie sle r wat 20 6n site r eviewin g the T a s k F o rc e 's wo r k plan, would 21 the Sth.of I' e b r u a r y have been likely the date on 22 w hi c h you were interviewed ?
23 A' It could very li k e l y have been, . yes.
24 Q You talked g e n e r ally about the w eldin g .
25 in spec tion- conce rn and'your p e r c e ptio n of the basis EVILYN $ BERCIR OFFICIAL C0umf REPORTta
- u. S. DisTetCT court CH ARLOTTE, N. C,
Daviron - Diroct 6 l
1 I 1 'of those concerns an d Quality Assurance at C atawbc' !
! 2 A Yes, he asked me qu e s tion s about those l
3 things.
i 4 i O Now he says af ter noting your job qu alifi-5 c a ti on s and ability of your work history, I take it he
- 6 l asked you q ue s tion s about those subje ct s ?
7 A Yes.
8 ; O He lists p e r c e ptio n of current problem--
9 do you have a copy with you?
10 f. Yes, 11 O Look on the bottom of that fi r s t onge, 1 12 think it ic N u rn b e r Three, does this ac cu rately re-13 fl e c t your answer to him on that t o pi c , the p e r c e ptic a 14 of the current problem?
15 A 1 don't recall exa c tly shtt I caid then.
10 I think is probably a p r e tt y accurate record of it, 17 though.
18 C Fir st you have li s t e d pay, and I think we 19 unde r s ta nd that is the r e cla r rific:.t f o n of the telding.
20 Inepector pey grade t. n d the concerne about that re-21 cla s sific a tio n ?
22 3 night, 23 C " F e elin g of %Is," %elding Inspectors, I 24 take that, "They have not been supported." Now how 25 did you understand or did you unde rs tand that genera l EVtpH $. BERGER
, OFFICIAL COURT REPORTER
- u. S. DISTRICT COURT CH ARLOTTE. N C. ;
l D a vi s on - Direct 7
! l 1[ point, lack of support?
t a "
, B ell, I think the telding Inspectors had i
3 expressed that in a lot of their concerne, and they I
4 lhad even v e rb ally said that to me, some individuals t
5 of t he m.
p 6 They just did not feel like they were being 7 s up po r t e d. That is probably his thought ofmy--
8 ,
C Support by whom ?
l 9 A Support by mana ge ment, their mana ge m ent.
l 10 C You would have been part of that ?
11 A Yes.
12 Q A ll right, "They did not separate techni-13 cal and pay incues." How do you underetand that?
14 A In te rms o f I c. e k of cupport, they caw or 15 jfelt the any a c tion wat taken to be a part of that i
16 l1zek of r. u p p c r t.
17 It wac int e r pr et e d that way.
18 r And did you underetand the f e elin g on the 19 !ptrt of th e Weldir.r 1r.r.cectore t h c. t the technical and 20 pry leaves vere not separate, that they were related ?
21 A I felt that that was part of the f e elin g, at 22 least part of the m. I can't say for all of them, but 23 at leart part of them.
24 C h hy did you see it as i m p o r t t. n t , if you 25 did; and I gather you did f rom your e a r li e r t e s ti m o ny, EvtLYN $ BERGER
_. OFFICIAL Count REPORTER U. S. DISTRICT court CH ARLOTTE. N. C,
D avis on - Direct B l
I I'
1 to separate the pay issue and the technical issue in f
the procese of r e viewin g those concerns?
2 [i 3 '
/- VJell, the two issues were reparate, pay I
i 4 issue was a r e vi ew of the pay grades for inspectors.
5 /. lot of other inspector cla s sific a tio n s other than I
y 6 ' ju st Vielding Inspectors were i nc lu d e d in that, the 7 concerns that they raised came up during the recours e 8 for that.
9 They did not deal s p e c ifi c a ll y with pa y.
10 In most ccsce t h e. y dealt with s p e c ifi c c a. s e s about 11 things they were concerned over.
12 I erw those as technicci it em t . I didn't 13 see the c o r r ela tio n. I raw them as two ecparate 14 issues.
15 C The lu ch of ruppor t being a c om mon f a ctor "
l 16 l !. I think th e V.elding Inrpectorc felt or rome 17 of t h e rn felt that the pay was an example of lack of 18 rupport alco, as well ac the technien1 icaucc.
I 19 i
. Do you b e liev r the Vi e l d i n g Ine pce t or e wer' 20 r a tir fie d with th e r e pa ration of the pay iseue from 21 the technic 1 icsue in the re vie w process?
22 A I co uldn't say whether they were a n tis fie d 23 or not with that. I think they unde r s ta nd that, i
l 24 C Now the second page, " Heard f rom Da vi s o n
! 25 at meeting wit h V' I s that he supported pay decision."
l Evttvn S. Bracta orriCiat Count atronten U S. DeSiniCr count CHARL0 tit,N C.
D avis on - Direct 9 l
1 W ha t meetin g woul d that have been?
2 A There was a January the lith, _ I b e lie ve ,
3 1982, m e e tin g that I had with the % elding Inspectors l
4 l at Catawba; and at that me e tin g.I indic ated to them 5 when one of them or a couple of the m, 'I don't recall ,
~
p 6 asked me did I think that their pay had been evaluate d 7 properly through this program, I indicated ye s, I did .
8 I thought that was accurate, and I support ed 9 th at .
10 Q h as this the me e ti n g at which the pay re-11 cla s rific c tio n issue was ex plain e d to the Leiding 12 In spec to r s ?
13 j. No, 14 O What was the purpose of the me e tin g ?
15 1. S eve ral in s pec to rs had been to sce Lob 16 x! o r ;: e n a n d h e ti exprerted some technical concernr; i
I 17 and ao I r e c all, they indicated they wo ul d lik e to 18 meet with me, and I w en t ahead and set up that meet-19 i r. g .
20 T he purpore of that was ba sically to find 21 out if the y he d technical concerns, what they were, 22 l and explain to the m how they should handle t h o t, e t
I 23 concerns and how we would handle them and' direct 24 them to li e t those concerns down, and we would look l
l 25 into them.
l EvfLYN $. BERGER
. OFFICIAL COURT REPORTER U. S. DISYetCT COURT CHARLottt,N C,
I Davison - Diroct to
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C Ie this the meeting at which you in struc ted I
2 the V. e l d i n g :n s pe c to r s to put thoac technical c ti n c e r nis 3 !in writing ?
4 l A Yes.
5 C That is the m e e tin g which produced the
- - 6 handwritten notes f r om CC and QA Inspectors whic h 7 set forth their "ba sic problems and concerns"?
8 I am r e f e r rin g to some indexed documents.
9 A Yes, that is where I instructed the m to do 10 that, and they were also instructed with n lette r fro m 11 Jim V, ells a f te r that time to do the s r. m c t hin g.
12 C- And that m e e tin g and Mr. W e ll r ' letter 13 produced the handwritten concerns that we have h r. d 14 r ef er enced ?
15 f yes, 16 c :.: o w the meeting with Mr. Iv o r 2 r. r. , when 17 had that occurred?
18 A I don' t r e c a ll :.n y s p e cific mc c tin g. Of 19 cource, ash 1,' o r t; L n .v s s the P roj e c t CA L t. g i n e e r Lt 20 the ti me , and ne'and I diccussed regularly things
- l over the pnone; and I pe rio di c a lly me t with him on 20- a r e gula r b r. r.i s , so there war no di s tin c t m e etin g on 23 that that I can r e m e rn b e r .
24 O I picked up on s ome thing you said a momen t 25 ago, some V, e l d i n g Inspectors m et with M r. l.. o r g a n -
EVELYN S. B(RQtR
. OFFICIAL COURT REPORitR u S. Disf RiCT COURT CH ARLOTTE, N. C,
Davi s on - P oct 11 I and that is how you learned of th a technical concerns i
2 P and set up this J r. n u a r y 11 mee ting ?
l 3{ A y.,
l 4l O V. h a t me e tin g with Mr. Mor gan ?
I 5 A There was no specific m e e tin g on that.
6
, Some of the m had talked with him about it over the 7
phone, and we talked about it over the phone; and I 8
think at least one or two inspectors talked to him 9
individually, and when I was down there, we would 10 talk about that situation, but as I r e c cil I don't i
11 r e c all any e pe cific m e etin g.
12 It would have been during the normal 13 course of events.
14 C What kind of technical concerns did you 15 l unde r e tand through Mr. Morgan had been expreesed 16 lby V.c1 ding Inepectore?
17 A t. s I r e c all, I b e li e v e Mr. Bryant had 18 talked to hi m, and Mr. R o c kholt had talked to him 19
, c. b o u t having some technical concerns.
90 I don't recall c p e cific a lly the issues, what 21 those were at that ti m e . They would be included in 02 the li s t of c oncern e f rom those people, though.
23 0 You don't know which ones were brought 24 to his a ttentio n ?
25 A I don't remembe r s p e c ifi c ally which ones EvtLvN S. BtRota
. OFFICIAL COURT REPORTER U. S. Desf asCT COURT CH ARLOTTt, N. C.
,+1ron - Direct 12 1l cam- up in those sessions.
2 i C Did anybody else meet with the inspectors L
30in a dditie n to yo ur s elf on the lith of January ?
4 , A It was the W e ldin g Inspectors and me; Mr.
5 , B ra dl e y may have been there. I think he was, I' m i
I
.. 6 not sure on that point.
7 I don't know whether 3ob was in that meet. -
8 ing or not.
9 C Eob Morgan?
10 A Bob Morgan, I d on ' t r e c all that; they may 11 have been there, but other than t h e. t . it was m y s elf 12 and the V cldin g Inspectors.
13 O sir; now A ll ri gh t, f ollowing along on 14 Page Two of Mr. Z wis ele r 's notes, there is a note, 15 "Diff e renc e between Ca tawba and M c G ui r e -- r u p e r vi ci on 16 l in r tille d idea that V.Is worked for Othe and had to do 17 as they were di r e c te d --a t Ca ta wb a--n o t co at M c G uir e."
18 l E x p 1 t. i n to me w he.t that reference m ean s, t
19
, .'r. Davicon.
20 /.
I don't r e c a ll what that might be referrinD 21 go, 22 O It saye here " s u p e r vi r io n in n tille d idea 23 that Welding Inspectors worked for Duke and had to d a 24 as they were directed--at C a ta wba..n ot so at M c G ui r e ."
25 A That does not ri n g a b ell in my m e mo r y.
EvtLYN $. 6(RGER OFHCI AL COURT mEPO*T(4 U. S DISTRICT COURT CMARLOTTE, N C.
Devison - Direct 13 h 1 i
i 1
O W ere there any s i g nific a n t dif f e r enc e s I
2 lbetween th e work o f the W eldin g In s pe c tor s at M c G u ir e
. 3 and C atawba ?
4 A Not th at I would say, I think perhaps the l 5 c ommunica tion may have been bette r at McGuire l 1
', 6 between the second line mana g e me nt and the inspector s 7 than they were at C a t awb a.
8 C Okay, and so would the reference p ro ba bl y 9 have been at M c Guir e the s u p e r vi si o n in s tille d the 10 iden that W eldin g inspectors worked for Duke and had 11 to do ao they were directed as opposed to the way it 12 appears on this note, which is the other way around?
13 A N o, the note is s a yi n g to me, at least, it 14 is saying that s u p e r vi s io n had in s till e d the idea that 15 Vi c i d i n t; In s pec to r s worked fo r Duke and had to do ac 16 they were directed at Catawba, not to at M c G ui r e, i
17 1 don't recc11 any s p e cific s on that point.
18 j That do e s n't ring eny b ell s in my m e mo ry.
19 O Okny, how were the c o m munie n tio n e better 20 '
ct .,: c C u i r e with the second level s up er vicion ?
21 A l
I would s ay they may be simply because 22 the concerns, of course, came up at Catawba and all I
23 the concerns d ealt with how the diff e r e nc e s between 24 s up e r vis io n and in spectors- were handled as such that 25 the inspector, his f e elin r e as a re sult of that was m y EvnvN S. Bracta
. orriciat Count stromfan
- u. S. Diste CT court CHARLOTTE. N. C.
D vir on - Direct 14 1
1- p a r c e pti on that that f e eli n g was not prevalent at l 2 M c G uire, t
i.
3[ C Were the same procedures f ollo we d at i
4 4l M c G u i rwith 1
e respect to do c um en tin g c o ns t ruc tio n 5 f d eficiencie s .in the welding area?
) 6 A B a aic ally, yes.
7 C Diff erent ma na g e m en t and people r e s p on si b le ?
8 A They had dif f e r e n t in s p e c to r s and dif f e r ent 9
management, yes..
10 C Vi h o would have been your c o u n t e r p t. r t at 11
- v. c G u i r e during that pe riod ? V. h o would have been 12 responsible for the r e vie w of n on co nf o r ming items ?
13 A y;hich period are we r ef errin g t o ?
14 C.
Take me through a couple p e riod s.
15 A I was the Senior CC En gine e r et Catawbc 16 l fo r a long p e rio d of time up until IC E l.
17 c yes,
( 18 A Mil: Starnes w t. s the Senior C i. zt M c C rir c 19 1 d u r i n t, t i t. t period.
20 2 de would 1. a v e had the r e s p o n s ibili t y 21 for revieving N CIs at McGuire ?
- 2 A Yet, other peopic would have had that 23 re s pon sibility also.
24 O What is Mr. S t r. r n e s ' po citio n now?
25 A
I b e li e v e he is the Senior C o n s t ru c ti on EvttvN S. 8tRotR OFFICIAL COURT REPORTER U. S. DISTRsCT court CH ARLOTTE N. C.
Davison - Diroct 15 6
i i
l I i 1 ' E ngine e r at M c G uir e now, I b e li e v e is his title. ;
2' O Has he ever worked at Catawba ?
I 3 /. To my kno wle d g e , no.
4 C If Wr. S ta rnes would have been the Third 5 Level S u p e r vi s o r at AcGuire--
. 6 A yes, 7 Q ---who would have been the Second L ev el 8 Supervisor in the weld' , area, if you know ?
9 /. As I recall that would have been I' r e d 10 13 u l g i n .
11 c ;,;r. 3ulgin w o uJ d haave c ccupied the po cition 12 that was c omp ar c hic to u. r . Baldwin ?
13 f, yec, 14 Q Y. h t. t j o b was that?
15 t. T e c hnic al S u ;? c r vi r o r is the po sition title.
16 l /.11 ripht, cir; he w o u l d h s. v e CJ s. l o o h a. c.
I 17 r e s po n sibili ty for r e v i e w in g nonc onforming items at
, 18 .$.'. cGuire ?
19 l
, .. Up un til 19 L1; of course. the benior 20 E n gine e r r e vie w e d--Ic t m t-L t. c l. up a little bit--the 21 N CI form us ed to be a Senior E ngin e er r e vi e w; and 22 while it had that on i t, the S eni o r E ngineer would 23 ,,yg ,,
24
/. s the pro cedu r e was r e vis e d that was 25 changed to technicci r evi ew, l
and M r. Bulein may hav4r EvtLyn S. BtRotR
_ 0FFICs4L COURT REPORitR U. S DISTR'CT COURT CHARLOTTE, N C.
D avi s on - Direct 16 1 ! done that, I d on ' t know at Mc Guir e.
I 2I Mr. Baldwin did it at Catawba.
3 C M r. B aldwin was the T e c hnic al Su p e r vi s o r t l
4 t A Yes, i
5 l c n. h o w ou ld have been the Senior En gine e r ?
. 6 Would that have been Mr. Sta rne s ?
7 A Yes, he was the Senior QC Engineer at 8 M c G ui r e for a long pe rio d of tim e.
9 O In your judgment, Id r . D avi s o n, did the 10 diff e renc e s in these mana g e m en t personnel account fo r 11 the d i f f e r e r. c e c in c o m mu ni c a tio n at k. c G ui v e ?
12 1. T he y could, that could be a f ac to r in thct.
13 C 1.11 right, sir; now I' m interected in 14 dir e c tin g your a t t e n tio n to the second half of Page T wo.
15 "In October, '90, NnC In s pec to r M c x w e ll i r.f o r m e d 16 O nvir on that M Ir are b rin gin g p ro bl e m s to hi m . "
17 Yv h e t kind of p ro ble m e did Mr. M a r vi ell
[ 18 i tell you 'F e l di n g I n s p e c t o r s were ha vin g ?
19 '
!> !! c di d n ' t go into s pe cifie r ; Le jurt etid 20 that rome of the %elding Inepectors had mentioned 21 thingc to hi m that they weren't happy about, and he 22 was lettin g me know that.
23 G W hy ?
24 A He felt li k e that maybe we rhould know 25 that and chould do, make an effort to per more atten .
EV(LYN $. B(RG(R
. OTHCIAL COURT REPORf(R u S. OtSTRICT COURT CH ARLOTTE. N. C.
D a vi s on - Direct 17 I
I i
1 ! tion perhaps to be sure that the %elding Inspectors l
2 were s a t: s fi ed with thingo.
3 I I-l e thought they might be keeping notes in 4 books, and he said, "
You might need to be aware of 5
that and make sure that you are doing what you 6
should do in terms of s a tis f yin g th e m. "
7 O But he did not have any s p e c ifi c problem 8 that he wanted you to address 7 9 A No, no a ;s e c ifi c problem or s pe cific 10 in di vi d u al .
11 C It has here, " L c. r r y , " I as sume that's you,
- 12 " felt that the M r. I, " i n e p e c t o r ; ic that referencing 13 Mr. M a xw ell ?
14 A 1 a s t u ni e so.
15 C "...had, in fact, e c li cit e d t hi c . " that 16 ci n e s that mean?
17 A v/ ell, Mr. <. a. x w e l l , ce I recall, ne Mr.
18 YanDoorn doec, wo uld be around the job, vould heve 19 free tcccer 'o
. "Il the people en the job; a r. d 1 felt 20 li k e he might be .shing i n c r e c t o r e, " it r e yeu h t v i r. t 21 any problems, l or if you are ha vi n g any problems i
22 you are not happy with, come see me."
23 l And I thought that might be an explanation l 24 ifor why they may be exp r e s cin g thrt.
25 C The use of the term " s olici t e d, " was that EVELYN $. BERGER OFFICIAL COURT REPORTER U S. DISTRICT COURT CHARLOTTE. N. C.
D a vi s on - Diroct 18 l
1 !your word?
i 2 4 I don't remember s p e cific ally, but I might 3 have used th a t word.
4 O Is that inconsistent with th e context in 5 which you were dis cus sin g this s ubj e ct with him ?
6 A No, 7 O The wor d "s olicite d, " carries with it to m e.
8 M r. D a vi s on , the i m plic a ti on that the concerns did 9 not exist other than a s a r e s ult of them being c r eatec 10 or in s tilled or s olicited by M r. Maxwell.
11 Vi a s that your inte n tz o n in the use of that 12 word?
13 A No, the way I would use that was in the 14 process of carrying out his job on site he had 15 occasion to talk with inspectors, C raf t s men, a lot 16 of dif f e re nt people; and he might ack them, "Do you 17 have any problems or are ther e any things you don't 18 like that ar en't being done right or what is going on 19 that you don't lik e " que s tionin g men, e oliciting in
- that senne.
21 And then the c o nc e rn that I had was that 22 in so d o i n g t h r. t . if that is what he was doing, he 23 might b e leaving the imp r e s sio n with th e inspectors 24 that anything the y didn't li k e , they should go to him 25 as opposed to goin g to their ma na gement, or if their EVELVN SERGER ASSOCIATES. STENOTYPE REPORTING SERV 1CE. CHARLOTTE. NORTM CAmouNA I
Davis on - Direct 19 r
l 1 l management did s om e thin g th ey didn't like, they ;
2 c h o uld go to him as opposed to c onf rontin g their 3 m an a g e m ent with it.
4 C, Y' h y s ho ul dn ' t an inspector go to the NRC?
5 A No pr oble m with the inspector going so the
. 6 NRC, but we have procedures and recourse procedure s 7 in place.
8 Of course, they should use those also.
9 Q Should they us e those fir s t ?
10 1. I my vi e w, yes, an an e mplo ye c they shou.Ld 11 use thos e avenues fi r s t. There is nothing the.t p r o v e r: ts 12 them from going to the Nn C tt any time about any 13 issue they want to.
14 C /411 r i g h t , " U n s i c a lly NCIs not cafety re-15 la t e d. " Is t la s, t your judgment cbout NCIc g en e r c lly 16 or the oner t h e. : r. '. r . '.' c x v c I l had i r. mind?
17 I. i. c I r e c t.11, I b e li e v e Mr. f.. e x w e ll said 18 th e y had gi v en him t lict of several NCis that they I
19 nd te ~
, t t !h ed to h i rz- t b ou t; r e c cll, h e. indicated 20 that a lot of them or mo z t of them were not even 21 in safety reltted crecs of the plant.
22 C O nl y one waa cited by the inspector ? _
23 Yea,
/. and I'm not po sitive on that point, 24 but as I und er stand it, as I r e c a ll it, ?. r . M ax we ll 25 may have indicated that there was only one of the Evtiva S. Beacta OFFICIAL COU AT REPOmitR U. S. Distpict Count CH ARLOTit. N. C.
Davison - Diroct 20 1 N CIs that he felt lik e a coccern might be' legitimate t
2 l ove r.
3 C Did he inve s ti ga t e that particular one?
]
4 ! A I assume that he did, he did not indicate i
5 to me when this was or a nythin g like that.
6 '
C Do you know whether his r e vie w of an NCI 7 was ever r e fle c t e d in an in s p e c tio n report?
8 A I don't know.
9 Q " Inspectors keep books--are encouraged to 10 do."
11 ,.
That was my r e c olle c tio n o f di s,c u s s io n s 12 then. Mr. tv. a x w e ll f e l t like they would keep in c.
13 bicch book a list of items they were not happy with; 14 and I b e li e v e he indicated they may be encouraged to 15 do that.
16 g g.,, h o m ?
3 ).
17 A Ec didn't in dic a te , just that in general 18 ~
this, might be a t hin g that thoy are encouraged to do.
19 ; !. c encouraccd them ?
20 '
h N o.
21 C You, La r r y. D r. vi c o n ?.
22 li N o, nobody in - p :.r ti c ul a r , just t h r.t that 23 '
practice might be encournged.
24 g Vi h o did you underrtand he .r.i g h t : b e re-25 f e rrin e to?
EvtLvn S. BERotR
_ OFFICIAL COURT REPORTER '
U. S. DISTRICT COURT CHARLOTTE. M. C.
Davier -
-!roct 21 1 .-.
I really didn't understand it to'be any 2 , p a r tic ula r i n d i v i d s. a l , just as a pr a c tic e cmong th e m..
I 3 !selver they felt that was s o m e thing that they s h ould 4 be do in g and encouraged others to do.
5 0 It says f o ll o wi n g , " Larry," you, " met with .
6 i s uper vision as a r e r uit. " As a r e s ult of .v. a x w e ll ' s 7 contact?
8 A Yes. _
9 O " Discussed Da l d wi n and Desu R o s s. "
10 t. C ha rle s B a l d win, yes.
11 ; /. n d ;d r . Ross and the First Level Super-12 vicor?
13 A yce, 14 O i, hat did you discusa about Baldwin and 15 12 eau Rose at that time ?
16 .. 1.t.ll, we di t c u s s e d wnat h r. d gone on ve i t h 17 my m e e tin g veith Mr. Id a x w e ll c r. d that we needed to 18 be sure our people und ers tood thtt if they had con-19
. cerno cr if tn t y had ite:..a they were d i s s a t i c il e, d 20 wa;L, we had recourt.c procedures in pla c e the.t they 21 could and should use.
22 C T o h <. n d l e those concernc? T hi s wat in 23 1980, did you have a recourre procedure-nt that ti m e '
24 A Yes; October of ' 8 0, may n :, t be correct 25 there.
,,__ As I r e c all Mr. M a xwell Icft in the ea rl y EvtLYN S. BERGER
. OFFaciaL court REPORTER U S. DISTRtCT Courf CH ARLOTTE. N C.
D a vis on - Direct 22 I i I j summer, 19 f. 0 .
2 C So it may have been ea rlic r ? -
{
3 A Yes, my best r e c o lle c tio n would probably 4 be that was in the s um m e r of 1980, as opposed to 5 O c tober.
. 6 C It would have been before h! r . M ax w ell 7 left as a Re sident ?
8 L Yes.
9 C And the m e e ti n g with the s up ervision t
10 ref erenced her e would have occurred in the same time 11 f r am e as your m e e tin g wit h M r. M a s:w e l l , summer of 12 'C2 or the re about s ?
13 A yer, 14 G What in the s i g nifi c a n c e of the reference 15 to Unidwin and F. o r r at that point?
16 . There ir no p t. r t i c u l a r r ig nifi c an c e there.
17 What I war t e lli n C hi rn here, tc 1 recall, it war that 18 as a r e a ult of that I m et wit h both s u p e rvi s io n and 19 the t < tdir r In c r e cie r t to be ture they underrtend 20 we had the recourre item, a r: c' If they h r. d any c on.
21 cerne about any woric to be done, that-ir the proper
~
22 procedure to f ollo w, and that they ehould f ollow thct 23 procedure.
24 O A gain, at that time you had
- recourse 25 procedu re ?
EvtLYN $. StRMR OFFICIAL COURT REPORTER U. S. DISTRICT COURT CHARLOTTr. N C.
O.vison - Diroet 23 I
1; i, Yes.
2 rl C in the nummer of '80?
3 A Yes.
4 l O Help me i d e n tif y what that wa s.
5 A We had the recourse procedure,- as I re-
~
)
q
. 6 c all, the fi r s t one came into official writing in ~1977 i 7 or 19 7 8, and it was part of the c on s t ru c tion p ra ctic e 8 book that was put out.
9 Later on it came out when the management 10 procedures came out. It came out as a corporate 11 management procedure in that book.
12 O W hen would the co rporate management pro-13 cedure have come o ut ?
14 A I don't know, I would just be guessing.
15 Q Is that the one in effect now?
16 A Yes, that one is s till in effect now.
17 C here either of those procedures regularly l ,
18 e mplo ye d as a device to voice te chnic al proble m e ?
19 A Those procedurec were known to the 20 e mplo ye e s , and they were us ed; I would have to say 21 in e f f e c tively used, for items where the e mplo ye e was l
- 22 di s s a ti s fie d.
l -
l 23 I don't r e c a ll any s p e cifi c technical issue a 24 that that wa s us ed for.
25 O But you encouraged them to use them for EVELYN $, BERGER
.._ 0FFICIAL court REP 0RitR U. S. Disf alCT COURT CH ARLOTTE. N. C.
l
D a vi s on . Diroct 24 it 1[thct purpose? J 2 A Yes.
2 ; O " S o li c it e d WIs to come to him before I !
4 I Nuclear R e gulato ry Commis sion ins pe c tion s. "
5 ,
A Yes.
6 O That i s b a s i c all y use our procedures befor e?
7 A Yes, you have the right to go talk to the 8 NRC Inspectors at any time about anythin g, but we 9 have those procedures in place, and we want you to 10 use those procedures.
11 O Okay, "At that time Bryant," the V. e l d i n g 12 In s pe c to r ?
13 A Yes.
14 O " Brought up 50 SSE item, other than that, 15 nothing." And the SSE being a s i g n i f i c t.n t d e fi ci e n c y 16 reported to the NRC?
17 A yes, .
18 C Vi h a t did he bring up?
19 >
.. S pe cific ally 1 don't r e c c11 all the d e t ail e .
20 It had to do with welding around penetratione in the 21 Reactor B uildin g.
22 During those me e tin g s the Vi e l d '.n g I n s p e c t o r s, 23 I asked them if the y had any concerns of a technical 24 natu re ; we would look into them, and if they had any 25 they should bring them u p.
EVELYN $. B(R$(R
.. OFFICIAL COURT a(PORr(R U. S. DISTRICT COURT CHARLOTT(. N. C.
D a vi s oe - Direct 25
'l 1 ;
'. n d I don't r e c a ll s pe cific ally how John 2
b r o ugh t this one up. I don't think he brought it up 3 as a concern, he brought it up as a qu e s tio n.
t 4 I don't think he even brought it up before.
5 II e brought it up as s o m e thin g he had a qu e s tion
. 6 about, and I s aid, " Vi e need to look into that."
7 A nd he looked into it. As I re c a ll it end-8 ed up being a 50.55E. a 9 MR. GIBSON: Excuse me a minute, I 10 am not sure whether he meant John Eryant, 11 the Yv eldin g In s p e c to r, or Jack Bryant fro m 12 NRC.
13 MR. GUILD: M r. Maxwell wa s the 14 R e rid ent Inspector and this was the Viel' din g 15 Inspector Bryant?
16 THE WIT NE S S : Yes.
17 18 BY MR. GUILD:
19 C Vi h a t w e. c his qu e s tio n about th6 SSE?
20 A I think he had some que s tion about the way 21 th e weld was being made or the way it had been weld -
22 ed. I don't r e c a ll s p e cific ally; but we did assign him
,. s 23 to go look into that, get the facts o n t hit .' e 24 O A nd ultimately it was written up as a 25 significant d efi cie n c y ?
EvitvN S. StrotR -
CFFICIAL COURT REPCEYER N *
- u. S. DISTRICT COURT CHARLOTTE, N. C. ,
- t. /,
D avi s on - Direct 26 1 A That is my r e c oll e c tio n, yes.
2 i Q R ela ted to a s p e ci fi c piece of welding i
3 { work?
4 A Yes.
5 Q A ga in, the reference to October, '80,
. 6 would have been in error; it would have been the 7 summer ?
3 A .A s I r e call it would ha ve been the summer 3 of '80.
10 Q Okay, third page, again I guess in the sam e 11 context, "Eeau began to develop a t titu d e --won 't 12 a c c e pt r e s olu t io n s he doe sn't agree with. Had to be 13 directed by supervisor but did c om ply. "
14 V. hat do you mean by that?
15 A R ef er rin g to the f e elin g on my pa rt that 16 l if B e a u, being the First Line S u p e r vi s o r, he vould 17 have occasion t- seek r e s olution s to NCis, and if ho
. 18 eaw one that he did not agree with we would look into i
19 l it , get bach with the peopic who wrote it, n atir f y 20 ourselves; and it was very difficult to get him to be 21 s ati s fied wi th th at.
22 C With the r e s olu tio n by the supervision abo ve 23 him ?
l 24 A To be satisfied with the r e solution an d the I 25 explanation that he would be given.
EVEL)N $ BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CHARLOTTE, N C.
D e vi s on - Direct 27 I i 1 U Q That would be the r e s olu tion that you woul'd l
2 decide at that tim e ?
3 l A No, the r e s olu tio n would be put cn the 4 l NCI by the T e c h ni c al Group th a t was assigned to i
5 resolve it.
- 6 O When you ha d reference to r e s olu tio n s ,
7 did you m e s. n r e s o lutio n s in that sense?
8 A That is the way I r e c all it.
9 O So it would have been by the technical 10 people, not by the CC individual and the o rigina tion 11 process?
12 A Right.
13 O Vhat wae M r. Roos doing when he dis-14 agreed, when he did not accept r e s olution s ?
15 I; /. gain, this ic a g e n e r a.1 s tatement here.
16 lI don't have
- z. n y c p e cific r it uc tio n c :n mind fcr Lim, 17 but if an NCI had a r e so l u t i o n , for example, that sai d
. 18 that the V. c 1 d i n g In c pe cto r chould be trained in thic
. 19 particular t. r t i. or whateve r, and h e- did n5t thinh 20 that was appropriate, he would say, "I don't thinh
, 21 that's right," and we w o uld look into that situation, 22 talk v. i t h ~ t h e people th at put it on'there, come to a
- 23 decision as to wh e th e r it was a pp ro p ria te or not; 24 and if we decided it was, it .wa s very difficult to get 25 him~ t o a g r e e ' with th at .
EVELYN $. BERGER
_ 0FFICIAL COURT REPORTER l U. S. DISTRICT COURT CH ARLOTTE, N. C.
D ovis oc - Diroct 28 l
t 1 , O V. hat was hie r e s con s ibility, if any, with 2 respect to agreeing or not agreeing with that 3 , re s olution ?
4 A V' ell, he didn't have any direct responsi-l i
5 bility for the r e s olutio n. He had r e s pon sibility for 6 c a r r yin g out the a c tion.
7 Of course, anythin g that is involved in that 8 process, if you see s o me thin g you think is wrong or 9 incorrect. I f eel he has a re s pon sibilit y to bring that 10 up.
11 Q In thic instance it is not a que e tion of 12 seeing s o m e thin g he doesn't agree with, it is accept-13 ing the r e s olutio n of that i d e n tifi e d d eficiency ?
14 A Right, as I r e c a ll this c on ve r s a tion.
15 O Is it your po sition he did not have any 16 j re s pon eibility with r e gard to the r e e olu tion ?
4 17 A That's correct.
18 G Unle s s he war directed to do c omething ?
f 19 /s T ha t 's correct, u r. l c e r he w e. s directed to 20 r e r. o l s e it zud sig n the resolution. And the e x t. m p i c 21 that c om e s to mind is a re a clution th at c all e d for 22 t r a ini n g of an inspector.
23 O Yes, how about the rituation where the 24 r e s olu tion s p e cifie d to accept weld s as is; would l
1 25 that have been an example of a s ituatio n ?
EVELYN $. BERGER
_ 0FFICIAL COURT REPORTER U. S. 0l$f RICT COURT CN ARLOTTE, N. C.
Oaviron - Diroct 29 I I. It might be, I d o n 't r e c a ll any s p e cific a.
}
'l O What do e s the reference mean "ha d to be 2 lt 3 directed by supervision," S-U-P-R, "did comply"?
4 A Y. hen he would bring the item up to his 5 s u p e r vi sio n the s u p e rvi s ion would look into it and giva 6 him an answer, and he might not like the answer; but 7 the s u pervis or w ould tell him that is th e answer on ,
8 the que s tion.
9 C A nd the s u p e r vis or would have been you r-10 s elf ?
11 A Mor e th a n likely Mr. B aldwin, but it might 12 have been me.
13 C Did you have to direct him to comply ?
14 A I d on ' t r e c all any a pe cific cases of that, 15 but it could have occurred.
16 Q A nd the n e r.t paragraph, "Charler," w o u l el 17 ch t t be a: r. nldwin ?
18 A I a s cume so.
19 R " C h a rle s made effort to get c on r t ru c tion 20 side of di c pu te --ma d e best decision--did not.compro-21 mise in favor of c on s t ru c tion. "
22 Was that in a comp ro mis e of M r. Baldwin 23 g etti n g the c o n s t ru c t i o n side of the issue?
24 A Yes, in that context it was indicated 25 C ha rl e s would make an effort to get both sides if EWELYN BERGER ASSOC 4ATES. STENOTVPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Davioon - Diroct 30 I i
~
I 1 : there were two sides to an issue, and he did not i
2 I c o m p r o mi s e any of our r e s p o n r ibili ti e s and du ti e s in 3 favor of the porition C on s t ructio n might take.
4 O And f ollowin g, " Commonly NCI r e s olu tio a 5 not worded as th e y (OC) li s t e d , but accepted techni-
. 6 cal r e s olu tion. Made every ef f o rt to obtain WI and.
7 s u p e r vi s o r vie wpoin t. "
8 1. A gain, that is just r _e f e r r i n g again to the 9 example I used before. The wo r din g "t r ain, " that 10 Iword being on the part of the a c tio n of NCI af ter the l
11 r e c olu ti on la stated.
12 T ha t word might not be a word that the 13 inspectore liked or thought was appropriate, but 14 r e main e d.
15 That might be en e x e m pi c, thct type of 16 t h i r. r .
I 17 i C I ccn un de r e t e nd t h t.t if it in training a 18 Y.elding In s p ec to r, and the c u p er vi r o r in this case i
19 ' th ou ght the Vc1 ding Incpector hed done the ri,ht t 20 t h i c ;; , h e. might dispute the r. e s o l u t i o n thzt training 21 the incpector van appropriate ?
22 ^
.. He could, yes.
23 Q "R e s olu tio n not worded as they (QC) li s t e d ,"
24 hhat would QC have to do with li s tin g - the r e s olutio n ?
25 A OC w ou l dn ' t liet the r e s olution.
EVELYN $ BERGER Of FictAL court REPORTER U S. DISTRICT COURT CHARLOTTI. N C.
Lt.v. von - Diroct 31 i
1 O How do you understand the reference here j
2 f then ?
3 A W ell, I thought that word was "like d, " a nd i
4 ithat is the way I would r e c all that r a the r than 5 [ "li s t e d. "
l
, 6 O Okay, that should be "lik e d. "
7 A It looks li k e "li s t e d , " but in th e context 8 as I recall it, it was "lik e d. "
9 O Okay, it should read, "NCI r e s olution not 10 worded as they ( O C) li ke d, but was accepted tech."
11 meaning technical support people ?
12 A Yes, the technical p e o pl e that were a s r. i g n ed 13 to resolve the N CI.
14 O "Made every effort to obtain V/ I and supe r-15 viror view ooin t. " Mould the.t mean the V. o l di n g 16 Incoector, Mr. Eoss, t y pi c ally ?
17 A Yes.
18 C Now the same page further on, "% hen CC i
IL l wa r in C o n s tr uction, it vcr CC'e job to d e t e r mi n e 20 a c c e p t a bility. "
21 How did that change; what le the signifi-22 cance of thoee notes and underlying f acts ?
i 23 A I' m t r ying . to r e c all that; I don't recall 24 any conve r s ation s along those lin e s . I do n't what 25 he might be referring to there.
EvELYN $. BERGER OFFICIAL COURT REPORTER u S. OtSTRICT COURT CH ARLOTTE. M. C.
Dcvison - Direct 32 1 Q Okay, when the OC was in C o n s t ruc tion, 2 this was before the C u ali t y Control In s pec to rs w e r e 3 placed under the Quality A s aurance D e pa r tmen t ?
l 4 A Correct, I assume it is. I 5 O When QC was under C o n s t ruc tio n--
, 6 A And it was changed and put under QA, yes ,
7 Q It was QC's job to d et e r mi ne a c c e p ta bility ?
8 A I don't know what you menn by "d e t e r mine 9 a c c e p ta bility. " It was their job to do the ins pe c tion 10 and p e r f o r tn the in s pe c tio n, th a t wao their job before 11 and le now.
12 Q K he t was CC's job with r e c p ect to accept-13 a bilit y before ?
14 /. E s s entially th e r e is no dif f e re nc e.
15 O U hat dif f e re n c e t. t e ll ?
1G /. As far as their ,i o b , the only dif f e renc e 17 ' wo u ld be the d e par t m ent they were in.
18
, , C " A f te r QA/GC needed t e c h ni c al cupport to l
19 take load off r u pe r vi s o r reddo t e c h ni c al evalut tion--
20 rnche d e ci ele n s . "
21 A I don't r e c a ll anything along th o s e lin e s ,
22 and I don't know what that might mean.
23 O Okay, what, if anything, changed with 24 respect to technical support'c r e s po n sibilitie s or rolo s 25 with regard to r e vi e wi n g c on s truction d eficiencie s ?
EvtLYN $. SERGER
.. OFFICI AL COURT REPORTER U. S. DistmeCT COURT CH A RLOTTE, M. C.
D a vis on - Direct 33 l
1e A None because of the CA or CC m o vin g int o 2 iOA part.
3 Q Tor any rearon what changed?
4 A The p ro g ram was the same; the only chang e l
5 was that a d mi ni s t r a tiv ely now in terms of hour s
. 6 worked, that type thing, that was handled in the CA 7 D e pa rt men t; whereas before it had been handled in ,
8 C o n s t ru c ti on. ,
9 C "Needed technical suppor t to take , load off 10 s u pe r vi sio n. " Was technical support needed to take 11 load off s u p er vi cion ?
12 N o,
- t. C on e t r u c tion technical support did the 13 same thin g bef ore as they did after, just as CC did 14 the same thing the y did before as af t er.
15 T he y just reported to a dif f e r e n t d e p a r t-16 l ment.
17 c; g u y,. w r. s r e po r ting for the C o n s t r uc tio n 18 Technical D epa r tm ent changed?
19
, L ..: thet time v.* h e n iC v.m t brought into the 20 04. D e pa r t ri t t.t ?
21 Q /. n y t h i n g , how was it changed?
22 A l. t that tim e it wasn't changed at all to my 23 kno wl ed ge . C on s t ruc ti on h r. s had s o m 'e o r g a ni r.a tio na l 24 changes throughout the prolact, and I could not n
1
- S dercribe all o f tho se to for ~
i EvtLvn S. BERotR l OFFICIAL COURT REPORTER U. S. DISTRICT court CH ARLOTTE, N. C.
D avi c on - Dircet 34 i
i l' 1 I. C I want to understr.nd how the organization ,
2 r e s p on si b ili t y of C on rtru c tion t e c h ni c a l support lor 3 has changed.
4 /. Ec sic ally I would say they have e s s entially 5 been the same throughout.
6 O No changes?
7 A No si gnifi c a nt changes.
8 O No changes to take load off s u pe rvi sio n ?
9 A No.
10 G No changes with respect to t e c hnic al 11 evalua tion s ?
12 t. No.
13 0 v.here did M r. Zwissler get this iden?
14 A 1 don't know, you would have to esk him 15 that.
16 l C V. c can do that, but thic it on c. note of 17 t. n in te rvi ew he h r. d with you. Yr. D a vi s o n. I' m try-18 ing to understand if you know anything.
19 /.
I cnn't reent: that, vhat h e 's g ot writt en 4
20 down h e: r e r. r n cubject we discuteed or if v. e did.
21 I don't r e c a ll w h e.t we said.
22 It docen't ring any b ell with me in te rms 23 of my die cu s sion e v. i t h him.
24 O Not only don't you recall having any such-25 discussione, it doesn't r e fl e e t a n ythi n g that you know EVELYN $, B(RGER OFFICIAL COURT REPORTER
- u. S. DistatCT COURT CHARLOTTE. N. C.
3avison - Direct 35 h i i
about the o r g ani z a tio n ? l 1 .
2 ; A Not C on s truction te c hnic al support.
I 3 ! O How about technical support?
4 f A T echnical support refers to C on s t ru c tion 5 technical support.
. 6 O Okay, so this is all in error, it does not 7 r efle c t the way thing s are?
8 .A I don't have any r e c olle c ti on, I mean you 9 might ref re sh me, and I might remember s o m e t hin g 10 about it.
11 O Okay, "NRC said too many NCIs over in-12 significant items."
13 A Vi e had R2 as they were used in othe r 14 areas th at would handle a lot of things that in weldin g 15 would be an NCI.
16 C The NEC s t. i d that?
17 A Ao I r e c all in one of their in s pe c tion 18 reports they indic a te d they thou g ht we had too many 19 in si g nific a nt NCIc.
20 Q And that wcc the source that you had in 21 mind here?
22$ A Yes.
23 C An ins pectio n report?
24 g y,,,
25 O And would this have been in the summer EvtLYN $ BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT CHARLOTTE, N. C.
Davison - Direct 36 l
l 1 'of'80 time f rame ?
I 2 A I don't r e c all whe n that would ha ve been:
3 I can't say.
4 O Did the NRC d e te rmin e that those NCIs were 5 not rela te d nec e a s a rily ?
6 A I c a rit say, that was not a d e t e r mina tio n tha t 7 the y had.
8 O T ha t they did s ay they we re not a safety 9 related ite m ?
10 A No, they did not say they were safety 11 r ela te d ite m e.
12 C Sut they did s ay they were in s ignific an t ?
13 A Yes.
14 O Or minor?
15 1: They tried to reduce NCIs by looking for 16 o the r w e. y r to handle those.
17 O V hich is the reference here; when did you 18 do that?
19 A r. r 1 r e ccli the NRC looked ct the NCI pr o-20 cees d u r i n ;; one of their in s pe c tion s i n 19 81, maybe 21 February of 19 81: and we lo ok e d a t--oka y--we may be 22 w ri tin g to o many NCIs on minor, i n s i g ni fi c a n t ite m s.
23 There may be a bette r way to handle those, 24 and that re ally wa s probably the s t a r tin g o f o u r c o n --
25 cept, hey, we have RZA that we use in ' o the r areas and EVELYN $, BERGER
_. OFFICI AL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE. M C.
.~) n v i s o n - Diroct 37 1 we ought to look at the concept of tha t.
2 C Okay, the fourth pa g e, Mr. Davison, "Can I
h 3g resolve pro ble m s , technical."
i 4 MR. GIBSON: V here are you r e a din g 5, f rom ?
i 6 [ MR. GUILD: It e m Fiv e, "F e el that 7 Task Force approach is good one..can re-l 8 solve p r o ble m s , technical."
9 10 S Y MR . GUILD:
11 G Is that the s pe cific hardware proble m s ?
12 A Yes, the technical problems would be ite m s 13 d ealin g with te c hnic al thing s .
I 14 O The s p e c i fi c n o n c o n f o r m i r. g i t e m s , s p e cific i 15 l weld e, that sort of thin g ?
., 16 l A Yes, c p e c ifi c que s tion s about NCIe or what.
i 17 ever. .
18 O Now by compa rison, "F eel the y had su pe r-19 visory p r o ble m s . " V. h o feels, you fecl?
20 A These are M r. Zwi s cle r' c notes, r. n d I 21 assume he is saying they feel they had supervision 22 problems.
23 O Did you tell him that you f elt they had super -
24 viso ry p roblem s ?
25 A Yes, we talked about the approach we were EVELYN S. BERGER OTHCIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE, N. C.
l
i i
Davison - Direct 38 1 t a ki n g to bandle thcee concerne. Of cour s e, the t e c h n i, -
1 2 c al conc e rn s were cet up one way, and we had a Taek 3 Force to work on n o n -t e c h nic al, also.
4 T ha t was what I would be ref erring to there.
5 O Did you express to him a f e elin g that you
. 6 had supervisory problems ?
7 A Yes, and what I would have been r ef e r ring 8 to was the way we handled the dis a gr e em ent that may 9 have come up betwe en s u p e r vi sio n and inspectors.
10 C " Trust and c onfidenc e at all levels, c an ' t 4
11 do job without this. He is pa rt of p ro ble m. " In that 12 r ef e r rin g to you, Mr. D e vis on ?
13 A Yes.
14 C Y ou told him that?
15 A As I recall. 1. gain, rome of the letters frorr 16 the i n s p e c t o r t, indict te d that they had l o r.t some con-l 17 fi d e nc e in me: and so I s t. w m ys elf, yes, as part of 18 that p r o bl e m.
19 O i htt did you ety to t 1. Zwiester about that ?
20 A I just indicated to hirn that we needed trus t 21 and c onfidence to be able to work together the wcy we 22 s hould wo r k, and we needed to r ebuild that; and I had 23 been a part of obviously not maintaining that at the 24 level that we would want to do that.
25 Q What did you eay about you being part of the EVELYN $. BERGER
, OFFICIAL COURT REPORTER U S. OsSTRiCT COURT CM ARLOTTE, M. C.
l Devicon - Direct 39 I
i 1 p ro bl e m, Mr. D a vi s o n ?
2 A I said that the f e elin g on the part of the 3 i W elding Ins pecto rs was that they had los t some c o r. -
4 fi d e n c e in me; and I must have done som ethin g to cause-5 that c o nfid e n c e to be lost, and therefore I.was part of
, 6 the pr oble m.
7 C He "does not know how the n o n -t e c hnic al 8 p ro ble m will b e solved." That is ref e rrin g to him, 9 did you express that to him ?
10 A 'l e a h , as I recall, you know, th e time he 11 in t e r vie we d me the Taek Force had not com ple t ed it s 12 report and all th e r e c o mm e n d a tio n s had not come out; 13 a n d I d i d t. ' t know what the outcome would be of that.
14 C The tec hnical or n o n - t e c h n i c .a l ?
15 A T he technical, I did n 't know that eithe r; but 16 I felt like a l l t h o s. e imeuer. I didn't feel like thle war 17 t. n y p r o b l e m there, the p r o ble m of trust E. n d c o nfid en c e 18 in r e buildin g that, I did n't know what m ig h t be 19 r e c o m m e r. d e d o u . of ti a t.
e 20 C And therefore hov- the p r o b le m would se 21 eolved?
22 A Right.
23 C Okay, " Fl a. s been told that W elding Ins pecto r s 24 have s aid th ey ha ve enough on La rry that he wo n ' t be-25 here long."
EVELYN $. B(RGER
. OFFICIAL COURT REPORTER U. $. DISTRICT COURT CH ARLOTTE. N. C.
D cvis on - Direct 40 I
i 1 l A It is just a hea r say comment that I heard 2 at some point in ti me , and I don't r e c t.11 w h o or when 3 or what.
l 4 O You didn't know who told you that?
5 A No, I don't r e c all.
. 6 C Did you know at the tim e you talke d to Mr.
7 Z wi s s le r ?
8 A P robably not, I m a y ha ve. ,
9 O How did you understand th at inf o rm a tio n, 10 c omm ent ?
11 n n g nin, in the s r. m e context te the letter 12 indicated, the y had los t c onfid e nc e in me.
13 l C Vr h a t did they have on you, Mr. Da vis o n ?
14 W ha t did you unde r stand that they were r ef e r ring to ?
15 .4 1 would a r s u me, and this is a n a s s umption 1 16 on whtt I had hec rd.
l 17 -
C 1 want to know wha t you under stood, that's v
18 2 11, 19 .i i had i n t e r p r e t e d t h e. t. to me, the technical 20 icsues that the y raised.
21 C w hat about you on those technic al is su e s ?
22 You are the su bj ec t of thi s, and I unde r s tand the 23 s en sitivity of this s u bj e c t, Mr. D avi s o n. l 24 It i r, talking a bout you and your job and 25 whether you will be in that job: and you ar e expressing EVELYN $. BERGER OFFICIAL court REPORTER U. S. DISTalCT COURT CH ARLOTTE. N. C.'
O tvio on - Diroct 41 1
l this t o t.t r . Zw is sler.
i i 2 i V ha t did you under s tand the Vc! dint 3 Inspectors had on you?
4 A I didn't unde r s tand anythin g o the r than what 5
had been raise d in the technical c onc e rn e and how I
. 6 ' might be involved in those.
7 C Your involvement in the r e s olution of 8
te chnical conc e rns ?
9 A Yes, my in v olv e m e nt in the concerns, them-10 ,,1y,,,
11 O In the r e s olu tion of the technical problems ?
12 .s Yes, since thr.t was some of the concerns.
13 R is that what you meant? I'm no t t ryin g to 14 put words in your mouth. I'm tr ying to under stand what 15 you meant.
16 A V. hot I me an t wac t h s. t I viewed that s t r. t e -
17 n.cnt that I h ad hea rd, whic h wL s hearsay, as referring; 18 to the fact that some of the concerns tht.t hcd been 19
, b ro ug ht up, I w a. e involved with the item t i, a t the con-20 cern wce. c. v e r , s. n d t h a t vu. s probably making reference
. 21 to ths.t f ce t.
22 C A nd that they have enough on you that you
- 3 won't be here long.
24 A That is what I hea rd, yes.
25 O W ho did you underetendthe reference was.
EvtLYN $. BERGER
_ 0FFICIAL COURT REPORTER U. S. DISTRICT COURT CHARLOTTE. N. C.
. ]
D a vis on - Direct 42 1 to what % eldin g In s pe ctor s ?
2 A No V elding I r. s p e c t o r s in pa rtic ula r, just I 3 can r e c a ll s om ebod y i r. d i c a t e'd t o me that they had ove r -
4 hea rd that c omm e nt.
5 O V ho told you that?
. 6 A I don't k no w.
7 C W ho was the comment ove rhea rd f rom ?
8 A I r e call it was o verheard f rom some V/ e l din g; 9 Inspector, but I do n' t know who in p a r tic ul a r .
10 C Number Seven, m o vin g down the page, "No 11 constraint to doing his job in OA/OC, always have 12 C on s t ru c tion pressure but never to s a c rific e quali t y. "
13 V. h a t kind of C o n s t ru ction pressure?
14 A Viell, there is always emphasis placed on 15 doing the job in a correct and timely manner.
i 16 C T hi s cost an d s c h e dulin g pressure?
17 A is e well as qualit y p r e s su r e , yer; I see all 18 three. There is pressure in a cence to build the job, i
19 ! to build it e f fi ci e n tly, to build it within schedule and 20 to build it the vsy it should be built, with qu ality.
21 Q A nd you recognize that the cost and schedul in g 22 preocure can work in an opposite di r e c ti o n f rom the 23 qualit y pre s su re ?
24 A It can, I don't b e li e v e it has at Catawba.
25 O M ell, you unde r s tand that p r o g r a m m a tic ally EVELYN $. BERGER
_ 0FFICIAL COURT R(PORTER U. S. OtsTRICT COURT CHARLOTTC. N. C.
i l
1 Davis on - Di roct 43 l 1
f i 1 that r elation s hip, the c ount e r v ailin g force f r o m p r e s s ul.r !
2 from qu ali t y , and on the other side, the pressure of 3 cost and s ch ed ulin g is r e co gniz ed in A ppendix B under 4 ene of the c riteria ?
5 A Yes, I unde r s tand that can occur or it can-
. 6 not occur.
7 O Y ou under stand that the NRC r e c o gni ze s that 8 is a f un da me nt al r ela tion s hip and p r o g ra mm a tic ally D there have to be devices maintained to prevent that 10 pressure f rom ove r comin g quality ?
11 A Y e ah, I unde rs tand that one of the key 12 points is the p e o ple that inspect the qualit y a re not 13 re s ponsible f o r doing the work, that is the way 1 would 14 under o tand NR C.
15 Q You were in the middle of an answer, Mr.
l I
16 l D a vis on; anything f urth er ?
i 17 n No.
18 C Okay, the last item on that page, "Da y to
(
19 ' d a y --in t t r uc tio ne not always cle a r --do n ' t always keep 20 serious ceroro f rom oc cu r rin g--han g e r e good ex a m ple ,
21 maybe electrical is also a p r o bl em. "
l 22 %ht.t does that mean?
t 23 A I don't r e c all s pecifically wha t they ha d in 24 mind the re.
25 C Give me what you can r emembe r.
EVE LYN $. B(RGtR OFFICIAL COURT REPORf(R U. S. DISTRICT COURT CH ARLOTT(, N. C.
Davicon - Diroct 44 i
, I 1 A %e fin d errors; that is ou r job, to look for 1 1 1 1
2 l errors, and we find them in all a r ea s . !
3 O Use this as an example of a serious error.
l 4 A I don't r ec all wha t the example may have 5 been.
. 6 O V ha t kind of s e rious errors regarding 7 in s t ru c tion s have oc cur red with r e ga rd to han ger s ?
8 A The only thing that comes to mind is one 9 ti m e with a hanger pro gram the di s cove r y wa s made 10 that some of the hanger s pe cific a tio n s from D e sign 11 may have been misinterpreted in the field; and th e 12 p r o ble m war nonc onf o r m e d an d ide ntifi ed.
13 C Vhat kind of design s pe cific atio n s for 14 hangers?
15 A It vr o u l d have been the s p e cifi c a tio n s for 16 ,the erection of the hangers.
l' 17 C V. h a t e p e c ifi c c.11 y ?
18 .A I don't recall the s p e c ific n u m b e r.
19 C I unde r sta nd that, but what type of cc sigt 20 c p e cific a tio n error?
21 A Y. hat I s aid wa s the s pe cific a tion we dis-22 covered we ma y ha ve inte r prete d that incor rectly with 23 the folks in the field; a nd the instructions for doing 24 the work-up.
25 O They we re out in backwards, upside down, EVELYN $. BERotR
_ OFFICIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTTE, N C.
D avis on - I:i r o c t 45 l .
sl I lin the wrent way, u s ed the wrong belts ?
21 A No; I would have to refer to the s pe cific s i
5 j of the p ro ble m, but some of the tolerances may have 4 been accumulated where the y should not have been 5 i a ccumulated.
. 6 Q Tole r a n c e s in the dimensions of the hanger?
7 A That type thing, yes.
8 Q % elding ?
9 A 1 don't r ec all any in weldin g, s p e c ifi c all y.
10 0 The han ge r in s tallation, plac e ment ?
11 A Lo c a tion.
12 g ye,7 13 A No, not s p e cific ally, althou gh the tolerance s 14 may have c o me in a nd ef f ec ted that, too.
15 C % ha t tolerances do you have in mind?
16 h if you have tolerances of whe r e a hanger is 17 to be located.
18 C Is that what you had in mind her e when you l
l 19 were tc1 king about in st ruction c ?
20 A Yes, that type of thin g.
l 21 O And that item was nonconf ormed ?
22 3 y,,,
23 O Did that r equir e signific ant r e w o r kin g of 24 hangers?
25 A It r equir ed re-evalua tion of quite a few EvtLyn S. BERotR
, OFFICIAL court REPORTER U. S. DISTRICT COURT CH ARLOTTE, M. C.
l 1
D avis on - Diroct 46 i
I' l
. 1 l hangers,
, yes. i i
2 O I-ow man y ?
3 A 1 couldn't give you that numbe r. I c an e s ti.
4 mate maybe in the n ei g hb o rho o d o f 1. 0 0 0.
5 O That is a pretty major problem?
. 6 A It is a large p ro ble m.
7 O Wha t tim e frame did this oc cur in ?
8 A 1981, I t hink. I don't r ec all specifically, 9 probably 1 would think maybe th e summer of '81.
10 C Okay, and the r e - e v a lua ti o n , did it r e s ult 11 g en er ally in a c c e ptin g the han g e r s as is?
12 A G ene rally fo r the mo st pa rt.
13 Q " Ma yb e elec trical is also a p r oble m. "
14 A I don't have a n y r e c olle ction about dis cus s -
15 in g elec trica l ite m s wi t h M r. Z wi s s le r. I don't recall 16 what they have r ef e rr e d to.
17 C You don't know what s e riou s problems 18 occur red in the ele c t rical a rea that would f all unde r 10 the h e a din g of la c k of clear in s t ruction s that r e s ult ed l
20 in serious errors o c c urr i n g ?
21 A None that po p in ' my mind, no. Of cou r s e.
22 we have had NCIs in elec t rical-j u s t lik e we have-had 23 in other areas, also, but none t h'a t pop out in my mind 24 there.
l i 25 O What is the mo s t s e riou s 'd eficienc y in an EvtLYN $,S(RGER-
{ _ 0FFICIAL COURT REPORTER U. S. DISTRICT court CHARLOTTE, M. C.
Davioon - Diroct 47 I
1 . ele c t ric al a r ea that c ould f all unde r the category of f
2 l lack of clea r ins truc tion e 7 3 A I don't know t h at I c ould give you a s p e cifi c 4 problem there. I would have to r e vi e w all th e NCIs 5 in the ele c tric al a r ea and see.
. 6 O Give me the best of your r e c olle c tio n. It 7 may not be a perfect r e c o ll e c tio n, and I understand 8 that; but what do you know at this time that falls in 9 that category, elec tric a l ca t e go r y, involving unclear 10 in s tructions ?
11 Is that what you s aid ?
12 /. Yes. I d on't r ecall anythin g that c o me s to 13 mind that I would tie to that.
14 I C h hat is th e mo st seriour pr oblem in the 15 , electrical trea?
16 Y. R . GI G S O N: Excuse me, M r. Guild, l
i 17 just for inf o rmation do you contend that this 18 is r elat ed to CC and C A in welding at 19 C a tawba ?
20 MR. CUILD: V hatever manner, this 21 wrs a part o f h: r . Zwis cle r 's effort in 22 r evie win g the Tack Force report, and the s e 23 are notes of M r. D avis on's c onve r e ation 24 w i t h hi r . Zwi s sle r; and the best I can do is 25 look at the n ote s as the y appe ar.
EVELYN $. BERGER OFFICIAL COURT REPORTER
- u. S. DISTRICT COURT CHARLOTTE, N. C.
D avis on - Diroct 48 i.
1 Something s pecifically listed in a con.
2 ver s a tion between Mr. Zwis sler and Mr.
3 D avi s on, I a m trying to ref re sh M r. D avis oo 's ;
4 r e c olle c tion of wha t ma y ha ve been pa s s ed 5 on to the c on s ultant.
. 6 MR. GIBSON: Is there a conne ction ?
7 MR. GUILD: I'm t r yin g to make the 8 d ete rminatio n what the co nn ec tion s are.
9 MR. GIBSON: Okay, go ahead.
10 THE VI IT N E S S : % hat is the mo st 11 eerious de ficiency I ca n r e c all ?
12 13 BY MR. G UILD :
14 O Yes, that was nonconformed ?
15 A Nothing pops in my mind ac saying here is i
16 jc c e riou s problem in electrical.
i 17 O Y ou don't remember a serious problem ?
18 A Not that stands out in my mind, I' m sure 19 th e r e have been a lot of NCle in the elec trical a r ec 20 just like other areas that v. e have id en tifie d.
l 21 I don't r e c c.11 a n y o n e r ea ndin g out or any 22 s pecific ones that have occurred.
23 Q No s e rio u s problems occur to you now in the 24 electrical ares ?
25 A The only one that I can even re c all that mig ht Evrtyn S. BtRotR 1
.. OFFICIAL COURT REPORTER U. S. DISTRICT COURT CH ARLOTit, N. C.
I
Davioon - Direct 49 c 1 come in that c ate gory is the in s p e c tion of elect ra ys, f
2 lthat is non-s af e ty relat ed ele ctr a y s.
I i
3
- Q Electray?
4 A Yes, electray.
5 O V. hat is that?
. 6 A T ha t is a form of support for cable that 7 u sually runs from th e cable tray to a piece of equip-8 ment or center of whatever the cable is going to.
9 O V/ h a t was the nature of the nonconf ormance ?
10 A The nature was that this ha d been cla s sified 11 as non-c af ety r elated; and the refore did not come unde r 12 our in s p e c ti on p r o g ra m, but it was d ete rmined that it 13 was in some way seismically related, even though it 14 was not nuclear s af et y r elated and s hould be- in s p ec te d.
15 O V. a s it inepected?
1G /. It had not been as a r e r ui t of th a t coming 17 u p, it it in the process.
18 Q Of being r eins pected ?
19 A
, I; o , it would be an initial ins p ec tion for 20 th at.
21 g y. ere the items that had been previously 22 in s t alle d in s p e c t e d ?
23 A T he y would b e, yet.
24 Q They would be r e in s p e c t e d.?
25 A No. th ey have not been in s p ec te d.
EVELYN $. BERGER l _. OFFICIAL COURT REPORTER U. S. DISTRICT court l CHARLOTTE. M. C.
D evicon - Diroct 50
- 1 ; O They are going to be inspected, they are in i
2 l place and th ey will go back and insp ect tho s e ?
3 A Yes.
4 C A nd that is a r es olution of a no nc onf o r ming 5 item ?
6 A Is that a pending r e s olution; it ha s n't been 7 c ompleted yet, the re solution is not complete at this 8 time.
9 C Eo it is a pendin g N CI?
10 A yes, 11 A: R . GIESON: Do you have anything 12 that is related to welding in s p ec tion at 13 Cctawba now?
14 MR. GUILD: I s till d o n ' t know.
15 16 :3 Y MR. G UI L D :
17 O Mr. D e vi s on, le that r e l e. t e d t o weldin g 18 I in s pec tion ?
19 i I. T hr t ir on ele c t ric t1 a r ea, I wo ul d n o t--
20 C E l e c t r e. y , E-L-E-C-T-R-A-7, is that a t rad e 21 name?
22 A I d o n ' t .t hi n k t o, I think it is just a c o mmo n 23 te r m.
24 g .Page Five, " M cybe procedures are too 25 c o m pl ex, perhaps use travelers not procedures."
EVELYN $ BERGER OFFICIAL COURT REPORTER U. S. OtSTRICT COURT CHARLOTTE. M. C.
Das.aon - Diroct 51 1 uhat is a travele r ?
2, A That is a term that I under s tand r ef e r s to h
3[a pi ec e of paper that goes along with the w o r k; and as 4 lI re c all the dis cus sion with M r. Z wi s s le r, we talked ir 5 gener al about his experiences and what he had seen and i
6 how he had s een procedures being too c o m ple x, and the 7 use of traveler s at variou s diff e r ent sites that he had 8 been a s s ocia te d wi th.
9 O H elp me und er stand how you use a traveler 10 ins tead of a procedure.
11 A W ell, an M4A, for ex a m ple , would proba bly 12 be coneidered a tra vele r. That le c omething is eued 13 and goes to the C r.a f t m a n doing the work and stays with 14 the wo rk while it is being done.
15 C How would it be identified with a procedure 16 f f the procedure is to o comple x ?
17 i A Some of the in fo r m a tio n you have in the 18 procedure may be on that traveler, or it may not be.
1 19 If you wan te d to in c ti tute a traveler to make a proce-
! 20 dure less c om ple r, that is one thing you can do.
1 21 Q Y ou have a procedure you iden tif y as too 22 complex..
23 A No, I said we talke d in gene ral about ours 24 e nd conver sations de alt to a large degree with his ex-25 periences and how he.had s e en place s where p r o c e da r e s EVELYN $. BERGER OFFIC'AL COURT REPORTER U. S. DISTRICT COURT CH nRLOTTE, N. C.
Davison - Diroct 52 I were much more c o m pl ex than ours, and he had seen 2 many pla c e s where the procedures were less complex, 3 He had seen many places where they used 4 travelers to a greater degree than we did, and pla c e s i 5 where they were used to a lesser degree.
6 Q I want to understand and I don't yet, how a6 7 traveler, say an M4A, how that would displace a pro -
8 cedure that was too c o mple x in the s pe cific or in the 9 a bs tra ct; and as an example of s o m e t hin g a c t u a lly did 10 change; if there is one, I want to unde r s tand it and 1 11 don't.
12 n V ell, we were talking about the fact that 13 travelers are used, we use them at Duke in certain 14 areas.
15 It is a c o mmo n thing used in a lot of vari )us 16 pla c e s . They would lis t s pe cific steps for the C raf t e-17 man so the C r af ts man may not have to refer to a pro -
18 cedure, in s t e a d pu t tin g it in the traveler. It would 19 make the procedure leet c o m pl e x.
20 It might make the traveler more c o m pl ex.
21 Q Uce a check list on a form such as an M44 22 as opposed to a d e t a il e d c on s t ru c tion procedure?
23 A T ha t 's right.
24 O In fact, has that been done at C atawb a ?
25 A Of course, we use t ra v ele r s 'in that contex :,
EVELYN BERGER ASSOCIATES. STENOffPE REPORTING SERvtCE CHARLOTTE. NORTH CAROLlNA
Daviso n - Diroct 53
~
l I
1 'the example I mentio ned. The dis cu s sio u with Mr.
2 Z wis sle r wa s in general te rms a bout wha t he had seen 3 jinotherplaces; and to my knowle d g e that did not resul t I
4 ;in a ny changes as a r e s u lt of that di s cus sion.
5 i O Whether as a r e sult of that dis cus sion. I
. 6 want to under s tand; subsequent to this ti me , February 7 o f ' 8 2, have you identified situations that are f airly 8 repre sented by that c omment wh er e procedures were 9 determined to be too complex and where travelers or 10 in-procese documents were ured?
11 A I' m not a w a' r e of s pecific s. Procedures are 12 c onstantly und er review looking f o r better wrys to do 13 thin g s , and there mu y have been s om e r e vi sion s wh er e 14 we incor po rated traveler e where we diNn't before.
15 I' m n o t a v. a r e of any.
16 C Okey, you ar e n o t ,r. w a r e of cny?
17 A Right.
18 C A nd the n Mr. Z wis sle r han a li' t t l e str r by 19 l the last commert e. p d t h t. t is tbc last c o m-m e n t on thore
~
20 notes, "Need to loch a t how to direct work ca opposed .
~
21 to expecting C ra f t to know all r eq uir e me nt o. "
22 Mould that be ef f ec te d 'n s a y usin g a 23 t ravele r ?
24 A Yes, I don't remember s pecifically what he 25 has written down her e, but that was in the same context EvtLYN $. BERGER ,
OFFICI AL COURT REPORTER U. S. DISYRICT COURT
- CH ARLOTTE. N C. ,!
} b. A___________._____.________...___.___t-
Davison - Diroct 54 1 a s the us e of the travelers; yes.
2 Q You are not aware of any re sulting change 3 in procedures at C atawba ?
4 A l'm not aware of any chan ge s in proc edur e s 5 as a r e s ult of M r. Z wi s sle r 's and my dis cu s sion s to
. 6 go back and put travelers in.
7 Now the Tas k F o rce, as a re sult of that .
8 e ff o rt, procedures were looked at and re vision s we re 9 made. -
10 I' m n ot awar e whether that in stituted the -
11 use of a traveler whe re the re hadn't b een one before.
12 C Are you aware of any Task Force r e gula tio n s 13 that us ed document s more in detail and t ravele r s and 14 con s t ruction pro c e dure s less?
15 A There may have been, but none pops to my i
16 mind.
17 C Ncne in th e welding area?
18 A Not that I'm awa r e of, no.
19 . O Let me get you to look at r.nother dot v ..s e n t 20 d a t e d J a nu a r y 13, 1982, a Ictter f rom Mr. R o c k holt to 21 h; r . bradley (indic ating).
22 J. C an you i dentif y that ?
23 /. Yes, that is a le tte r, like you said, from 24 M r. Rockholt to Mr. Bradley.
25 O Have you seen that before ?
EVELYN $, BERGER
.. OFFICIAL COURT REPORTER U. S. DISTRICT COURT CN ARLOTTE. N. C. l
Davioon . Diroct 55
. . ~ .
~
1 i A Yes.
l 2 l Q V! h e n did y ou see it, Mr. Davison?
3 A I don't r ec all specifically wh en the fi r s t time i
4 I saw it was. I saw this lette r in conjunction with 5 s everal othe r lette rs from V eldin g Ins pector s.
6 I think the re wer e five or six, some to Mr.
7 Mo rgsn and some to hi r . B r a dle y.
8 Q Did you see it at about the time it was sent 9 to Mr. B r adley ?
10 A As I rec all I would h ave s een it about that 11 time.
12 MR. CUILD: C oun s el, do you want to 13 take a b r e a k a n d m a. y b e we could g et a copy 14 of that f or the Witne s s.
15 ( % h er eupon, the D e po sition recesse d 16 l at 0: 55a.m., cnd reconvened at 10:08 1
17 i I
a.m.)
18 l
. i 19 BY h.1: . CUILD:
20 O M r. Davison, have you had an opportunity 21 to e xa mine the J anua ry 13 th lette r f rom Mr. Rockholt 22 to Mr. Bradley ?
23 3 y,,,
24 ME. GUILD: Let's mark that as 25 Exhibat B.
EvtLYN S. BtRotR OFFICI AL COURT REPORTER U. S. OtSTRICT COURT CHARLOTTE. M. C.
____________-_-_-__-____-_____A
D a vi s o n - Direct f
=.
I 1 ( % h er eupon, the letter da te d 1/13 / 8b, i
2 ; f rom Mr. R o c kholt to Mr. Bradley was 3 ma rked and rec eived by the Court i
4 Reporter as D a vi s o n E xhibit B and 5 enter ed into the R ec ord. ) i G
7 B Y MR. G UILD :
8 Q Now, th e 1/12 / 82, reference, the fir st para- -
~
l 9 graph, Mr. D a vi s o n, "I di s cu s s ed some of the problem s l 10 which have eff ected my job with Bob M o r ga n. "
11 T ha t wa s one of the discussions you have 12 r ef e r r ed to ea rlier ?
13 /. Yes.
14 O "I b eli e ve Bob to be r e c e ptive , but he is not 15 in a position to help. I told him I wanted to see Varre n 16 Owen."
1 17 '
M r. Owen is the Vice P re sident of 18 l C on struction ?
19 A Yes, Design and Con s tru c tion.
20 0 "He s aid he would have to inform Larry 21 Davison and M r. W ells. I told him okay, but that I 22 d idn ' t r eally wish to talk to eithe r one of them because 23 I fe el like they a re part of the problems that the OC 24 Inspectors have."
25 " Bob Morgan called C ha rlotte, but M r. W ell s EvtLYN S. BERGER OFFICIAL COURT REPORTER U. S. DIst#tCT COURT CHARLOTTE, N C.
Davioon . Direct 57
,g n
1 l, h a d lef t for A ri zo n a and Larry Da vi s on was en route 2 to C a t a wha. "
3 l " Bob inf or med me when Larry arrived, and l
4 II had to talk with him. I told Larry th at I felt he 5 was one of my big ge st problems because he had al-G l ready stated that he did not and wo ul d not support me 1
7 on the issue of our general increase, but th at he wou ld 4 8 support me on technical issues."
9 "I inf orme d hi m that according to past 10 p ra ctic e s he had not s uppo rted us, an d that I didn 't 11 f e el that he should expect me to b eli e v e he would 12 support me no w. "
13 Did Mr. R ockholt state to you his b e li e f 14 that you had not supported hi m on t echnical is sue s, 15 M r. Davis on ?
16 A Yes.
17 C Next paragraph, " Larry said th e pay issue I
18 was one ball game and would be handled in acco rdan c e 19 with the E rn pl o y e e R e c ou rs e Procedure, and any mattier 20 lof a technicht nature would without a d ou bt be handle d 21 through hi m , " m ea nin 5 you, Larry D a vi s o n ?
22 A I as sume that is what he means.
23 O Did you say that in essence?
24 A That the decisions would be handled the 25 same with all the in s p ec to r s , and I informed him it Evrtyn S. BtRatn
, orraCIAL COURT REPORTER U. S. DISTRICT COURT CHARLOTTE, N. C.
D a v i s o r. - l' i r e c t 58 I would be ha ndled thr ou gh the recourse, they would lie t 2 th eir concerns and they would be inve s tig at ed.
3 Q But k c c o r din g to the recourse, it would be 4 your re spon dbuity to handle the technical is sues ?
5 /. I would be the fi r s t step in that.
6 Q "I inf o r med La r ry that I did.not'have any 7 c onfid e nc e in hi m and wished to talk to Mr. O w e n. "
~
8 Did he so info rm you?
9 A Yes, es he says this is the le tte r that say s 10 I was on the way down there, and I did have occastor 11 to talk with him when I arrived down there.
12 I b eli e v e he told me during that m e e t in g 13 that he did not have any c o nfi d e n c e in me.
14 Q " Larry, at this point told me that it woulc 15 be done a c c o r din g to the way he had laid down, and 16 he hoped that I r e ali z e d the s e riou e ne s s of not doing it 17 thic way."
18 What did you say to him in that regard?
19 /. He had asked to see %arren Owen, and his
- 20 reason for wa ntin g to see him was the lack of cuppo 21 which he saw pay and the technical concerns as both 22 ' e part of; and he wanted to talk to %arren about it.
23 I in di c a t e d to hi m that the pay issue was 24 in the recou rs e at that time and was f ollo win g that i
25 procedure, and the technical concerns would be hand Led f EVELYN SENGER ASSOCIATES. STENOTYPE REPORTING SERVICS. CMARLOTTE. NORTH CAROUNA 1
i
Davioon . Direct 59 1 in a lik e manner, and that was the way he s h o u ld 2 deal with those things, and it would not be appropriat e 3 for hi m to go di r e c tly to Mr. Owen without going 4 through thos e steps.
5 O "La rry told me that if I didn't do as he 6 said that I was headed for real p r o bl e m s . He said 7 he watted to make sure that I unde r s tood that. " l J
8 Did you c om munic at e this to him in 9 sub s ta nc e ? J 10 A W ha t I co mmunicated was those~were the 11 proceduree we had in place and efforts to dea l with l 12 t h o s' e is su es, and he indicated he wanted to talk with 13 Warren without going through those steps, and I 14 indicated I would have to instruct him to go through 15 those eteps, that would be the way to do that.
16 It would e v entually get to V. a r r e n that way 17
- c. n y w a y , a s s umin g it wae pursued. If he chose to 38 act in s om e other manner, i.e., go to M r. Owen, 19 him s elf, on hic own; I didn't know what the conce-
- 2" quences of,that wo ul d be, but he would have to suff e z 21 whatever the y might be because they were not in 22 accordance with the in s t ru c ti on s given.
23 D a vi s on, g e n e r ally people that have O Mr.
j 24 been in hi g h e r s up e r vi s o r y p o s i tion s have expressed 25 I have an open door, come talk to me a j this p olic y, l
l E VELYN SENGER ASSOCIATES. STSNOTTPS REPOftTING SSNWEE. CHAIILOTTE. NO8ETH CANOWNA
D e vis on - Diroct 60 1
,any time if you have p ro ble m s ,
i 2 Is this co mmunica tio n to Mr. Rockholt 3 inconsistent with what I un de r s to od, people have open 4 doors and have problems ?
5 Is that a polic y you are f a milia r with or 6 is that a polic y of Duke Power?
7 A I don't think that is inconsistent. We have 8 proceduren and policie s in effect fo r h a n dli n g recourines.
9 T ha t does not preclude anyone from talking, but if 10 they are d ealin g with a n issue. the procedure is set 11 up to handlc, th a t is the way it should be done.
12 O One should understand, as Mr. Rockholt 13 was told a p p s. r e n t l y by you at this point, if you went 14 to Mr. Rockholt and since you went around proce- ,
15 dures, that you would be subject to di s cipline.
16 it T ha t you, in doing what you had in varianc e II with what you ha d ~ ocen instructed to do, that could 18 r e s u lt in s o me consequences.
19 l C Di v eiolin e ?
- # ~
- D i s c iplin e might be one.
91 Q They c o ul d fi r e you fo r it, t e r rn i n a ti o n ?
22 A They could, yes.
23 O "I told Larry I qu e s tion ed decisions that 24 had been made by him s elf and others, and I wanted
)
25 to assure ra y s e l f that people above M r. V. e ll s were 1
e m y,... .....oci r....r. r m - .. c..e = m. e. u l
D a vie on - Diroet 61 1 aware of the o v e r all situa tion. "
2 Did he c o m muni c a t e thast in s ub stanc e ?
3 /s Yes, and I told hi m I would make sure 4 the people above Mr. W e ll s were a wa re of that.
5 O T nat would be M r. Owen?
6 A Yes.
7 O Last two lin e s on the page, "I feel that 8 Larry D a vi s on 's track record proves that he do e s n't 9 deserve the trust he is a s kin g for."
10 Did he c o m mu ni c a t e that in sub stance ?
11 A In rubstance, not in those worde.
12 C "I sincerely hope that Mr. D a vi s o n will no t 13 terminate me becauce of my sin c e r e concern for the 14 problems of lack of support we in CC Y. e l d i n g have 15 experlenced."
16 "I muct r e e mpha cire the fact tht.t th e 17 s tc t e ments m a de by Larry D r. v i s o n lead me to b e li e v e 18 that my job c o ul d be in jeopardy because I don' t 19 agree with hi m. "
j - 20 Now, di d Mr. R o c k h olt communicate to 21 ta r . Ps t r. d l e y on the 13 t! ' r ela tin g to carrying these 22 concerns to management in a way inc on si s tent with 23 l your in s truction e ?
I 24 A I do n ' t f o llo w you completely on your last l 25 l part of that qu e s ti on. Say that again.
EVELYN SENGER ASSOceATES. *TSteOTYPE HEPOsmMG SERVICE. CMAALOTTE. feO8mt CAHOUMA
Lavsto - I;irect 62 i
I O F. o c k h o l t w r ote the le tte r to Bradley we ar a 2 looking e. t ?
3 .. Right.
4 O And he wrote it on the 13th af ter you told 5 him to handle these ma tter s through the recource. 3 6 and he communicated with Mr. Bradley who works out 7 side.
8 T hi s wa s n 't a recourse, was it ?
9 /. Nc, althou gh we would vi e w it as a recour se 10 and handle it as a recourse.
11 O V. n r. t I w r. n t to understand is did you view 12 this letter w ritin g to .v' r .
. Bradley as inconsistent 13 with your in s truction s ?
14 A No.
15 C W hy not?
16 /. .. gain, beccure normally in the recourse 17 you w a.:l d :; o to tne d e pa rt m ent and could go to the 18 d e p a r tm e n t.
19 ' . Fo he was sta yin g i n the department by
- 20 w r i t i r. g to ';:.
. E r adley ?
21 He w t. c doing something that had not been
/s no done in any other recoerree.
23 O If he had written to M r. Owen, would' tha t 1
24 be inconsistent with your in s truc tio n s ?
25 /. W r itin g the lette r would ha ve to be a evesva manoen ...ociares. svenome nemara senwice, em=orre. =om ca un.
De..a . r. - :roct 63 1 g d e c i a t o r. innde by Mr. Owen.
2 C 'C a s this the ;' r o c e r t he h r. d been instructo d 3 to f ollow ?
4 A No, he would liet his concerns, and we j 5 would reply, answer at the fir s t step of the recourrt ..
6 .
O How about the n o n -te c h ni c a l is sue ?
7 A Same thing.
g O And he was describing non-technical issues 9 here?
10 A IIe refere to technical issues, rn o e t l y .
11 W ha t he la talking about in hic f e elin g e 0.bcut me and 12 5. r . V. e l l r, .
13 C Is thle a proper, right way for him to 14 have done that?
15 A Ve di d n ' t think that was totally inapp ro pri ate Ifi for him to Co that, although we htd a l r e s. d y r. t r. r t e d o n 17 e wry to hendle that.
18 O V hat war your response to this lette r ?
19 /. I didn't r e r po nd ,
e 20 O You learned of thie lette r ?
21 A yeg, 22 O And you learned of a letter cloce to the 23 ti m e it was written or received by Mr. Bradley?
24 A yes, 2 C A nd wha t did you do?
emyn .. . ...ociar .. er ome n - co. c ,muma nom ennou
D avis oe - Dir ec t 64 1 t. W e ll. the le tte r s were addrersed to Mr.
2 3rrcley. He h r, d th e lette r s so we ne eded to rerpond 3 to those lettert.
4 Of course, the method we had already esta b-5 li e h ed and c ommu nic at ed to them on Janunty 11 war 6 the proper way to go about that; so as a r e sult of 7 this letter plus the fact that these lett er s may 8 indicate that there was at l e' a s t some p e o pl e confused 9 about the in s t ruc tion s they had been given.
10 Then we generated the letter f r om Mr.
11 't ell, to e . c i, of the V el din g In e pec t o r s , whic h was 12 b a s i c .t il y intended, ae I understand it, to be r e r. c o n si.ve 13 to these let t e r s as well ne to cla rif y to tny of the .
14 Vi e l d i r. g Inspectors whct the procere would be.
15 I did talk to Mr. Owen af ter me e tin g with 16 Mr. "ockholt and in f o r m e d him that Mr.
, F. o c k h o lt 17 had indicsted that he ws nte d to talk to Mcrren t.b o u t 18 it.
19 "e felt lil e both my s elf and Jim were
= 20 p e r t i r: s , thtt he did not w t. n t to go through in doing 21 that, and ou r responce to him had been that the 22 procedure o u tlin e d w ha t we w ould do, and we would 23 f oll o w that, and it would not be appropriate for him 24 to go to Mr. Owen u n til we had been through the ste ps 25 to get to him.
EVELYN SERGER ASSOCIATES. STENOTYPE RSRONTING SSRWCS. CHARLOTTS. NORTM CAROUfeA
Da vis on - Diroct 65 I
,- 1 Q What did Mr. Owen say to that?
2 A He ba sic ally e gr e e d.
3 O Did he take any a c tio n af ter your t ellin g 4 him M r. Rockholt wanted to talk to him ?
5 A Not that I am aware of.
6 O Did M r. Owen come talk to the % eldin g 7 In s pec tors ?
8 A As I say, we got seve ral of these letters.
9 O To Mr. Bradley?
~
10 A I think s o me were to Mr. Morgan also; 11 ai n d if I'm no: mis tc he n, ceveral indicate d tha t t t: c y 12 did not want to det.1 with me or Mr. V. e ll s ; and a g ciri, 13 I discussed t h t. t w i t h % t. r r e n at a later ti m e.
14 I h a d- t w o diecuttions with hi m , one wee 15 af te r the Eockholt situation, I b e ". i e v e kr. B r y s. n t 16 i n d i c e. t e d the rame thing, thet he wanted to talk to 1; :s y, c. v. e r , cndI i n d i c t. t e d to him in my opinion pcr.
18 hans several of the V eldin g Inspectore would f e el o
. 19 ths.t v t y, t. r. d I felt li k e it might be c proper wcy fo r g 20 hin to t.+, l k 8 0 the n, just to help the m know thtt he 21 was a wa: e of whet wac going on.
22 O And that is on the bacia of that 23 rec ommendation ?
24 A On the basis of that r e c om m e n d atio n M r.
E Owen cet up a time to come down to the site.
D a vi r on - Diroct 66 i
1 C And he did come down and talk to tl.e m ?
2 A Yes, he did.
3 O Now, second page of that letter, Mr.
4 D a vi s on, "R e vie w e d 4 /19 / 8 2, no further a c tion n ee d-5 ed, CNA."
6 V, h o would that be?
7 A That is Neal Alexander.
~
8 C And M r. Alexander was responsible for 9 r e vi e win g the non-technical concerns?
10 A As I understand it, yes.
11 C Did M r. Alexander ever talk to you about 12 the concerns Mr. Rockholt rais ed c onc e rnin g you 13 r e fl e c te d in this lette r ?
14 A I don't remember any discussions s p e cific a lly 15 on this le tte r. In g e n e r al I em sure we talked on 16 occarion about inspectors' f e elin g s that mana gement 17 had not supported th e m, and the point Mr. R o ckholt 18 made about my self and Jim, them not wanting to talk
! 19 to ur; but s ne cific ally thie letter. I don't reen11.
1 o 20 C Did Mr. Alexander inte rvie w you as part 21 of his process?
l 22 A Not th at I r e c all, he may have done it 23 without t e lli n g me that was what he was doing.
24 O Okay, a 12/28/81, .d o c u m e n t, can you 25 id e n tif y that (indicatin g) ?
EVELYN SERGER ASSOCIATES. STENOTYPE RSPORTNe6 SEnveCE. CHARLOTTE. feORTM CAs>MP4
Davison - Diroet 67 1 A Yes, this is a plan of a c tio n that I pre-2 pared for submittal to Jim W ell s .
3 MR. GUILD: Okay, let's mark that 4 as th e next Exhibit, please, Exhibit C.
5 ( V. h e r e u p o'n , the document referrec 6 to as six-page note of Larry D a vi s o n 7 dated 12/28/81, was marked and
~
8 received by the Court Reporter a's 9 D a vi s o n Exhibit C and entered into 10 the R e co rd. )
11 12 SY :vi R . GUILD:
13 C A nd a Decemoer 12 document that has on 14 the face of it December 12, 1981, I think we have 15 c o ta bli s h e d that it hns been misdated; and attached tc ,
16 it is a document that has the date December 29, 19 81 .
17 T hi s was id e n tifi ed in Mr. V. e l l e '
18 D e p o s ition as Exhibit Three. Can you identif y that 19 ( i n d i c a t i n g ) 't
, 20 No,
- r. I d on't b e ll e v e I've seen thtt. I may 21 have seen 1.t in some of the inf o r ma tion that was put 22 to g e th e r for me to review, but that would hav e been 23 the fir c t time that I saw it.
24 MR. GUILD: Okay, let's mark t h is ;
25 it has been identified as Exhibit Three to EVELYN BERGER ASSOCIATES, STENOTYPS HEPOsmose SesmCE. CNAIBLOTTE NOftTM CAIBOU8tA
U a e t s n ei - Direct ,
68 h
1 ! Mr. T. ells, let me get you to do this.
I 2 l You s ub mit te d to Mr. V. e l l s your pla.n ,
l was 3 and you did that wh at day?
4 THE V. I T N E S S : December 26.
5 .
6 BY MR. GUILD:
7 C The 28th of December, and Mr. W ell e sent 8' to Mr. Owen what is referred to on the cover memo 9 a s '"S u m ma r y of the A c tion V hich V, e R ec ommen d be 10 0ndertaken at C a ta wb a. "
11 is n d a tta ch ed to that le entitled, " Catawba 12 CA Pr o g ra m, A c tio n s to Im p r o v e C ommunic ation e, "
13 look through those and tell me, isn't N r. W ells '
14 plan of action there identical in all respects as a 15 typewritten version of th e handwritten pla n that you 16 c ub mitte d to him ?
17 Jurt go through end compare, if you would ?
18 A Yes, it appears to be it.
19 C So 1. ', r . Vi e l l e ' plan, Mr. V. e l l o , who was l
20 C o r po r n te C unlity u s t u r e nc e Manager at the ti m e, l'
21 his pla n wa s , in fact, your plan ?
22 A V-ell, I propos ed this t o -M r. W eli n , and h e l
23 has w rit t e n here what appearn to be what I proposed.
24 C He appears to h e. v e adopted in t o't o your M proposal s. o his own?
EVELYN 3E20E80 ASSOCLATES. STENOTTPE REPORTHeG SERvtCE. CMAALOTTS PeO8me CAmOuseA
D avi s on - Direct 69 1 A Yes.
2 O Did you and Mr. b ells heve any further 3 dis cu s sion s of thin ? You sent it on to him on the 4 2 8th, and his typewritten version is dated the 29th.
5 Did you discuss it?
6 A 1 don't re call an y dis cu s sio n.
7 O Now the la st page of your proposed plan
~
8 and the plan that he t r a n s mitt e d to Mr. Owen v e r ba ti m 9 has your o r g a ni a a tio nal and management r ecommenda-10 tion s, one, "Eceu Ross tranrfer to Oconec as % eld-11 ing I n s p e c t c, r or t r e. n s f e r to CA Tech Services Group 12 :n C h a rlo tt e (possibly C o n s t r u c ti on V, e l d i n g ) , r e plac e 13 with C. F a r r e ll, " and below it it has under the 14 heading, " H e r. s o n i n g , one, removes Eeau who manage-15 ment aees ne bloc k to c o m mu nic a tio n s . "
16 y ho in ma na g e ment were you r e f e r rin g to 17 cr seeing !.: r . Rose .e a block to co mmunicatio nc ?
18 A M y r elf and Mr. Baldwin.
19 O V. h a is .r. F a r r ell ?
20 . str. .1 a r r e 11 v t. o a V.elding In z pe c to r .
21 G In he now?
22 c. y e 3, 23 C L r. s he on M r. Beau Ross' crew?
24 A 1 b e li e v e so, although I' m not po si tiv e on i
25 that point. At that time I b elie ve he may have been
! EVELYN SERGER ASSOCIATES. STENOTYPS ASPORTING SERVICS, CMARLOTTE. PeOstrM CAROUNA i
I D a vi s o n - Direct 70 li 1
on Dill Deaton's crew at that time.
2 At one ti m e he was in Mr. Ross' crew.
3 O Vi h o r e c re w is he in now, if you know?
4 A I believe Bill D e nton.
5 O And is he s till a h eldin g In s p e c tor ?
6 A Yes.
7 MR. GIBSON: E .x c u s e me, Mr. Guild; 8 I may have been reeding from the typed 9 version.
10 You are referring to Mr. F a r r ell, an d 11 1 ree no m e nti o n of hi m there. W hic h 12 verrion are you r e c. d i n g f rom ?
13 MR. CUILD: I am lookin g at Mr.
14 D a vi s on 's recommendations.
15 .M R . G I D C O rt : The items are not 16 v e r b c t i n. becauce I war r e a d i r. g from the 17 typed, and I di d n 't f ollo w you.
18 The " replace with C. F a r r ell"
?.. r .
10 e c c> rn m e n d a t i o n did nct mahe it to
' 20 Ue11r' version.
21 MR. GUILD: It did not appear to.
22 I did not read it word for word.
23 MR. GISS O N: I' v e got a b o ut three-24 quarters of the way through and did not 25 see it, that was why I could not f o llo w you .
EVELYN EERGER ASSOCIATES, STENOTYPE REPORTING SE Rv1CE. CHARLOTTE. NORTH CAROUNA
D a vi s on - Direct 71 ,
1 1
1 Do you want him to compar e the two 2 documents now ?
3 MR. GUILD: Yes. It appears that i n 4 the only item that is not in Mr. W ell s '
l 5 le tt er that is in min e.
6 MR. GIBSON: The only n o n -v e r ba tim 7 t r an s c ri ption. that was in yours, but not in 8 M r. % ells ', the handwritten is an Exhibit 9 to Mr. D a vi s o n 's D e po sition, and the type.
10 w ritt e n one is an Exhibit to Mr. W e l l s'.
11 12 BY MR. GUILD:
13 C Now the r e c o m m en d a tio n that you made to 14 M r. % ells and what is t r an s mitt e d to M r. Owen, you 15 a a y, "C. R. Baldwin transfer to Tech Supe rvis o r, 16 RT and NDE."
17 "R e pla c e with A. E. A llu m, " and under 18 reasoning it says, "One, removes Beau who manage-19 ment sees cc block t o c o m mu nic a tio n s ; two, r e m ov e s
- 20 C ha rle s who inspectore see as block to communica-21 ti o n s . "
22 Those two r e c o mm e n d a tio n s were tran-
! 23 scribed verbatim; were they not? e l
24 A Yes.
l l
M O And did you see Charle s as a block to eveu .c . ...oeian.. .nnorm - . c.. c=. . no- c ou=4
Davison - Direct 72 1 co mmunica tion s ?
2 A Yes, I saw that and Charles had in dic a t e d 3 to me that he had difficulty because he did not feel 4 like he could c o mm u ni c a t e w ell with the inspectors, 5 that they saw hi m as a big part of their problem, 6 and that one of the o bj e c tive s was to r ee s t ablis h 7 c o m munic a tion s , if we were to do that, that might 8- be one w r- y to do that.
9 O Now that recommendation was f ollow e d, 10 was it not?
11 A basienlly, yes.
12 C i.; r . Ealdwin was transferred to Supervisor 13 of BT and NDE?
14 /. Yes.
15 O T hc t io where he is now; correct?
16 , Yet, he it T e c h ni c e.1 Su p e r vis o r over RT 17 cnd hcc some V.elding Inspector crewz r e p o r tin g to 18 him.
19 C ..nd he wct replaced with Mr. /.11 u m ?
. 20 A Yer.
21 O And M r. Allum became then the S u p e r vi s o r 22 over A: r . Ross and his crew?
23 A Yes.
24 C U p until the fi r s t of J uly ?
25 A I believe that was done in February, _1982.
EVELYN SERGER ASSOCIATES. STENOTYFS REPCHmese SERvtCE, CNARLOTTE. NOsme CAROUNA
... .J
D avis on - Diroct 73 1 Q That change of p ut tin g M r. Allum over M r.
2 Ross?
3 A Yes, I b e li e v e that was when that was done .
4 Q Mr. A llu m no longer holds that p o sition ?
5 A T hat 's right.
6 Q M r. Allum has a new job?
7 A T ha t 's correct.
8 O And M r. Bulgin has that po sition ?
9 A T hat 's correct.
10 Q The fir s t recommendation, the tr an s f e r of 11 Beau Rose, that was not done?
12 A T ha t's ri g ht .
13 Q % hy not?
14 A I don't know why not, that was, as I say, 15 th a t was just my proposal as to what could be done.
16 O Okay, did you ever get any feedbach f rom 17 Mr. Owen or from Mr. W e ll e or anyone els e ac to 18 why that recommendation was not a dopted ?
19 No, not in the termr o f no,
.. we are not 20 g oin g to adopt that r e.c o m m e n d a t i o n .
l' 21 O Did you ever come to an understanding of 22
, why that re c om me n da tion w as not a do pte d ?
23 A In some of the discussions with M r. M ella l
24 and maybe Mr. Owen. I'm not sure, we talked about 25 did we feel like we could r e e s t a bli e h the c o m mu ni c a -
EVELYN SERGER A790CIATES. STEMOTYPS RSPOftfues SSOUWBCS, CMARLOTTE. feO8tTM CA8tOUMA
Devioco - Diroct 74 1 tion s that we needed with Mr. Ross in the position ha 2 was in, and decided b a s ic a ll y we felt like that could 3 be done.
4 C So you changed your rec ommendations ?
5 A I had said that as a proposed r e c o rn tn e n t'.a t ion, 6 and t h r o u g h di s c u ssi o n s , yes; we concurred that would 7 not be done.
8 O You recommended it as a s olutio n to the 9 p r o ble m. Mr. V, e l l a agreed with your re co mmend a.
10 tion and inade that r ec o m men d a tion to Vr. Owen, co 11 you and he e.e d Jim % ella concurred.
12 Did Mr. Owen veto that re co mm endc tion ?
13 A I don't know what Mr. Owen did with that.
14 0 You knew he didn't f ollow it?
15 A I know that Mr. Rose was not mov e d, yes.
16 O so you know N' r . Owen did not follow the 17 r e c o m m e n d :. t l o n , or did you underetted t h t. t some-18 body vetoed it and not Mr. Owen ?
19 -
I did n't knov.
20 C' I vc a n t to k n o v- wh t your understanding i t: ,
21 Mr. Davis on. T he y did not transfer you or fi r e you?
22 1. No.
23 0 They did f oll o w one of your r e c o mm e nd e -
(
24 tio n s, and that was r emo ve f.'. r . Baldwin and b rin gin s l
l l 25 y, Allu m over th e re; yet Mr. Ross remain s and h r. s EVELYN SENGER ASSOCIATSS. STSNOTYPE pePostTING SERvCF. CMAHLOTTE. NORTM CAHOUNA
Dcvison - Direct 75 1
remained.
2 Of course, Mr. R o s s hi s to r y, we have gon e 3 through the ha s sle with your Deposition ofMr. Ross' 4 recourse and concerns that he had been r e t ali a t e d 5 against for exp re s sing non-technical concerns; right?
6 A Yas.
7 O You s till supervise hi m , you deal with Mr.
g Rosa f r equently ?
9 A Vi e l l , not f r eque ntly, but he is in the 10 organization that I'm responsible for.
11 C All right, I want to understand, you made 12 a r ec ommen da tio n that he be removed as pa rt of the 13 c olu ti on to thie pr o ble m back in December, and he 14 wasn't.
15 I v t. n t to understand, .Y r . D a v i s o r. , is your in 1cch cf cu riori ty din tin c t enough that you .i u s t do not 17 CLic thout this ?
18 A N o, I would describe it to you--this
^19 occurred ir De c e mbe r ir vhen I cent thic; D e c e mb cr .
20 e s. r l y Jnnut r y, '82.
21 Of course, at the same ti m e there v as a 22 technical concern being raised, and the Task Force 23 was being e r t a bli s he d ; and so ba sic ally my 24 r ec om me n da tion e before the fi r s t Task Force had 25 fi ni s h e d their report was e s s e n tially just let's think I avstvm sanoen Associates. sismotype napoemne senwice. cuantorts. Nomw cA%UNA
i l
l Davioon - Diroet 76 1 of what we ccn do based on what we understand.
2 And we know now, and as things de ve lo pe d 3 these were never taken as my understanding--go do 4 this and go do t ha t --it was never discussed in that 5 li g h t as thin g s d eveloped there would be another Task Force to look into the concerns and r ec o m m e n da tion s .
~
6 7 These were pr e m atu r e at that tim e, if you
~
8 will . T ha t was m y under standing o f it.
9 C S pe cific all y u ith respect to hi r . Ross and 10 the tr an sf er, how did you understand the decision wa s 11 reache1 not to f oll ow that r ec omm endation ?
12 A I recall d i s c uss i o n s with Wr. W elir and 13 m cybe Mr. Owen ti c to wh e th e r or not we felt like we 14 could rebuild the communications that we needed to 15 have, war te d to have vri t h Mr. R o e. s in thit porition 16 becauce, 1, at let.s.t. viewe d hi m as a tiock to 17 c o n n' u r. i c t. t i e n t in that a r e r. , t. n d we f c it 1: L e we I
18 could.
19 ri Did you to your knowledge or a n y o r; e (Ire 20 in fo r m '.; r . Rote of this r e commen dation ?
21 A Not to my huowledge.
22 O You didn't a n y, "Mr. Roon. I've recommen d-33 ed ths.t you be tre nsf erred because you tre a block 24 to' c om munic a tio n s ; is there anything you think we 25 could do about this to avoid that ? "
EWELYN SERGER ASSOCIATES. STSpeOTTPE REPONTwee SERVtCE. CMARLOTTE. DeONTH CAmouMA
D avi s on - Diroct 77 1 A No.
2 C Did you ask Mr. Ross whether or not he 3
felt c o mmunic ation s could be im p ro ve d ?
4 A A gain, the Task Force looking into the 5
technical and no n - t e c h ni c al was in process; and I 6
, didn't discuss those it e m s with him about what he 7
s ho uld be doing or s ho ul dn ' t be doing in regards to 8
what that outc om e should be.
9 C Mr. Ross filed many technical and non-10 technical concerns; did he not?
11
/s I understand he did, yes.
12 C More than a hundred?
13 I. I don't know the exact number.
14 O W ell, you und er s tand he is the only super-15 vicor that is lis te d a mon g s t the W eldin g In s pe c to r 16 concerno; and to him there arc attached over n hundr-ed II te c h ni c al concerne?
I8 A 1 know that in f o r m ation in that he tu r ne d I9 in a lot cf :cchnic:1 concerne. There were threc
. oo
~
r,upervitorc at that ti m e they may have tu r ne d some 21 in to.
22 1 don't r e c all . I didn't take those con-03
~
cernc, my s elf; andI didn't go th rou gh the m, th e Tas k 24 Force did.
25 Q That is your area of r e s pon sibili ty ? You EVELYN SERGER ASSOctATes. STENOTYPE REPOftfwee SEstv>CE. CHARLOTTE DeOstTH CARouMA
D avi s on - Diroct 78 l 1 understood Mr. Ross was the source of a large numbe r 2 of technical concerns? .
3 A Yes.
4 O And you did not understand the other 5 supervisors fil e d technical concerns?
6 A 1 understood they may have had som e.
7 Q Mr. Ross filed those concerns af ter you
~
8 made your December r ecommendations ?'
9 A He was in structed along with the W eldin g 10 In s pe c to r s to writ e those down.
11 O A nd he did?
12 A yeg, la C Did his filin g those technical concerns 14 contribute to im p r ovin g the communication that you 15 saw him at a block to ?
16 A In this sence, in the sence that he had 17 the concerns a r. d the concerne had not been addrese-18 ed s a tis f ac to rily in his mind, and to the extent that 19 they come out and get addressed, yec; I think the.t 20 helped.
21 O So you encouraged him to express those 90 concernc? -
23 A I wouldn't say that I ever spoke s p e cifi c a l ,y 24 with him about that in that time pe riod; but I cer-25 tainly would not dis cou ra ge him from doing so.
EVELYN BERGER A$90CIATES. STENOTYPE IREPORTWe6 SERyeCE. Ce4ARLOTTE. P90ft7M CAROUNA
D avis on - Direct 79 1 Q Naw Mr. V. e ll s and his communication 2 with Mr. Owen s tate s on the fir s t page, " Task Force 3
findin g (a s sumptions on my part, I have not seen 4
r e po r t), " and it goes on, "No evidence of una cc e pta b le 5 work b ein g pa s s e d, " et cetera.
6 Now that language was yours; was it not?
7 A Yca.
~
8 O V er batim ?
9 1. Yes, on my proposal I had a s su mption e on 10 my part.
11 C So it was you who was s a yin g that the 12 Task Force fi r.d i n g s that are set out there were 13 a r e um ptions on your part?
14 A T ht.t is wh a t I meant when I wrote this.
15 y e 3, 16 O Ohn3, a. n d t h .t wc> true for you, you jurt II h r. c n ' t teen t !. s r e. p o r t a. u d those were your assump-I8 tion s ?
19 2 T h e. t ' s right,
" ao L Ard tc r . E ells, to tLe e x t e r. t that he w :2 3 "1
a do p tin g those, was a d o p tin g your a .; s u m p t i o n e ?
04
- . I would a e sume so, yes.
03 Q Do you kn ow whethe r he had seen the 04
~
report?
U A I do n't know.
EVELYN BERGER ASSOCIATES STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CA8tOLINA
_ - - - -~ -
Dovicon - Diroet 80 1 O The report did not exist at the time; l
2 correct?
t 3 A I don't think it did, I don't know. I don't 4 remember the date of that report.
5 O W d l, in fact, at the time of the Task 6 Force we are talking about is Task Force One? '
7 A T ha t's correct.
8 C Not the Task Force that carried on its 9 work through the spring of '8 2; i s that right?
10 A Right.
11 O to the Task Force report in the December 12 Tack Force may or ma y not have been a v aila b l e to 13 you at this tim e ?
14 A 1 do n' t know whether it v. a s or not, it was 15 not a v aila bl e to me.
16 O All right, fine. Fe what war :he barie for 17 vour a s e ump ti o n cbout the. conditions of the Task 18 Force, th e fin ding s of the Task Force that you ha dn't 19 g ,. e n ?
- 2" /. My no re s sment of w h s. t the problem wa s, 21 wha t the situa tio n was as well u c the fir s t Task Eorc e 22 did in te rview me.
23 C Did t h ey t ell you that was going to be their 24 f i n'd i n g a ?
25 A No, I do think when th ey c om ple t ed the evetv u.a. ..sOCiAr... .rs=Ow n - RVICS. CHAmum . nom CAROUNA j
D a v i s'o n - Diroct 81 1 int e rviews at Catawba they had a session and my 2 memory is fuzzy as to who it was that was there.
3 and they indic a t e d sorae of what they h a d', ; s o m e; of 4 the responses they had gotten in th eir' . in t e r view s 5 f r om the people. ,
6 I don't r e c a ll them saying here is what 7 our fi ndin g s are goin g to be.
8 O Okay, now a number of the W eldin g 9 Inspectors i de ntified you and M r. W ells as part of 10 th e problem.
I 11 In short, th e y used those worde in cub-12 stance or c o m muni c a t e o that f e elin g ?
13 A Yes, I b e lie ve Mr. Rockholt did.
14 Q Other % elding Inspectors held that same 15 vi e w or communicated that s a m e. . vi e w, di d n ' t they ?
f, 16 4 At I r e c all, one of C e 'other lette r s , ther e
/ /,
17 were about six lette r s all totc!; and I d o r; ' t r e c all 18 how many may have said t h a t, o r implie d' tha t.
t 11' That would be the li n e i s of m y knowin g 20 thug, ,- j 21 C The l e t t e' r s b .
M 1 d o n ' t> r call any othe'r inspectors that
,A
~
23 eaid that to me ~ or l'n di c a t e d- that.
24 C What l e t t e r ca are you t'a l ki n g about. M r.
1 e 25 D a'v i s o n ?
EVELTN et RGER A830CIATES.
STtNOTYPE REPORTweO SERVICE. CHARLOTTE. NORTH CAROUNA
.) '
E .#
'd_.__._____________________________________._____._____ _ _ . _ _ _ _ _ . _ _ _ _ _
Davison . Diroct 82 1 A W ell, you had the le tt er f rom Mr. Rockhol ;
2 to Mr. Bradley.
O Q You are t a lkin g about the other letter s to 4 M r. Bradley and Mr. Morgan?
5 A Yes.
6 O And the handwritten concerns, a nu mb e r of 7 them expressed the same sense, that Mr. D a vis on 8 and Mr. V. e ll s are part of th e. pr oble m ?
9 A I didn't read those, we passed those to the-10 Task Force, 11 Q Did you have the general o b s e r va tion that 12 perhaps a aumber of s u p e r vi s o r s held and c o m mu ni-13 c ated the view you and Mr. W e lls w e r e, part of the 14 p ro ble m ?
15 A It is my under s tanding t h s. t some V elding to In c p e c to r r ; I don't know of any s u p e r vi s o r t .
17 C Mr. Roee?
18 A I don't r e c a ll him ex pr e s sing that to me.
19 and I don't r e call thct, al t h ou g h he may have done 2" so in his concerno; I don't know.
21 What I'm t r yin g to say is I don't think 22 that war the Eeneral consensus of the whole group of 23 in s p e c to r s , although there were some inspectors, 24 o bviou sly, that felt that way.
25 O Some did and some communicated that feel o EVELYN 38RGER ASSOCoattS. STENOTYPE REPO8tTING SERweCE. CMARLOTTE. NORTM CAmoupsA
Davison - Diroet 83 1 ing?
2 A Yes.
3 O Sho rtly af te r those concerns were express-4 ed Mr. Vi e ll s was re plac e d as Corporate Qu ality 5 Assurance Manager by Mr. G rie r ?
6 A Correct, yes.
7 Q You r emain e d in your job?
8 A Yes.
9 Q Did you ever have any discussions with 10 any management about your transfer or change of 11 po sition ?
12 A No.
13 O No one ever sat down with you r. n d said 14 M r. D a vis on, are you a part of the p roble m, or IT' words to that effect?
16 !. No, not that I r e c a ll; no.
17 Q Did you ever tnik with M r. Owen about la Iyour role as being part of the problem, or not?
l
~
l 19 /. No.
2" C Did he ever inte r vi e w you during thic 23 period of time on the subject of those concerne?
~
A No.
23 Q M r. Baldwin was traneferred s ho r tly there -
24 , g g , ,7 25 A C or re ct, yes, he was; the crews under hirt EVELYN DE AGER ASSOCIAftS. STSNOTYPE mapORTING SGIMCE. CHARLOTTE. NORTM CAROVNA
..j
D a vi s oo - Direct 84 1 were switched.
2 C As you r eco mm end ed, he got t. new job?
3 A Yes, it is very simila r to th e job he had, 4 it was more just a lateral s wi t c h.
5 O V/ h y do you b e li e v e that you, Larry 6 D a vi s on , were not changed in your po sition ? V/ h y do 7 you b e li ev e that you stayed in your job, M 'r . D a vi s o n "
8 A I don' t know that I have any belief as to 9 why I s tay ed in my job or didn't. T h e. t was c e r tainly 10 not my dectrion to ta n k e .
11 Q That is true, but I want to know w h r.t your 12 u n d e r s t e. n d i n g wr a. You survived; the Vi e l d in g 13 Inspectors id e ntifi e d you as pa rt of the p r o bl e m.
14 A If you are talking about s u r vival, I don't 15 think, that la not the way I would see it at all. I 16 don't think stryival would be a term that would 17 dercribe any of wha t was done.
18 Q Y ou remained in the same p o sition that yo u 19 h e '. d before, in i t. c t , you were promoted th e r e s it e r,
- 20 were you r. o t ?
21 A No.
22 You lef t Catawba and went to be in c h a r ;; c O
23 of Quality Assurance for all the proj ect ?
24 A N o, that occurred in 1981.
25 C You retained the p o sition you h el d ?
EWELYN SEROta ASSOCIATES. ST50eOTYPE RSPORTWee SemytCE. CMAmLOTTE, peOstfM CAmouMA
__ ___ _ _ _ _ __ _ .___._._______..__ ______ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ . . . _ _ _ _ _ _ _ ________.__._a
1 D a vi c on - Direct E5 h
1 A C or re c t, yes.
I 2 C A nd we have discussed the fact that you
'3 came to understand very early in 1980, that you 4 understood the V elding Inspectors held the view that 5 you had been involve d in enough pr o ble m s that you 6 would lone your job, or words to that ef f ect ?
7 a In 1980, no.
8 Q T hat was the dis cu s sion we had e a r li e r, 9 Li r . D avis on, about you h a vin g the hearsay c o m m e. n t to communicated to you about V, e l d i n g Inspectors?
11 e That occurred during'the time f r r. m e of 12 the D ec embe r, '82, ' E 1, January, '82.
13 C' .411 right, cir; that ca me to you, you came 14 to understaad that a nu mbe r of W elding In s pec to r e 15 held you and Mr. V. e l l s were a part of th e proble m ?
16 T hti it what I went to know.
17 i /. n' mber o'. inspectors felt--I never had 18 any p r o bic m et all in my f eelin g s of what I had done 19 or in :r y understanding of w h ::. t Vr. B a l d wi n hec done .
- 20 I never f elt I h e. d done a n ythin g that w ou ld 21 require that, although I felt we had a co mmun te ntion 22 p r o l,l e m , o k. v i o u s l y ; and we needed to be cbic to work 23 be tt er h a n dlin g dis a g r e e m e nt s :nd buildin g trert with 24 th e people the.t were inspectors.
25 Q And you admitted e a rli e r you raid to M r.
EVELYN EERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
l l
Davicon - Diroet 86 i Zwi s s le r you were a part of that p roblem ?
2 A I was a part of the c o.m m u ni c a tio n problem .
3 O And a number of p e o pl e changed jobs over 4 this ?
5 MR. GIBSCN: I object to the form; 6 I don't think that was a form of c o r r e c tiv e 7 action.
8 I object to your c h a r a c te riz a tio n.
9 10 SY MR. G UILD :
11 Q Your recommendation was Mr. B a l d win 's 12 job be changed as an a c tio n to improve communica-13 tio n s ; and that occurred.
14 'It is my characterization that Mr. M ells '
15 po s iti on changed, that is my c ha r a c t e ri z a ti on.
16 You r e m c. i n e d in that p o s itio n, and I want to under-17 etand, Mr. D a vi s o n, if you have an o pinio n, if you 18 have an u nd er s tandin g of why one of the s olu tio n s to j 19 ety to im pr o ving c o m muni c a tio n e , did not involve i
20 r e m o vin g Larry Davison.
l 21 I want to know if you have an opinion or 22 und er s tandi. 2 of why.
23 A I c e rt ainly did not include that in my l
24 r e c o m m e n da tio n s .
M Q That is understandable.
EVELYN SERGE R ASSOCIATES. STENOTYPE REPORTINC 98RvtCE. CMARLOTTE. NORTM CAROUNA .
Davison . Diroct 87 1 A And I don't know that the people I worked 2 f o r, I don't r e c a ll them talking to me about that.
3 That is my unde r s tanding.
4 O A nd so that was just never considered as 5 far as you know ?
6 A As far as I know.
7 O By other than the V< e l d i n g Inspectors, who 8 communicated that view ?
9 A By other than the hearsay comments that to I had heard, 11 Q And then I' v e seen at least one communi-12 cation, that is when M r. Rockholt expresses that 13 view, 14 A He expresses th at he does not want to talk in to me or hr. V.elle; I d on ' t know v hethe r he express ed 16 thet I ehould r. o t be in my job.
17 C .S o na e Y eldin g Inspectors etated that you 18 ought to be removed.
19 .. I hea r d the comments that they had onough 2" on me thAt I wouldn't isst long.
21 C % e ll, what I want to understand i st why 22 l d on 't you think that m o vi n g you was part of that 23 s olu tion ?
24 M R'. GI BS ON : Mr. Guild, we have 25 said that four tim e s. li e told' you what hi s SWELYN SEE .8R ASSOCIATES. STfMOTYPt REPO8rTtNe eenvlCB. CHARLOTTE. DeORTH CAftOL48eA
D avi s oo . Diroct 88 1 understanding was, and he can answer it i 2 again, but we are going around in this _
3 same circle c ontinuou s ly.
4 Do you have any other un d e r s ta n din g ;
5 please explain wha te ve r your u nd e r s t andin g 6 is to Mr. Guild ?
7 THE VI IT N E S S : I don't have any 8 unde r s tandin g as to why I was not moved 9 or wa s that considered, I don't know.
10 ( V/ h e r e u p o n . Mr. Guild s pent f rom 11 11 o ' clo c k to 11:0 2 a.m. l o o kin g for 12 do c u ni e n t e . )
13 14 BY f4 R . GUILD:
15 Q A ll right, sir; this in a document that 16 bne been identified in an e a rlie r D e p o r. i t i o n e r. r. o t e s 17 f r om : r.. D r y r. n t.
18 He is a V. e l d i n g Inspector, isn't he?
~
19 A Ycr. ,
i l 20 C Have you ever seen thore note s. bef or e ?
21 /s I do n' t . belie v e I have.
22 C Now, some of th e s e may have been in the l
l 23 concerns?
24 A l y e ,, , ' sir. But on th is f o r m' here I've not 1
25 seen those. I b elie v e you showed them to me in the
' 8WS4VN BORGER AG90CIATAS STENOTYP5 RGPOWTING SERY CE. CHAMLOTTE, NORTM CAROussa
D ovi s on - Direct 89 1
1 e a r lie r part of the D e po sition.
2 O A ll right, sir; on that second page that 3 you are lookin g at M r. Bryant has s o me qu e s tion s ,
4 and we may have looked at some of those, and one of 5 those qu e s ti o n s , Mr. Dryant includes, "W hy wa s 6 C ha rle s B aldwin removed as CA welding S up e rvi s o r; i
7 is A rt A llu m q u ali fi e d to e ff ectiv ely over s e e th e CA 8 P ro g r a m; why wa s Beau Ross overlooked for this job i 9 position; should not Larry D a vi s o n and Jim W ells also 10 be removed f rom their po sition s ? "
11 ,, r e you aware that kr. Bryant h eld that 12 o pinio n or raised those que s tions ?
- 13 A Seeing this in the D e p o s iti on, I' m aware of 14 I was not aware that he had made those s t r. t e -
it.
1 15 ments.
16 G i on were not aware that he held that vi e w II st the time ?
18 A No.
ID Is.n't it a fair c he rc c t erinatice, Mr.
C
. .>o Davicon, that the rumore that you had heard, the 91 hearsay inf o r m e tion that h46 came to you was born 22 a out by a number of ex pli ci tly exprested concerne,
~
a3 f ew of which are documented before us right now; 94 and that is t h s. t some W e ldin g In s pe cto r s thought that 25 or Larry Davison your head ought to be on a pic tte r, EVELYM BERGER ASSOCIATES, STENONPS REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
C avis on - Direct 90 I was a part of the p r o bl e m, and that you and Mr. V, e l ls 2 ought to be removed?
3 A I am aware of the hearsay that I heard 4 just g en e r ally, that they had enough on me to get me ,
5 that I wouldn't be around long.
6 O Yes, and you are aware that other W eldin g 7 In s p e c to r s expressed concern about you and your job 1 8 A Some of the concerns that I heard wce 9 p r o ble m s with the decisions I had made. I knew I 10 had done my job to the bect of my ability.
11 %e welcomed this c o min g out where it 12 could be dealt with so that if people ha d thoc e kinds 13 of f e elin g s and concerne they were not fu r ni s hin g the n 14 and d e a li n g with th em and g e t ti n g them r e c o1v e d.
15 V. e recognized, obviously we hcd come l'i c o m munic a tion s p ro ble m c , Leccuee we felt whrt we ha d 17 one was appropriate and right, and th ey had concern t .
18 over it so we had not c o mm u ni c a t e d well enough to 19 w he re they did n' t have the concerne.
20 C 1; o we get b c. c h to this lin e o f inquiry 21 a g a in, h: r . Da vi s o n. You agreed thct you were part 22 of the co mmunie ntion s problem ?
23 /. T ha t 's right, w e ll, I agreed that t lot of 21 the c o n c e r n t, or some of the concerne that d ealt with 25 it e m s where I had been invol ved with an inspector an d Ev%YN SSRQtR ASSOCIATES. STENOTYPt REPORTING SERVICE. CMARLOTTE. PeORTH CARouMA
D a vi s on - Direct 91 1 I felt pe rf e c tly comf ortable with all of the decisions 2 I had m ad e, and that obviously I had not donc perhap s a what I should have done in being sure that they were 4 s a ti s fie d.
5 Q You identified hi r . Baldwin as part of the 6 c om munic a ti on p ro bl e m and recommending action to 7 remove hi m from that po sitio n.
~
6 A Yes, Mr. Baldwin made the statement he f
9 had c ommunic a te d with the inspectors during that 10 ti m e.
11 O So he concurred and the r e s ult was you 12 removed D aldwin ?
13 A Yes.
14 Q The inspectors had a similar concern abou t 15 you, Mr. D a vi s o n.
16 j, yee, 17 C A nd you chare in come r e s po n sibility for 18 the c o mmu ni c a tion s problem. You r e m ain ed in that 19 job now, I precume, and t h t. t is rn y p re s u mption.
2" You did s om e thi n g to address your co n t ri-21 b u ti on to the communication p ro bl e m, and it was not 22 changing jobs; so what did you do Mr. D a vis on , to 23 change how you did your job?
24 A VJ e asked ou r s elve s qu e s tion s why would 25 this com e u p; why would people feel that way; why EVELVN SERGER ASSOCeATES. STENOTTPE REPORTING S$5fvlCE CHARLOTTE. NORTM CARQUNA
D avis on - Diroct 92 1 would they have those concerns?
2 And, of course, the Task Force'was deal-3 ing te chnically with the r e s olution. %e were not 4 involved, it is my view we s houldn ' t have been involv ed 5 in that; but we looked at what are the things that we 6 need to be doing to avoid this s i t u a t i o~n occurring l ,
l 7 again.
8 And that is some of the things I recommenc.-
9 ed. I did not recommend that I be replaced as part to of that; I felt we could look at that and ler rn from 11 that and co that in auch a way that it would n ' t.
12 O I see the r e co mme nd a tion s that you have 13 and we have now a vaila ble to us the r e co mm e nd a tion s 14 of the Task Force and what has been done to imple.
15 ment this; and we talked a lot about procedure m changen as w e ll, but I want to focus on what is not 17 a v a ila bl e to me an d that it what, if any, changer 18 did you, Larry D a vi s o n, undertake that r eflected you r 19 und e r e ta ndin g of your c ont ribu tio n to the c o m m u r. i c a -
20 tion p roblem ?
21 A I think, of course, the recommendations 22 of the Task Force were that we e xa min e and look at 23 a lot of these areas, and we did that and looked at 28 how do we handle disagreements; what procedures do 25 we have in place for recourses; how are we g e t tin g EVELTN SERQtR ASSOCIATES. STENOTYPS REPONTING SERvfCE. CHARLOTTE. NORTH CAROUNA j
Davison - Direct 93 1 input, both input f rom inspector supervision and inpu t 2 to inspector supervision and procedures, how they 3 are d e v elo p e d, what their intent is; what they are 4 t r yin g to a c c o m pli s h.
5 We looked at just how many c o m mu nic a tio n a 6 o pp o r tunitie s to talk and express concerns do we 7 have. %e looked at all tho s e areas and recognized 8 that a ll of those may have contributed to it, and we 9 could do some t hi n g s that would prevent us f rom 10 g ettin g in that situation again.
11 Q Focus, if you can, Mr. D a vi s o n--I want 12 as complete an understanding as po s sible, aside from 13 the t hin g s that are documented in the Task Force 14 r ec om m en da tio n and the procedure changes we have 15 talked about, is th e r e anything I should understand 16 that represented a change in the way you, Larry 17 Da vis on, did your job 7 18 A No, o nl y again, this is probably document < -
19 ed in part of the t r ainin g that we did. I r e ali z e 20 much more clearly when we get into an area where 21 there is a di o n g r e em en t we need to be very careful, 22 e e p ecially the in s pe cto r s , but everyone concerned
~
23 has the chance to express their o pinion s and resolve 24 them so they can communica te.
25 Q Mr. D a vis on, were you ever counseled abo ut EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERWCE. CHARLOTTE. NORTM CAROUNA
___ __ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ . _ _ _ _ _ . _ _ _ _ . _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.______._______________.__J
i Davison - Direct 94 1 the need to change or improve your wo rk pe rf or manc e ?
2 A Of course, part of m y --I am evaluated like 3 everyone els e, and we go over areas that involve my 4 p e r f o r m a n c e --I have had sessions with my super-5 vision as to how I'm i m p r o vin g.
6 O That is what I want to understand. %ere 7 you ever evaluated on the way in whi c h you perform-8 ed your job and required to take corrective a c tion ?
9 A C e r tainly as part of the r e co mm e ndation s 10 of the Task Force we looked at the various s p e cifi c 11 r e c om m e n da tio n s and gen er al r e c omm en da tion s as to 12 what we should be doing, and that, in a sense, is 13 the r e c o gnitio n we were not doin g as well a s we 14 should have been doing.
15 As far as s p e cific ally sitting down with 16 my supervisor and saying here is your c oun s elin g 17 s e s sion over this, no.
18 C For e xa m ple , in Mr. Ross' case you pro-19 duced document e r e ficctin g hir recourse and in c lu din g
- 20 t h ,e part of the r ubj e ct of that recourse, whic h was 21 his evaluation; correct?
22 A Right, 23
! C Now b e ginning at the end.of the year I 24 b eli e v e you told me that the c o m p a n y, I think, 25 in s titu t e d this new management, Pe r f o r ma nc e Manage.-
EVELYN SENGER ASSOCIATES. STENOTYPE REPOfrTwee SERV 4CE. CMARLOTTE. feOftTH CAROLINA
Davis on . Direct 95 1 ment Pr o g r a m , which in clu ded an evaluation of the 2 e mplo ye e by s up e r vision and a g r e e m ent or s p e ci fic a -
3 tion s of o bj ec tiv e s for improvement: correct?
4 A Yes, the PMP which is the worksheet 5 which sets out o bj e c tive s and there may be areas 6 where improvement is needed, there may be areas 7 where more a t t e ntion is focused.
8 There might be a new area that you are 9 going to s ta rt into. My point is it is not s p e c i fi c a 11' r-10 just s om e thin g that needs im pr ov e m ent, but that 11 c ould be on there, too.
12 O If the need for improvement were id e n ti fi e d ,
13 that is the need for appropriate co r r e c tive a c ti on ?
14 A That is one place.
I T' C' Isn't that the way the procese is supponed 16 to work? If y ou id en ti f y a need to improve, you put 7 tht.t on the work ple n ?
18 A Yes, that would be very appropriate, but 19 there work p l e n ti are m a d e., up for n year, and they t
20 are r e vie w e d every four m onth s.
21 Situ a tion s may change and they d on 't cover 22 e ve rything. There may be some ri tua tion e or areas 23 that are not covered on th e re.
l l
24 C Have you ha d Pe r f o r m a nc e Management 25 E valuation s ?
EVELYpe SE RGER ASSOCIATES. STSNOTYPE REPORTitee SERvtCE. CHARLOTTE. PeostTM CAnouNA
Davison - Diroct 96 1 A Yes.
2 O A n'd who performed that evaluation for you "
3 A M r. G rie r.
4 O M r. Grier did; and when was the fi r s t one 5 of those done for you, M r. Davis on ?
6 A In February. I believe, of this year.
7 O February of '837 8 A Yes.
9 O Did you and Mr. G rie r put together a 10 work plan ? L e t 's get what the s pe cific d o c um e n t in 11 c all e d, do you have one of those around here?
12 A PMPW.
13 Q Vhat is that called ?
14 A Performance Mana gemen t Plan--
15 Q V.orksheet?
16 1. Vi o r k e h e e t .
" O Did you and Mr. G rie r produce a worhehee t 18 fo r you?
19 A yes, 20 C Did that worke he et id entif y any areas wher e 21 you needed to im prove ?
22 A It ba sically e s tablishe s standards.
23 MR. GIBSON: Excuse me, Mr. G u il d ,
24 I will confer with M r. Davison before he M responds any f ur th e r about his works heet EVELYN SEROSR ASSOCIATES, STENOTYPE REPO8rTING SemvtCE. CHARLOTTE. NORTM CAROuMA
97 1 and his PMPW.
2 MR. GUILD: I would pref er if you nc.t; 3 I would like to continue with this series of 4 que s ti on s.
5 MR. GIBSON: I will not allow him to 6 a n s w e r., and I will' in s t r uc t him and you to 7 this point as to what I will all ow him to 8 answer.
9 MR. G UILD : I would prefer that the 10 W itne s s ' answer be uncounseled. I would 11 like him to answer the qu e s tion.
12 MR. GIBSON: I will conf e r with my 13 C li e n t before he answers any further 14 que stion s on this su bj e c t.
15 MR. G UILD : I want this clear, M r.
16 Gibson, that is over my obj e ction.
17 MR. GIBSON: I understand thr.t it it 18 over your o bj e c tion.
19 MR. GUILD: Fine, l
20 ( V. h e r e u p o n , t h e _ Vi l t n e s e and hic 21 Counsel conferred out of the hearing 1
1 22 of the Court R eporter. )
l 23 MR. GIBSON: Mr. G uild, I have con. -
24 l f e rred with Mr. D a vi s on about his e v alu -
25 ation and about his worksheet.
EVELYN SERGER ASSOCRATES, STENOTYPE REPORTIMS SERVICE, CMARLOTTE, NOsrTM CARouMA e
I 98 1 He advises me, and I will draw a 2 limit to state this under oath, also, that 3 his appraisal and worksheet does not indi-4 cate any areas where improvement might 5 be needed.
6 There is one goal which a rguably 7 might fall under that category though, I 8 think th at it does not.
9 The goal is that h e' spend more ti m e 10 in the work place. I am a d vinin g you we 11 b eli e v e thece evalua tio n s are c o nfid en tial, 12 not covered by the e a rlie r Discovery 13 Eequests.
14 I will not a ll o w him to answer s p e cifi c 15 que s tion s about his worksheet other than 16 to c o n fi r m or correct anything I have 17 stated just now.
18 THE VI IT N E S S : The only thing I 19 would add is the goci is not to spend mor e
- 20 time, but to e c t abli c h a standard of how 21 muc h tim e should be spent in the work 22 place, in the field as we refer to it.
23 MR. GUILD: Under C ou n s el's descri p-24 tion of what c o r r e c tiv e a c tio n was identi-M fled in your e va lu a ti o n , and that wa s a EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SSRytCE CHARLOTTE, NORTM CAROUNA
D ovis on - Diroct 99 1 subject of qu e s tionin g--
2 T l! E WITNESS: I would say no.
3 4 BY MR. GUILD:
5 Q No?
6 A Yes.
7 O Mr. Davison, was there an evaluation con.
8 duc te d for you for the tim e period prior to January, 9 1982?
10 A I believ e that was February, 1982, and 11 that was the one you were referrinB to e a rlie r, my 12 evaluation.
13 O % ell, you said you had an evaluation done 14 F ebruar y of '8 3 ?
15 A Yes.
16 C In J a n u t. r y of '82, w a r. there an e v alu a tio n 17 performed for you for the pe riod p ri o r to Jcnuary of 1H eB27 19 A Yee; again, our program is that exe m pt 2" e mplo ye e s have an annual e v nlu t t i o n.
23 C % ho p e rf o rmed your evaluation for the 22 January, '82, pe riod ?
23 A M r. W ells would have done that.
24 O When would t h a t--
25 MR. GIBSON: Excuse me, M r. G u il d ;
evium .. .. ...oc.4rs.. .r. orm .o.m vice. c atom. om e nou
D avi s on - Direct 100 f 1 I will confer with Mr. D a vi s on.
2 ( W h e r eu po n, the Witne s s and his 3 Counsel conferred out of the hearing 4 of th e Court Repo rte r. )
5 6 MR. GIBSON: Go ahead, Mr. G uil d.
7 8 BY MR. GUILD:
9 Q When was th a t evaluation perfo rmed ?
10 A It would have been perfo rmed in February II of '62.
12 Q So that is when your annual e v alu a t i o n for la the preceding period was perf ormed ?
14 A ye,,
15 C February is the ti m e c u s to ma rily when la your e v a l u t. t i o c o are p e r f o r rn e d ?
17 A That happens to be the time I come up o t:
18 an annual basis.
19 Q F rio r to the adoption of the Employec
- 20 Management Plan, what vc c u l d the form have been fer 2I documenting your e valuatio n ?
22 A There is a one sheet f or m, again, the 23 s pe cific title, I don't r e m e m b e r - - P e r f o r m s.n c e 94 A pp rais al.
25 Q A ll right, sir; is it ju st a check the box l
avetvn sanoen associates, svenorves aspoimwo seavice. cuantores.nonru canoWNA l
l
Davison . Direct 101 I f o r m, or does it have a na r r a tive evalu atio n ?
2 A It has the blocks that I indicated b ef o r e,
, 3 m a r ginal, fair, competent, c o mm en d a bl e, and dis-4 tinguished; and it has a place to write in any commen ts 5 that you might have.
6 Q Is there a space for a n a r r a tiv e de sc rip-7 tion of any identified work deficiencie s ?
8 A There is space on th e f o rm.
9 O Let me ask the qu e s tio n again: Is th e r e 10 a space that would id e ntif y any d eficien ci e s in the 11 e mplo y e e 's work pe rfo rmanc e ?
12 A Not labeled as such on the f o rm; there in 13 space to write on the f orm whatever explanation migh t 14 be needed.
15 G As t. ma tt e r of general p ra c tic e, would a 16 d e s c ription of work d eficie ncic e be included o r. t h r. t 17 form er an e a rlie r vercion of that form?
18 A If r. n e v alua ti o n was ma r ginal or fair or 4
19 commendabic or d i c t i n g u i s h e. d . I would say there w oul d 20 be an e v a lu a ti o n.
23 C 1-l o w about "needs to improve"?
22 A There p r o b a bly would be.
23 O What I want to understand ic for the p e ri o d 24 prior to January of 1982, the W e ll s ' evaluation was 25 done in I understand February of '82, fi r s t , what wa i EVELYN SERG ER ASSOCIATES. STENOTYPE REPORTING SE RVICE. CHARLOTTE. NORTH CAROUNA
f Devison - Direct 102 1 your evaluation for that pe riod ?
2 MR. G I li S O N : Objection; I instruct 3 him not to answer; as we have stated 4 e a rlie r, Mr. Guild, we do not b e li e v e that 5 is relevant and we will not make that 6 inf o r m a tion available absent a rulin g of 7 the C ou r t.
~
8 MR. G UI LD : The e valu ation s of a 9 large numbe r of e m plo ye e s already have 10 been responded to either with or withou t 11 objection.
12 I am not certain but th at with respecI 13 to VJ e l d i n g Inspectors, V,elding Inspector 14 Su pe r vi s o r s, imme diat e First Line Super.
15 visors and Second Level Supervicors, at 16 1 cart wit h respect to Mr. A llu m, my po siti on 17 it that .V r . D r. v i r. o n ' t evaluation is obviouc 'y.
18 relevant, his c r e d ibili t y of his t e s timo ny 19 will be in isrue, ir in 1 ti a. u e , and I i n t e r. d
- 20 tc--I expect that Mr. D rs v i t, o n ' t tv otimon y 21 will b e' ta k e n before the Board later, and 22 as for those other Witne s s e s whoso c redi-23 bili t y lik e wi s e is in issue, p e r h e. p s more 24 so because of the central r e s poncibility and 25 role Mr. D a vi s o n hns played in the V- eldin g SWELTN 50RGEN ASSOCIATE S. BTWNOTYPE R0 PORTING SORWICS. CHARLOTTE. feOWTH CAROuseA
i In s pecto r con cern s, there is a concrete i
2 need to understand his work his tory and a e valua tion s.
4 In fact, I b elie v e the que stion was 5 asked of a number of %itnesses in Mr.
6 D a vi s o n 's aupervisory chain above him of 7 his work hi s to r y.
8 Now there was some lack of c l a r i t y.
9 I can't remember ex a c tly which Witne s s I 10 asked it o f; but there war come le c k of 11 clarity about e v alu c ti o n s Mr. D r. v i s o n has 12 had.
la My best re colle c tio n is that s om eone 11 anid I think he wac in the average--
15 MR. JOS: Competent cate go ry con-16 el o t e ntl y, and be mcy have been rated 17 h i r,h e r then competent on one or more 18 occasions, and the %itness could not re-19 cr11.
- 20 M It . GUILD: Now the Vitness it her e 21 under oath te n d p r e c u m a bl y has that i r. f o r -
22 m a tio n a vaila bic to him since he la the 23 subject; and my qu e s tion is what evalua tions 28 has he had, how he is rated, and if there 25 have been identified deficiencie s and a nee d SWELYN RE RGER ASSOCIATS S STBNOTTPS REPORTING SERveCE. CHARLOTTE, NORTM CAROUNA
l l
l 104 l l
I f o r co rr ective a c tio n, it is relevant to the i
4 2 W el di n g Inspectors.
3 MR. GIBSON: Mr. G uil d. I appreciat e 4 your po sitio n, and I think the Record will 5 r efle c t what the other persons have te s ti.
6 fled to.
7 As has been the case e a rli e r. I dis-
- 8 agree with your charac te rization of the
, 9 e ar lie r t e s timony.
10 The s p e cifi c r a tin g e will not be re-11 vealed in thes e D e po sitio n s absent a ruling 12 by the Board, and I reiterate he would not 13 answer those qu e s tion s .
14 Aek him another qu e s tio n.
15 MR. GUILD: I don't know how to get 16 the information complete in the Record.
17 MR. GIBSON: You are mis c ha ra c t e riz ing 18 what has trans pired with e a rli e r D e po sitio n s.
19 That i n f o r rn a ti o n will not be given to you
. 20 in the f orm you have indicated.
21 People have given their opinions abou t 22 the work of other e mplo y e e s.
23 MR. G UILD : I have asked how they 24 have been evaluated, and they would say 25 commendable or m a r gi n al.
EVELYN SERGER ASSOCIATES, STSNOTYPE REPORTING SSRWCE. CMARLOTTE. NORTH CAROUNA 3
D avis on - Direct 105 1 MR. GIBSON: As I said, I appr eciate 2 your po sitio n. I disagree with your 3 characterization of what the Records 4 r efl e c t, a It will r e fl e c t what is there; you can r, take that matter up with the Board. If the 7 Board orders that items be made a va ila ble ,
8 we will c o m ply.
9 If you have other que s tion s of Mr.
30 D a vi s o n, feel free to proceed.
i; MR. G UI LD : I don't know how els e 12 to get it, C oun s el. It is g a me s man e hip.
13 14 BY !4 R . GUILD:
15 O M r. D avic on , let me see if I can approach t e, it this way, honoring your C o u n e. e l ' s in e t ru ction s ,
17 although I think th ey are incorrect and I dicagree is with t he m.
19 Hts your work performance been a b o v'c 20 average. Mr. Davison?
21 MR. GIBSON: Mr. Guild, I am not 22 going to a ll o w you to get that in fo r m a tion 23 through come other qu e s tio ns.
24 If you want to ask M r. D a vi s o n if he 25 has been criticized for his wo rk in some a rea 8WSLYN SERGE R ASSOCIATES. STENOTTPE REPORTING SERVICS. CHARLOTTE, NOarTH CAROUNA
106 1 or s o m e thin g , he will answer that que s tion ,
2 We will not give the r a ti n g he has ha d 3 on his e va lu a tio n. If that information is 4 made available by the Board, the document e 5 will indicate what it is.
6 MR. GUILD: I don't want to do that.
7 MR. GIBSON: I will not let him do 8 what you want.
9 MR. G UILD: If I can't ask him what to his e v a lu a ti o n was because you view that 11 as o b j e c tion able, and I disagree. I have ct 12 least asked th e qu e s tion in substance; and 13 I want C oun s el to tell me how I can percei ve 14 this que stion at this point, sir, and honor 15 your obj e c tion and get th e s r. m e in f o r m a .
16 ti o n or get the inf o r mation I 'a m t r yin g to 17 e li c i t , which la the e m plo y e e 's v ork per-18 f o r m a n c e.
19 MR. G I B S C": You b r. v e athed o th e r
- 20 people their o pini o n of other people's wo r k.
and th e y have given that opinion.
22 If you want to ask him his opinion of l
l 23 his work, he .will give you thet. If you l
! 24 want to ask him about incidents of being 25 c ritici z e d or counseled. f or his work, what ser l
1 eveten menosa associare s. stewotype menostmo senwice. cuantotts. MontM camouma
Dcvisea - Diroct 107 e
1 good or bad with respect to a s p e cifi c 2 r a tin g , I will not let you go about it in a 3 roundabout. manner.
4 If that information is ordered by the 5 Board, we will do it.
6 MR. G UILD: And we will bring Mr.
7 D avis on back for a third series of a que s tion s.
9 This is ridiculous.
10 MR. GIDSON: If you have ether 11 q ue stion s of Mr. Davison, proceci with 12 them.
13 14 BY MR. GUILD:
15 C V< hat is the opinion of your work held by 16 your c u p e. r v i c o r , L' r . D a vi s o n ? I want to start wit h 17 the period that I have been trying to direct your 18 attention to prio r to '82.
19 MR. GIBECN: I will instruct him not 2"
to answer if in his view he can only a ns we r 21 by givin g his r a tin g .
22 As I say, if you want to ask him abou t 23 any problems that have been identifisd by 24 his s u pe r vi s o r, anything he has been criti.
25 cized for or c ou n s el e d'~f o r, he is free to I
BW84TN BERGER ASSOCIAfst. STENOTTPS REPO8tTtNG AestveCE CMamL/JTTE. feO8rTM CAmou8eA - %
+ .
A-- _
I ti Davisos - Direct 108 1
te s tif y about that.
2 3 BY MR. G UILD :
4 O Respond to the question that your Counsel 5 just f ra med.
6 A Nothing in p a r tic ula r comes to mind. I 7 am sure in the course of work with my s up er vi s o r 8 we talked about some thin g s , and we talk r. b o u t things 9 that we need to a p ply more attention to, more directo d 10 attention to.
'll - V. e talk about thin g s we have not done well 12 or can do better.
13 O Thnt is what I want to focus on, the thingn 14 you have not done well and you need to do better.
15 A I don't have any s p e cific r e c olle c ti on of 16 thoee it e m r . Iam sure in a m r.nn e r of con ve r s a tion 17 with my s u p e r vi c o r , jutt like in the manner of 18 c on ve r s ation with the people that report to me. If 19 we have a prot,lem aren we talk . bout it.
- 20 We t.;1k tbout whnt we can do.
21 Q G r c r. t ; I want to und er n tan d evidence now.
22 M r. D a vis on. I am looking for rome evidence, that 23 is what thle ie all a b o ut .
24 I want to know any documentation that exis ts
% that would r efle c t th e id e n tific a tion of d e fi cie n c i e s 1s
. ,vetm .. .. ...oci.ve . eve ome ammu.e v.cs. c .torve. on ca ou=. ,
3
/
D avi s on - Diroct 109 1 your work, sir, and the need for you to take 2 c o r re c tive a c tio n. ,
3 T ell me about any documentation that exfst e, i
MR. GIBSON: I will i n s t r u c t hi m, t o 5
limit his response broadly cons trued to an) -
6
, thin g related or a r i s i r. g g o u t of the V' p id in g 7 -
In s pe c to r _ conc e rns. .-
8
,' %'ithin the scope'of these D epo s ition s,
) -
9 are you aware of anything, Mr. Davison, 10 arising out of or connected with the W eldin g 11 In s p ec to r concerns that have to do with y o t.r 12 performance, you can discuss that with Mr .
33 Guild.
M THE W IT NE S Sj - In general I would sa y 15 the r e c o m me nd atio n s of the Task Force of 16 the t e c hni c a l and non-technical T s s i; Force 37 that were im ple m e nt e d, thIse were di scu r e nd 38 and the a c tion s to be taken were di s c$s s ed 39 a,n d app' roved'by my su p ervi c o r.
- oo
~
Pa rt of those things were to conduct "I
~
training s e s sion s and how we handled dis-22 a gr eement s and our communications; and, 23 of course, I have been responsible for 94
~
d eveloping and giving some of that tr ainin g ,
25 and that training would obviously apply to SVELYN SERGER ASSCCBATRE. STENOTYPE REPOMTING SERVtCE. CMARLOTTE, hostTM CAROLied
Davison - D!roct 110 1 me, also.
2 3 BY MR. G UI L D :
4 Q Please don't plow over old g r ound; do cu.
5 ments r e g a r d in g you, Larry Davison, and regarding 6 the deficien cie s in work pe rformanc e; are: thdre any, 7 sir?
8 A Not that I'm awa re of.
9 O Would you be aware of them?
10 A I don't know.
11 Q See, what I' m concerned about, Mr.
12 D a vis on, let me lay thic out: I am trying to find ou t 13 about your company's claim o r defense.
14 T hat is what this Discovery is about. I 15 don't want to be surpriced, Mr. Davison, when we go 16 to H ea ring in thic case and find out that Mr. Davison 17 han been i d e n t ifi e d as needing to improve hit 18 c o m munic a tion s with Welding Inspectors in 1982, and 19 we have a document th at says Lerry D a v i s o r. , you h:.v e
- 20 not b e c. e c ommunic a tin g e f f ectiv ely, improve your 21 communications.
22 MR. GIESON: Is that a que s tion ?
23 MR. GUILD: N o, sir; this is a state -
24 m e n t. I want to state a p o s iti on for the 2 Record so you will understand.
. .uu .. .. ....cian.. .n rm - e.. e .um.. m. ca u
D a vi s oa . Diroct ill 1
f 1 I would appreciate it if you wouldn't
~
2 interrupt me any further.
3 MR. GIBSON: Go right ahead.
l 4 MR. G UI LD : I don't want to be sur-5 p ris ed a t the H e a rin g, Mr. D avis on, to see 6 a document used by your company that says 7 we identif y Mr. Da vi s o n as part of the s communication problem, and we c oun s eled 9 him and here is a d oc u ment, and he then 10 improved his co mmunn . t io n c .
11 12 DY M*R . C t'I L D :
13 C Given that s tateme nt, sir, is there any 14 document that would indicate any identification of 15 a need for you to improve your work a n d tr.h e 16 co r re ctive a ction ?
17 L A r, a result of the % elding In sp e c tor T r. t h i
18 Force?
19 C N o, cir; tr t. r e sult of a nythin g ?
l
- 0 l ?.i n . GI" SON: I am in s t ruc tin F him 21 to limit it to the Velding I n s p e c t o r e. ' T as h 22 Force and the items :. rl a in g th e r ein.
23 MR. GUILD:- My qu e s tion in Discover y 24 to him, is there a document that i d e n ti fi e d 25 wo rk deficiencie s t. n d a need for correctivo EVELYN SEROGR ASSOCIAT18. STSNOTTPS HEPORTING SSHypCE. CNARLOTTE. DeONTN CAROUNA
Davisoo . Diroct 112 1 action?
2 MR. GIBSON: And I will tell you how 3 he will answer it and what it is limited to, 4 TH E WITNESS: 1 don't r e call any 5 documente o th e r than the Task Force. ,
G 7 BY MR. G UILD :
8 C Not in your personnel file ?
9 A Not that I recall.
10 Q Do you r e vi e w your personnel file ?
11 A I don't n o r m ally r e vi e w my perconnel file.
12 G M t. v e you?
13 A No.
14 C Vhat have you seen that would be included 15 in your file ? Have you ceen your evaluatione ?
16 /. Yea, I have seen my e v r. l u a t i o n e i n Februar y 17 of '53.
18 O A nd your e v alu a tio n s bef ore that ?
IP I. I c'. o r. ' t r e c c 11 whether ! r r. w th e s e er n ot.
- 20 C In the notmal ecurse would th y rend you 21 a copy of the r e s ult s of your e v alu atio n, otr?
22 A Not ne c e s s a rily.
J 23 C What i e. the pr a ctice ? Ie th e pr a c tic e to 24 send su bj e c t e mploye e s a document of your evaluation ? ;
25 A With the PMP pro gra m, th e pr a c tic e is to twsLvN sanger ASSOCIATSt. STENOTTPE DEPOffftfeG SSHVtCE. Cl4AHLOTT*. NOsmt CAROUNA b
- i. . .. . .
r .
.r .
D a vis on -
Direct 11 3 _
1 go over that d oc um e nt. P rio r to that time I don't 2 know of any r equir e ment or rule to go over that.
3 C ertainly as an evaluation at some point 4 in time the employee would be told wha t the r e s ul t s 5 of the evaluation are, whether he is shown the docu-6 ment or not abawn the d o c.u m e n t that I've described 7 e a' r li e r that was in use durin g that pe riod of time.
8 P r a c tic e s have varied. .
9 C D',d you see those documents ?
10 A I d o .. ' t r e > 11 sseing t;4e m r. r i o r e '83.
11 Q Y au don't -e c All ?
12 4 14 0 .
13 C. V no cr. r.i n t a i n s your e v a lu .A t i o ta. for tne 14 p er iod (Po .- n o w, ;. r e s e n t , :a ct t h r o.. c h the peried we 15 '. .: - L t. d o n di e eu r sion ?
tr s. I w o ul d a s nume thore would t. c in m 3-17 p e r c o r.n c l filc. Ihat is no r m ally where thote are ke; t.
18 C M ho maintains your per c or nel file ?
19 !. It ir mv und t: s te rdin g thtt ir in ?; e t.1 20 4. ! c : a n d e r ' r r. r e c , the people that wor k for him main.
21 tLin thoec.
22 O And he would supervise the people who hav< .
23 cus tody of those file r ?
24 A That is my und e r s tandin g, yes.
25 MR. G UI LD : C ouns el, for the R eco rd gytLYN BERGER ASSOCIATES. STSNOTYPS REMINg gefMCS, CMARLOTTS. MONTH CAROUNA
Da- trot - .
,r: 11 ;
i 1 1: le our in te ntion to seek by compulsory i
1 2 p - c d s. c t i o n . Li r . Davison't e v al u a ti o n s f ro m >
3 tne period present back throu gh the tim e r 4 when he held the positions of s u p e r vi s in g, 5 Y. cidin g In s p e c to r s a t C a tawb a: and I would i 6 a rk that those documents - be preserved. l 7 ht R . GIBSON: The documents ke pt in 8 the normal cour s e of business by the comp any 9 are kept in the normal process o f all docu.
10 ments kept by the c o m pa ny.
,-- ~ 11 Is there some reason thore were not 12 requested ea rlie r, Mr. Guild ?
13 MR. GUILD: You have my position.
14 MR. GISSON: Le t's proceed with the 15 que s ti onic g.
16 17 EY M R. GUILD:
18 Q Wef e you ever commended for your work, 19 M r. D a v i r. o n ?
2" /. N othin g that I can r e c all c pe cific ally e 21 normal discussions with supervisore; s o m e t i m e. o they 22 would s a y you .did a good job or you didn't do s. good n3 job.
24 O El o w about in writing, sir?
M A Not that I r e c all s e ein g, no.
EVELTN St AGEM ASSOCaATES. STENOTYPE RSPCstTwe6 STME. CMAmLOTTE. feOfrfM CAseOuseA
o D avia on - Direct
.u=
1 3
i O P r e vi ou s Witn e r - c a . tnd I ca n't recall who 1
I 2 ll i t was, to t ell you the tre :. , rir, were a ske d g r e t tions 3 about your work, and the e r. s w e r was to the effect 4 that you had been rated c o tr. p e t e n t or had performed 5 c ompetent work. I don't r e c a.11.
6 But I think it w s. s that you were rate d 7 competent, and for a cou ple ~ of periods when the pro-8 ject was undergoing growth you may have been rated 9 whatever the next r a tin g higher was, that your work 10 may h a ve been b ett e r than co mpetent. '
11 It appears to be M r. Beam that was i. e k e d 12 "those qu e s tio n s . Do you know ha r. Beam?
13 A Yes.
14 Q P r e viou sly the Project Manager ?
Ir> A Yes.
16 C At C t t e r b t. ; Mr. Beam, my noter reflect 17 tb't F!*, B e t- m t e c tifie d that your werk h tt d b e e r.
18 c o n sis t e n tly competent; and that it may _have been 19 higher than competent one or two tim e n d u r i r. g growth l
20 p e r i o d r, where you h r. d a chance to excel, perhaps the 21 period before GC was moved up under Outlity Assura nce.
22 Was your work viewed as more than com.
l l 23 potent during a couple of period s ?
24 A 1am not aware of what my r a ting war duri ng 25 that period of time.
EVELYN BERGER ASSOCIATES. STEMOTYPE RSPORTime SERV 6CE CHARLOTTE. 9008FTH CAROWNA
i i
Dee,sor . 7iree: 11 ;
i 1 Q Ycu are cct t. v c r e ?
2 6. I don't have any reason to believe that it 3 was anything other than competent.
4 C Have you received any additional t r a inin g ?
l 5 A Of course, the t r aini n g that we conducted i 6 as a r e sult of the Task Force re co mmend a tion s .
7 Q For you?
8 A I helped develop that. It was approved by 9 Mr. G rie r, and I conducted that and that course 10 applie d to me as well er to the other p e o pl e .
11 C That le whet I want to understand, t r ainin t 12 that you have undergone, cir; what training have you 13 undergone?
14 A As a matter of fact, I made up a t r ai ni n g 15 outline on the subjects we went over, handling dis-16 a gre e me nt s, the E mploye e Quality E ccours e Crocedur e.
17 O T hi c t r a in in g that you h r. v e been the 18 s ubj e c t of, you have undergone this training?
19 /. Through c o n du c ting it, yes.
20 C VJ h a t I want to understand is not t r r.i n i n g 21 that you conducted for others, but training conducted 22 for you, sir. Have you received any a d diti o n al 23 tr aining ?
24 A Not that I can r e c all ;pe cifically pr e s e nt e d 25 in that fo rm.
EVELYN BERGER ASSOCIATES. STENOTWS REPOWTree SamnCE. C3%RLOTTE. nom CAROUNA
Dr..ssn -
.. rect 11-
.__ =w I
Vi h a t I wa nt to k no w, you know, here is 2 !aome t r c i ni n g f o r . y c, u as a r e sult of the V.' e l d i n g 1
3 lIn e p e c tion Tcsk F o r c e. .
4 Did Duke Power Company ever say Mr.
5 D a vi s on, you need to take a course, you need to learn 6 s o m e t hin g m o.r e about how you do your job ?
7 They did not s end you to any s eminar s.
8 training s e s sion s ?
9 A No.
10 O Mr. Davison, finally I want to und e r s ta n d, 11 i n' li g ht of what appears to me to be strongly held 12 opinions expres s ed by W eldin g la s p ec to r s and others, 13 I read those as c riti ci s m e , and the fact that you re-14 main in your position and mo st of th em r emain in 15 th ei r s , wh a t has changed to address what I would 16 und e r c ta nd to be the t er cion and h o s tili ty that would 17 t. r i s e f r om the V. c i d i n g Icepectors having dir e c t ed 18 those c ritici s m s , what has addressed that and what 19 la t. e changed to keep that f rom g e t tin g in the way that 20 work ir done?
21 !. V. ell, I think again, all the things we hav e 22 done as a r e s ult of the Tark Force have addressed
\ 23 thst.
l 24 V. e have exa mine d and talked about th e 25 s u p e r vi s io n, how we should h a t. dl e dis a gr eement s, l
EVELYN BEmOER ASSOCIATES. STE8eOTTPE REPORTING SSRvlCS, OMARLOTTE. NOftfM CAM
D .. , - Di oc' 1: e I w he a 1 ' htve t'. i t . rt -ements we put in place an 2 a d d i t i o n a.1 p r a c e 9 t. r e , the C. u. a li t y Recourse Procedure, 3 and ve e e x p l :. i r. c c' that to all of our in s p e c to r s t. n d 4 indicuted to th e m that te there for that purpore and 5 used for that purpose, and they should feel c o rn f o r t a ale 6 to use that if they are in that po s i tio n.
7 O That is an ef f ec tive procedure?
- 8 A Yes, I think so.
9 Q Has it been used?
10 A Yes, it has been used at least one time 11 that I am eware of. I think we have an Em p l o y e e 12 R e l t. t i o n s A s sistant on site now which is th er e as an 13 aid again to co m mun ica tion s.
14 V' c have got ten su pe rvision involved in 15 procedure r evi sio n s , g etting their input more so than t r> we did beforc.
17 'C e have tchen mor e time in e x p l a i n i r. ;
18 revisions when they come out to the supervision leve:
19 in time to get q ue s tion s and get answere to que ction t .
20
, I think all of tho c e t hin f o have cddrecsed 21 the f e elin g e of the M eldin g In s p e c to r c er t h e y e r: -
22 preesed them.
23 O Have the changes in procedures for handling 24 and id e ntif yin g and correcting cons truction deficienci e s, 25 th e changes in the N CI procedure and R2A procedure, SVELYN SERGER ASSOCIATE S. STSpeOTYPS IISPOfrTINO SSRWICE. CHARLOTTS. feORTH CA*OureA
D avi s on - Direct 11?
+
l I has that contributed to i m p r o vi n g c ommunications ?
2 A I don't know that I would s pecifically ray 3 that has contr1et:ed to ! m p r o vin g communications.
4 I think that hee near an improvement in the program.
5 O No e fi c c t on c ommunic ation s ?
6 A It would be hard for me to gauge. I don't 7 know. It may have; I certainly do not think that is 8 a p ro ble m.
9 Q Has it aided in reducing the tension betwee n 10 you and W el din g In s pec tor s ?
11 A I don't think that has ne c e s c a rily contri-12 buted to that.
13 O Okay, you were involved in r e vie win g a 14 complaint of h ara s s ment from a W eldin g In s pecto r 15 named Reep?
16 A Y e r. .
17 O And that was the only use of the Harass.
18
. ment Procedure to date that you are aware of?
19 A The procedure of the CA H a r a r r m e n t 't 20 0 The QA D e pa r t m ent procedvre; th t t 's right' 21 A To my kno wle d g e, yes.
22 Q You concurred in the conclusion that was 23 reached by the Employee R ela tion s Staff that r evi e we :1 24 M r. R e ep s ha ra s s ment complaint; did you not?
3 A B a s i c ally, yes.
EVELYN SENGEN ASSOCIATES. STENOTYPE NepONTWee SENWICE. CNARLOTTE. NOsme CANOL8MA l
a4 on . E roet 170
- = = . - =
b '
1! ou agreed with the fin din g s that the 2 t :mplaint was w e ll founded and harassment occurred?
3p A 1 don't b e li e v e that was th e fin di n g .
4
- ! O You did not b eli e v e ha ra s s m ent occurred?
d 5 ;' A I wouldn't characterize what had occurred 6 ha ra s sment.
- I; a s 7 O You did not cha r a c te riz e it as ha ra s s ment ?
8 A No, I believe it falls more into the i
9 c ha ra c t e ri za tion of an ar gument that d e v e lo p ed betwe: n 10 an in s pe c tor and a w eld e r.
11 O Did you conclude on the baeis of your 12 review that what occurred, the facts that occurred, 13 did not interfere with th e inspector's p e rf ormanc e of 14 his job?
15 A I don't think that situation caused the 16 inspector to be unable to p e r f o r m.
17 C You did not think it in te rf e red ?
I I
18 A Not to the extent that he would not be able
~
19 to pe rf o rm his job.
I 1
. 20 C Did it int erf e re ?
21 A C er tainly to the extent that any argument 22 is an interf e r ence in that term, in that s ense that 23 if you do not have an ar gument 'the job should be 24 easier to ao. ,
25 If you h ave an argument, that will cause EVELYN DERGER ASSoctATES. STENOTYPE REPORTING SERwsCE. CMARLOTTE. NORTM CAROUNA
H i
i D a vi s es - Dir ec t 121 l-U D
4 f
n I
- emo tion s to rise, and we would desire that n ot t o
{a 3
t occur. !
4 f
j G Eut that is the onl y way in which it inter-5 ! fered with the performance of his job?
6 , A y e a h, ,
+ ,
7 Q If that wa s n 't ha ra s s m ent, what would ;
' i 8
cause hara s s men t in your opinion as you e m plo y
~ b the te rm ? +
i 10 /. Haras sment is very dependent on the cird l
M cum stan ce s and conditions. I d o n 't know that there!
12 is e einEle d e finitio n that would t. p p l y t o e v e r yt hi n g
,, s in g en e r cl-- r e pe a t e d e. cts _taken toward one ll u'
in dividu al to another or group of individual- p
'5 ir clearly directed beenure of some dir tin c t c h s r :. c t e r i c t i c of an in di vidu ni -that the a c tion is taken ageinti.
10 C Race, sex, age? f, ll 8 Yech.
O A ll rignt, eir; only those c on dition c ?
2i A l
l That are designed and in t e n d e d to pre-1 m2 vent and interfere with and-cause the o th e r person l I '~
to be untble to do th e i r j i> b .
i l 24 MR. GUILD: Subject to my desire e
25 li to qu e s tion the Witne s s on the subject.of]
h LYNN B. GILLI A M .
f6 STENOGR APH REPORTER
1 i . D a vi s on - Crote 122 g
i,
~
!l
'I t' 2 .
his e v luations and any fin din g s in those 3
e valu a tion s concerning his ac tion s related to V,elding Inspector concerna. I nave u o; 5
a ddition al qu e s tion s for a. r . Ds vi s o n at
. 6, 6J this t im e.
l; i
7 MR. CIEEON: Okay, I have a couple E I matters to take up. ;
- l!
ii i
10 CROFF E X A MIN A TI ON
~!
11 BY MR. GISPON: ,
'l.
12
C The very la st serier f rom M r. Guild, ;
13 you d e fine d , you gave a definition of ha ra c ament l
" H that I will try to pa ra ph ra s e --i t involved r e p c a t e d .'
b 15 acts di r ec te d towa rd a person.
I L ould an inseector be included in that group, if t h c- :i c t e ere cir e ct ed' towcrd hi m bectuce p' . i he is an ins pector ? g h
M !. It could be.
AI R . G I l3 3 O N : Now I would li k e to Ci mark, G u il d ,
Mr. the t y pe writt e n ve r sion i;
E of M r. D a vi s on's proposal to Mr. W ell s il 1
O also ae an Exhibit. !?
'l 24 0
( , ( W h e r eu pon, the document r e f e r r,e d I
25 {!
l
.)
to as typewritten version of c o m m e n't
,, - LY N N - B. GILLI A M h STENOGR AP,4 REPORTER o
[ 1 l
l 2
I 3
...5r.,. - s rut 6
- t .; !/ . V,elie wae marked and re- ;
c eive d by the C ou r t R e porte r t. :
i 4 A p pil c a n t 's Exhibit D to Mr. D a v i s o'n ' s s O c po ci tion and ente re d into the j
. c. Eecord.) ,.
7 t MR. GIBSON: Also s om e c u e s tio n s
( c cin e e r n i n g Mr. B r ya nt 's o ta t e me nt s , if i i-10 you would make that a v a ila bl e to make a i.
i.,
i' copy of thrt would be I. p o ll e a n t 's E xhibit '
E.
I II
( V b e r cu po n. the document re-ferred to as qu e stione concerning i
?. r . Y r y c r. t w a. s marked and received by the Court R e po rt e r cr o pplic e n t 'c E x FiLit E r. r. d entered into the 1
Il e c o r d , i ,
eY 'h.
, Gin 3: F:
C I in all y, hr. D a vi s o n, are you cware 5 of a n y t h i r. g thrt would cause you to c; u e r t i o n vbether the Catawba Nuclear T. t a t i o r: is safely b uilt ?
I h N o. I 1 j!
D' MR. GIBSON: Any further qu e s tio ni, I
LYNN B. GILLI A M l
! STENOGR APM REPORTER j j
if i h 1 ,
124 jj h.-- 9 f
I 2 ij. Mr. Guild? _
3 !lI MR. GUILD: Not f rom me. 'li i
1 4 MR. GIBSON: Thank you, Mr. d i I l
5 D a vi s o n.
6 FURTHER THE DEPONENT SAITH NOT.
7 l.
tl MR. GIBSON: With respect to the 1
9 rest of the- day, do you want to start I, 10 with Mr. Morgan or take a lunch break 11 now? I f
12 '
V.ith respect to the af te rnoon, do ;
13 you want us to have M r. Shropshire? ;
i 4 l' MR. G UILD: Yes, at 2:30 or some-
'l i
15 thin g like that. !
p MR. GIBSON: Just your best
.i -
e s tima te of when you would like him to
" j show up.
= li
'.c l M R.- C UILD: You better ark him i j
. to come up now then, MR. GIBSON: V.ith respect to tne V.elding Supervisore, we have not r e c eiv '
Y- 6 ed Notic e s of their D e p o s i ti'o n s .
.n We have indicated their a va il a b ili t y','
I l 25 0
but our vi e w that you should comply withll
- LYNN B. GILLI A M STENOGR APM REPORTER g i
o 125 !J
. . ._- )
. the Rules of P r a c tic e.
2 Do you intend to serve Notic e ? ,
1 4 MR. GUILD: Yes. C ou n s el, as yoh n
l ~'
! know, we have been' c on s ta ntly involved i
' in these Depositions other than M onday :
l 7 and Monday we were m e e tin g a Board 8
Order d e a dlin e. ;
If you can make a v ail abl e a type- ,;
i
'O w rite r I can sit down and type out th e i
' Notice s that you insist on.
12 Ot he rwis e , I can write out the text P
13 of the N otic e s of De po sition.
U 14 h MR.
GIBSON: VJ e will waive the I
1 ~r formal Notic e of the D e p o s iti on as to t h o's e ,
three i n di vi du a l s who are t v aila ble and
~^
- t. r e indiccted in th e moet recent schedule M we have come up with. I However, we do not waive any of t h'e other procedural r equire ment e a p pli c a b le' to their D e p o c ition e .
l-2 o Vi e are just waivin g a f o r m al Notice.
-- i MR. .
C U l i. D : -I a p p r e c i t. t e that; andl; L
't o
. if there are other r equir e m ent s we should is ll' 25 J h address, let me know about-that at thie !
- h. ,
,l LYNN B. GILLI A M l srcuoon esnr.onven j
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3 ,
MR. GIBS ON: Okay, we will resume 4 j. in an hour with Mr. Mo r gan.
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8 . 1 Larry R. D a vi s on, hereby c e r t i f y, e that I have read and understand the foregoing t r a n -!:
1 10 , script and believe it to be a true, accurate and j
?
11 c o m pl e t e t ran s c ript of my te s timon y. I:r i!
t i: . p is i t
u Larry E. D a vi s on '
This Deposition wce signed in my
~
it presence by Larry R. D a vi s o n on the day o f .',
i' ii J uly, 1983.
b, i:
-e N ot a r y . Public i; 2: c I'
24 h 1= i 25 N LYNN B. GILLI AM
,j STENOGR APH REPORTER I!
a
' 127 if o i f.
Il 2 C E R T I F I C A T E !
l 3 STATE OF NORTH C AR OLIN A !
l l- ,:
5 ,
I, Lynn B. G illia m , do hereby c e r t'l -
i b
e L fy that th e p r o c e e din g s w e re by me reduced to 7 machine shorthand in the presence of the V. i t n e s s , l l'
=
t h af terwards transcribed upon a typewriter under my I
9 direction; and that the foregoing is a true and 10 correct tr an s c ri pt of the p ro c e edin gs. l M h I further c e rtif y that th e s e proceedd i
l' i in g s were taken at the time and place in the for e- ;
13 g oin g caption a p e cified.
It I further c e rtif y that I am not a II o
is r ela tiv e , Counsel or Attorney for either Party or H a
otherwis e in te r e c t e d in the outcome of this ac tion. !
IN L IT NE5 5 V. H E R E D F , I have here-10 unto set my hand z. t C h r. r l o t t e , North C a r olina, on ,
M this the day of July, 1983.
- I, h
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LYNN B. GILLI A M Court R eporte r [!
(
My Com mi s sion ex pi r e s May 12, 1988.
25 LYNN B. GILLI AM f[f STENOGR APH REPORTER
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- 1 Mr . V, H. Bradley Duke Pecer Co? any Pers nne! Department Charlotte, N.'.C.
Dear Hr. Bradley:
On this date, 1/12/82, I discussed some of the problems which have affected my Job, with Bob Horgan. I believe Bob to be receptive, but he is not in a position to help. I told him I wanted to see Warren Owen. He said he would have to inform Larry Davidson and Mr. Wells. I told him 0.K., but that I didn't really wish to talk with either one of them because I feel like they are part of the
, problems that the Q.C. Inspectors.have.
Bob Horgan called Charlotte but Mr. Wells had left for Arizona and Larry Davidson was en route to Catawba. Bob informed me when Larry arrived and I had to talk with him. I told Larry that i felt he was one of my' biggest problems because -
he had already stated that he did not and would not support me on the issue of our general increase but that he would support me on Technical issues. I in-formed him that according to past practices he had not supported us and that I didn't feel that he should expect me to believe he would support me now.
Larry said the pay issue was one ball game and would be handled in accordance with the Employee Recourse Procedure and any matter of a Technical nature would without a doubt be handled through him. ,1 Informed Larry that I didn't have -
any confidence in him and wished to talk to Mr. Owen. Larry, at this point told me that it would be done according to the way he had layed down and he hoped that I realized the seriousness of not doing this way. I told Larry that i fully intended to do everything in a professional manner according to all Company :
policies, but that I wanted to talk to Mr. Owen. Larry told me that if I didn't E do as he said that I was headed for real problems. He said he wanted to make sure i understood that. I told Larry I questioned decisions that had been made by himself and others and I wanted to assure myself that people above Mr. Wells were aware of the overall situation. 7 I sincerely believe that Larry Davidson was threatening me with my job if I didn't do everything his way even though I feel he is a big part of our problem and is trying to cover up many items that he does not want to reach upper ?
management because many decisions made would look bad on him.
I fully believe our Q.C./Q.A. Program to be adequate in all areas if followed, but I don't believe it has been followed and can produce proof.to substaniate -
~
lt. I feel that Larry Davidson's track record proves that he doesn't deserve the trust he is asking for.
m e
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- Jancerv 12 19E*
- In conclusion. all i am asking for is for Mr. Owen te Irvesticate the problems and mane juc9 ment anc cecisior.s accorcir.g to what comes out of the investication. I beTieve that this woulo be seneficial to myself as well as all Duke Power here at Catanba, and I sincerely hope that Mr. Davidson will not terminate me because of my sincere concern for the problems of lack of support we in Q.C. Welding have experienced. I must re-emphasize the fact that the statements made by Larry Davidson lead me to believe that my job could be in Jeopardy because I don't agree with him.
Sincerely,
, {O' ffY Jo,hn M. RockFolt f 191
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December 12, 1931 3
W H Owen
Subject:
Catawba QA Program As requested in our meeting on December 23, 1981, I am enclosing a summary of the actions which we recommend be undertaken at Catawba. -We, of course, l would apply some of these to the other sites. When you have read this and desire further discussion, please let me know. We are anxious to implement these items as soon as possible.
.' - /
, / f. if. C-Q
< J R Wells v
JRW/ph O
9 i
Prge 1 CATAWBA QA PROGRAM
. ACTIONS TO IMPROVE COMMUNICATIONS
( Problem - Breakdown in communications between the QA Welding inspectors and other groups, e.g. 2nd level QA Management Construction Technical Support and Craft Supervision, at Catawba. This has resulted in -
a feeling on the part of the inspectors and their first line super-vision that (1) They are not supported by QA Management in doing their jobs (2) Construction Technical Support is not qualified to do their Job and works against QA (3) Craft Supervision do not care about quality of work and are overly influenced by schedule pressure. These feelings result in an attitude toward their Job of being the only ones looking for quality and having to " catch" all the deficient work being pushed through, rather than one of
, being part of team effort to achieve quality as an end result.
This attitude is reflected on the part of craf ts and technical
, support in that they feel inspectors (welding) are too tight and unreasonable in their inspections. They also question the competency of the inspectors to do their job.
Task Force Findings (Assumptions on my part - I have not seen report)
(1) No evidence of unacceptable work being passed (2) Welding inspectors feel unsupported - no similar feelings in other inspector groups.
(3) Communications have broken down between welding inspectors and QA management, technical support and crafts.
(4) Practice of verbally denying NCI's to inspectors is upsetting to them.
Solution:
Goal - To re-establish good communications between welding inspector and other groups (QA Management, T.S. and craf ts) such that inspectors and other groups can understand the role each plays and can trust the other groups to do their part.
Actions to accomplish:
(1) Instruct construction (T.S. and craf ts) as to the proper ,
e relationship with inspection personnel, i.e. respect the Job they have to do.
Completed - JEG ltr. to LRD dated 12/16/81 (2) Provide inspectors with training in
- 1) Role of inspector
- 2) Human relation skills Being developed by QA Long Term item
____________________________j
(3) Establish a QuP11ty Communications F.-og am - consisting of periodi c meetings between inspection , T.S. , and craf ts with the express purpose of identifying cuali!Y problems
(' and coming up with solutions and/or action items.
Weekly basis to start- I bour (cr less) -
Actendees - Craft General Foremen (Welding)
Construction, T.S. Welding Eng & Sr Tech inspection Superv Tech's, Tech Superv and selected inspectors (one or two). Others (PHM Gen Foremen, Steel Workers Elect Foremen) as necessary.
(4) Go over Task Force findings with QA Management and Technical group (QA) to establish the need for better communications 3 on their parts.
(5) Go over with inspectors items being done to improve communi ca tions/ support i.e. 1, 2, 3, 4. Instruct them as to what will be expected of them - a) Professional behavior b) Technical Matter Recourse (6) Discontinue practice of verbally denying NCI's. If NCl is volded do so on copy of NCl.
Organization 1/ Management -
(1) Beau Ross - Transfer to Oconee as Welding inspector or transfer to QA Tech Services Group in Charlotte (possibly Construction Welding?)
(2) C R Baldwin-Transfer to Tech Supv RT & NDE Replace with A E Allum Reasoning - (1) Removes Beau who management see as block to communicatiens (2) Removes Charles who inspectors see as block to
, communications I
m 12/29/81
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