ML20082C163

Transcript of Rl Dick Deposition in Charlotte,Nc.Pp 1-30

ML20082C163
Person / Time
Site:	Catawba
Issue date:	07/15/1983
From:	Dick R DUKE POWER CO.
To:
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FOIA-83-434 NUDOCS 8311210483
Download: ML20082C163 (30)

Text

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UNITED STATES OF K4 ERICA

(

NUCLEAR REGULATORY COMMISSION

- BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: ) Docket Nos.

)

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

COPY I, Barbara V. IIaas, Commissioner and Notary Public, proceeded to take the deposition of Robert Lacy Dick on the fifteenth day of July, 1983, beginning at 3:10 o' clock

( p.m. in the of fices of Duke Power Company, South Church Street, Charlotte, North Carolina.

DEPOSITION OF ROBERT LACY DICK I

44o Colvd Rd.

l ASSOCidteC p.o. Box zzo.si Charlotte NC. tazzz -

l {Ourt pOr(CfS 7o4.i64 3i7s '

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j p3 8311210483 830825 PDR FDIA AHLERS83-434 PDR

s ROBERT LACY DICK, being first duly sworn, testified as follows: ,

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i 2 ' EXAMINATION: (By Mr. Guild) 3 MR. GIBSON: This is Mr. Dick, Vice-President for Construction available for deposition. I assume Ne'll proceed J

5 by our now familiar set of stipulations and present during

$ .this deposition will be Mr. Grier and Mr. Bell. As I indicated I

7  ! earlier, we have made available the documents relating to 9! Quality Assurance Program that we talked about, l and I want 7 special emphasis to present you with your personal bumper

0' sticker that you requested about ten times. Mr. Dick, your i

'i, full name, again, sir?

12 A. Robert Lacy Dick.

3'Q. Your business address?

14 A. Box 33189, Charlotte, North Carolina 28242.

'5'Q. Is that here at.the general offices?

I'm in the Wachovia Center, across the street, on the

$ l A.

17 I twenty-second floor.

'a .

Q. Your present position with the company?

W f A. Vice-President Construction.

i 20 l 0. If you would, Mr. Dick, would you give me a run-down of i

21 l your work history 'with the company, when you came with the f- to the 22 ! company and what positions you have held and when, 23 best of your recollection?

24 A. I joined the company upon graduation from North Carolina 75 State University in 1949 in the position of Assistant Of fice 2

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. -. _. - - . - - .. ~ .- . - .._ - - - , - - . _--

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( Engineer. I worked in the Engineering Office in the field .

in support of the construction of coal-burning generating 2

r 3 plants.- I was made Office Engineer, which was the supervisory J position in the Technical Support organization,about 1951.

a 5 I stayed in that position till about 1964 when I was placed  !

i 6'in field charge.of Duke's Construction Department which, at l 7 that time, was coal-burning generating plants and some hydro- ,

B, electric construction. I have been in the field on almost

' every generating plant that has been constructed since World 10 War II includhg oconee in 1971. Well, in early '71, I was t

elected Assistant Vice-President but remained generally in

^

11 12 the field. December 1, 1971, I was made Vice-President j .

I3 Construction and became department head for the Construction -

(. 'd Department and responsible for generating plant construction.

l 15 Q. And your professional training and background prior to i

I '$ joining Duke Power Company?

17 A. I have a Bachelor Civil Engineering Degree from North IS Carolina State.

19 Q. For whom do you work presently with the company?

20lA. I report to Warren Owen.

21 Q. All right, sir, I want tx) show you a document.that has ,

j 22 previously been marked as an Exhibit 'tx) Mr. Bradley's depo-23 sition. Can you identify that, sir? It's Bradley Exhibit 5.

24 g, ,es, I'm familiar with this document..

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25 Q. Does your signature appear onitheLlast page of'that?- ~

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. . - . - - . - - x. , u

• . _ . . . _ . . _ _ _ _ _ = _ _ _ . _ _ _ _ _ . - _ _ . . . _ . _ _ _ .

, -( i A. Yes, it does.

' I 2!Q. Does that indicate your approval of that document for the ,

3 Construction Department? l 4

A. For Construction.

5 Q. I understand that that plan and the team that Nonconformance

! l 5 Evaluation Team that Mr. Bradley chairs, resulted from a plan to 7 , address ways of identifying and handling construction deficien-a cies, nonconforming items, process control, and other things

'!developedunderMr.Owen'sgeneralsupervision, is that right?

'A. I believe that's correct.

't

.Q. Mr. Owen related that you, and I believe Mr. Grier for C ;l Quality Assurance and Mr. Dial for Design Engineering, met to 13 address this general area of concern, do you recall meeting 14 with Mr. Owen and those other gentlemen on that subject?

5 l A. I remember discussion on the subject. I don't remember

!$ that specific meeting though--

17 Q. Let me see if I can help you a little bit. I'm looking

!8 for a document, sir. I understand from Mr. Owen that this

team was originated sometime in the Summer of '82, does that 20 sound right?

2;lA.  ! That sounds right.

4 What I was trying to understand, and he referred me to you, 22 l 0 23 ' sir, was whether or not there was a work plan or memo or 24 general description of an overall plan to address this question

" .of more effectively using nonconforming items and responding '

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a 4 .to corrective action? ,

- l 2 A. I met with this team, as I recall, to hear a report which t 3, recommended implementation of this plan. Is that what you're  !

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4 referring to?

I 5 Q. Perhaps, perhaps. Do you recall a meeting with the members!

$ of the team, Mr. Bradley, and others? ,

7 A. Yes, members of the team. l B Q. And representatives of your department?

0 l' A . Yes, it was a report to probably the ones who signed it, C ias I recall.

i 11 'Q. You, Mr. Grier, and Mr. Dale? ,_

12 A. Yes, that's my recollection.

13 Q. Do you recall a meeting prior to that at which Mr. Owen

~

14 was in attendance where you discussed generally, not just this 15 team, but generally a plan to address more effective use of f6, nonconforming items, one or more meetings?

I 17 A. I do not recall specific meetings with Mr. Owen. There 18 was a great deal of discussion in this period about NCI's and 19 the evaluation of them and how they were handled, but I don't 20 remember specific meetings as such.

21 Q. Do you remember any written documents reflecting a plan 22 to address that issue beyond the team's procedure, that is, i 23 the document numbered 5 there?  !

24 A. N o ', I do not recall any other documents. l 25 Q. What was the purpose of the team, as you understand it, r-5 l k. . l

o _ . _ . _ _ . _ _ _ _ _ _ . _ _ . _ . _ .

J

( Mr. Dick? ,

2 A. It was to have a group of people who were expert in the 1

3 areas to look at the resolutions of the NCI's, and they came i

2 'out of the field and to see if we were doing a good job of .

5 w.riting resolutions and to see if we were looking at the generic implications of these and the root cause and, therefore g 7 getting the corrective action that would reduce the number of d them in the future as opposed to simply fixing whatever was We were looking for trends. We were looking

' related to that.

i,for generic issues and just improving the quality of the

'l process.

'2 ; Q.

I Why did you understand there was a need to do that?

'3 ; A. As I recall, the NRC had called to our attention NCI's

(. l 14 l where they did not feel that we had addressed the generic is ; applicability of the issue, and we had gone back and looked 3 j at a number of NCI's to make our own check to see if we were t

17 ; satisfied with the way we were handling them, and this team

'8 then studied the subject and made a recommendation. That came 19foutofthat.

I 23l0. Would that NRC observation have been contained in an 2' inspection report?

22 A. I believe that it was. It probably was the inspector open_ item at one time.

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23 2d Q. At Catawba?

25 A. Yes, I think only at Catawba though.I'm not sure. t 6  !

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( Q. Did it at least occur at Catawba?

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2fA. Well, it's a generic type concern, and it was increased i 3 i i emphasis from the NRC, and I believe broader than just this J

f licensee toward the evaluation of generic root causes of a 5 problem.

$ Q. Do you know the source of that increased emphasis?

7 A. I would have to speculate.

What is your understanding of it? The best of your under-3 l Q. '

1 0  : standing?

'O,A. If you read the bulletins that NRC puts out, you find  ;

11 some generic type problems that have occurred at more than one ,

12 location, and I suspect that NRC had some concern that the  !

13fproblemwasbeingdiscoveredatvariouslocationsratherthan

(_ 14

'being evaluated and reported in a way that would enable them j

'5 , to notify all licensees.

'$ ! Q. Was there a specific type of problem or just generally J the use of NCI's?

IB ,A. Just general. It was not anything specific that I recall.

i

• Q. Are you aware of any specific study, document, Nureg, or j 20 position paper of the NRC that reflected this general concern?

2'{;A. I'm trying to' recall whose Criterion 16, whether that was  ;

22 l an NRC Criterion or a Duke, that relates to generic appli- i 23 cability.

24 Q. Appendix B Criterion Corrective Action? i 25 A. I don't recall. It's what we refer to as--

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.( Q. Criterion 16?

2 A. Uh-huh.

3 Q. Let me ask if I can show you, you generally are familiar i

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with Appendix B to Part 50?

+

A. Yes.

$ -Q. Let me show you. This is criterion 16 Corrective Action,

' l Appendix to NCFR 50.

3 A. Yes, I believe that's the one. Then it was related to--

? It's Criterion 16 Evaluation.

' I O . Q. That is what this team was to address generally, more

't effective criterion?

'2'A. Perhaps broader than that. It was the total subject of 13 ' resolution of NCI's; and as this list as objective the

(~ '4 feedback of training materials, this was to improve our

5 handling, our understanding, and to avoid the problems in the i

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l future.

7 IQ.' Do you understand this to have been a product of the

'3 , responding to the Welding Inspector concerns at Catawba?

7 I don't believe it had any relation to the Welding jA.

i 20-concerns, no.

21 Q. Or the Task Fo'rce that addressed these concerns?

22jA. No, my recollection is that it was not related to that.

I 23 'Q. This process'of addressing these more effective use of 24 NCI's and the Criterion 16 Evaluation come before the Welder 25 concerns at Catawba?- Before late '81, early '82? '

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- m_-m____ . _ _ _ . _ _= , , .. _m_, . , ,

s 4 A. I don't recall.

I 2

4 Q. There's no date on that. <

t 3

• A .- I se'e. This is George Grier, did date his signature.

4 Q. What is the date on that?

5 A. July 30, '82. . .

t Q. That would have been af ter the Welding Inspector concerns?

7 A. Yes. ,

a ' Q. Mr. Dick, I want to show you a document dated January 6,

- l1982, can you identify that, sir?

a 10 A. Yes, sir.

i il

~Q. What is that?

12 A. This is a memo from Mr. Owen to Jim Wells and to me 23 ', relative to meeting with the special Task Force which he

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id I appointed to investigate the Welder concerns at Catawba.

13 Q. Let's mark this as the first Exhibit to Mr. Dick's 16i ; deposition. The memo from Mr. Owen to you and Mr. Wells, I

17 I have received from Jim Wells the plan which he proposes for i

13 the Quality Assurance Department, and I would like to raceive I i

a similar plan for the Construction Department before the 20 , meeting on the 12th. Did you prepare such a plan?

I 21 l A. Yes, I did. - j '

i 22 l Q. I will show you a document marked as Exhibit 5 to i i

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23 Mr. Owen's deposition. It's a January 11, 1982, document. l l

2d Can you identify that, sir?  ;.

?

-4 25 A. Yes, sir.

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( Q. What is that?

i 2lA. It's my memo to Mr. Owen dated January lith, which dealt i

• 3 with my plan for increasing awareness of quality in i

1. construction and response to the memo from him that you just l i

5 showed me. {

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• Q. That's the Quality Awareness Program?  !

I

'IA. Quality Awareness Program.

3 Q. Is that the plan he asked for and you submitted to him? i

• 'A. He asked me to develop a plan, and I developed that and C , submitted it.

>Q. Did you submit anything else to him at that time?

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'2 I.A. No, this was all.

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'3 I Q. I believe one of the things that this program or this i

I*jplan Quality Awareness Plan represents is items such as

" l bumper sticker that was brought into me, quality in the I*

, making, Duke Power Company Construction Department?

"'A. Yes, sir.

'8 l10 That's produced as part of the Quality Awareness Program?

A. Yes, sir.

20 ; Q. Let's see if we can fit this on the machine and mark i

'!that? !

f MR. GIBSON: It's clear that the original is going 23

to go on your car or your briefcase.

2#

Q. On my-head. .

25 I object if you put it up there MR. GIBSON:

10

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o( Q. Have you implemented the Quality Awareness Program? '

2 A. Yes, sir.

I 3 Q.. Describe it for me and tell me about it.

J A. I guess the most visible things, we have put posters at 5 the entrance to all of our projects, and we developed that

$ logo of the hand, which is on the bumper sticker, and that 7 appears on the posters, and to remind the workmen of their al role, we have this big banner as you come in that says 9 Quality is You, and then on the flip side on the way out {

!0 when they are leaving the project, they can see the poster

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i 11 that says Thanks for Quality. Then we formed-- May I use this I l

12 to refresh my memory and be accurate?

13 Q. Please do. ~'l

( 14 I A.

l The Quality Team of the Month. Where we select one crew, i

15 ! the Quality Crew of the Month, where we select one crew and I

'$ l we award them with a little sticker for their hardhat that i? has this hand logo that's on the bumper sticker. I wrote a 13 letter to the employee and sent it to their home address to 10 emphasize their role as an individual in Quality, and the 20 : bumper sticker was included in the letter. We have a couple of 21 departmental publications, one is called The Hardhat and 22

,another is called Supervision. And Supervision is produced 23 for our supervisors on a fairly regular basis, and we had an 24 article' on quality in it. As I recall, we did get an article  !

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25 on quality in our first edition of Hardhat, our departmental 11 .

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-[ newsletter. We produced a videotape which was designed to i

2 further this same theme of pride in workmanship, personal 3 pride. l 4

Q. What did you do with the videotape?

5 A. It was for use with the crews in the field.

$ Q. Was it shown to the crews in the field?

7 A. Yes, it was. My note indicates on here,this was my 3ljrecordofaccomplishments, these were commitments, and I l

'!recordedthemastheywerecompleted.

U Q. What was that, do you remember the name, was there a title

.to the film or videotape?

2 I just don't recall.

A.

l3 Q. Did you ever see it?

(. " l A. I did. I approved the script, and I saw the tape, but I 75! don'trecall.

16 Q. You know what the subject was?

I

iA. It was quality, personal pride, and workmanship.

'a l0 It would have been produced about the time period you had l*!done--

20 ,A. We had committed by June 1st and we came close to that, t

2! !and that would have been June 1st of '82. I believe that's 22 l generally the program. The posters at the job entrance and 23 l the quality crew of the month have been continuing.

2d Q. Was there any other thing of significance with respect to

?

25 your department that in addition to the items mentioned on that  !

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( plan, that is the January lith, '82, memo, reflected additional' 2 efforts on part of Construction Department to respond to these 1 concerns.

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2 A. We had some discussions that came out of some of the l I,

5 Welding Inspector concerns about the kinds of direction that I o they were giving to construction craft forces and through l

! l 7 ! supervision, as I recall, re-emphasized that it was the job  ;'

3'of the craft and their supervision to produce the work, and ,

i S that it was the job of the inspector to accept or reject the l

!? results and while still trying to maintain the relation i I

;and good communications between the two, it was to re-emphasize:!

i 12 l that inspectors are not responsible for directing the craf t I i

13 ,and the execution of work and that the responsibility for

'4  ! producing quality work lies with the craft and their super-  !

'F l vision. That was not a formal program. It was so elementary ,

$ that we really didn't feel it was necessary to have more than 17 ' just communication to supervision.

'S ; Q. In your opinion,.was that already in effect understood

'9 :l by craf t people, that relationship?

20 A. Ithinkthatwe,fromhearingfromtheinspectors, believed l' i

21 lthatcraftpeople'didsometimesaskinspectors'howcanI fix i

22 it or how can I do it or something like that, and that perhaps '

23 the inspectors were giving some directions. -We assumed that i 24 based on what we had heard.

25 Q. So this was to address that assumption?

13 k .

( A. Yes, to re-emphasize whose job it is to get the work done.

2 Q. That was passed down through supervision?

3 A. .That's my recollection.

Q. Do you recall any specific new training for craft or 5 training materials that communicated that message or anything 6 , else like that?

7 IA. Not specifically, although it's difficult to say that it 3 didn't influence the theme of supervisory and other training

! 7 ' materials that are, you know, in development at all times.

! I 10lThe role of the supervisor. But I don't recall that we j

'specifically moved to produce some course or--

'2 .Q. How about this videotape, did that deal with this subject

'3 I or was that something else?

i (. 14 I

'A. It was the theme of quality. It waa a motivational type 15 thing, pride in workmanship.

d !Q. It didn't deal with this particular point though?

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'7 iA.

I don't recall that it did. You could infer that since la j it was pointing to-- you're the one that produces quality now,

• *fdothejobyoucanbeproudof,anditwasdesignedtoenhance

. 20 our overall efforts,. reinforced overall efforts, and enhanced 21 fquality.

i It wasn't produced explicitly for the purpose of making _

22 lQ.

23 t this point?

24 A. Not just that, sir.

l 25 Q. Mr. Dick, are you aware of'any- before I do that, let me

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= . . . . . . . . - . . .--

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' mark that copy of the bumper sticker. ,

i 2 MR. GIBSON: For clarification, can we also mark his 3 memo to Mr. Owen?

d Q. I have that marked as an Exhibit to Mr. Owen's deposition.

5 If you want to make that an Exhibit to Mr. Dick as well, let's

$ l make the bumper sticker Number 2 and let's mark-- I've got a 7 second one is a copy of the quality in the making bumper sl sticker, and we'll mark 3 as what was previously identified I want to show you another document

• [ as Owen Exhibit 5.  !

10 December 16, '81, memo from Mr. Grogan to you? .I l

11 ! A. Yes, sir.

2 Q. Have you seen that?

13 A. Yes, sir.

(. I4

,Q. Does .that memo reflect that instructions through super-

'S } vision in that first paragraph, instruction regarding the 16 role of the craft and inspectors?

'7 I don't believe so, Mr. Guild. All of this was happening A. .!

13 in the same general time frame, although this might or might l'

not have been related. I think this was more related to i

20 i some specific incident.

21 Q. This was on'De ember 1, 1981, John Rogers, Project Manager, t 22 met with Charlie Aycock, General Superintendent, to discuss (

23 the subject. Charlie was directed to ccmmunicate with his t

'24 staff and through the level of supervision to' employees that 25 construction builds in quality and QA verifies.it.  :

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s A. Those words do reflect what I was telling you about earlier

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j 2lofthatpartofit.

3  ! Q ., It goes on that construction employees by their actions l J ' show we mean it. Intimidation, coercion, or kidding will not l

t 5 be tolerated. Charlie was also instructed to confirm his 3 , instructions were carried out?

l 7

'A. Yes, I think that the more accurate answer would be there i were a number of things going on in that period, and this 7 , addressed several of them. l j .

t What is the reference to the intimidation and kidding?-

t

'O ; Q.

A. My recollection is that we had an incident between the 12 craft and inspection and had investigated it and wanted to ,

d . reinforce what we expect of people and their conduct and

( Id l; behavior and, again, it was through supervision ~ communicating i

is --pectations and securing confirmation that had occurred.

i 4 Q. Counsel, I'm trying to-- is this a new copy we have 37 just made?

18 MR. GIBSON: You gave the Reporter yours. I gave that

' i 39 to you.

20

,Q. Thank you very much. Are you aware of a training film 21 called The Inspector, Mr. Dick?

22 A. Not by that name, no, sir.

23 Q.. Do you know whether or not.that film has been used in d

24 the training of the craft? .

25 de, sir, I don't know.

A.

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Q. What involvement did you have with the Management .

2 Analysis Company, Mr. Dick?

3 A. As it relates to?

4 Q. What kind of involvement have you had? I'm looking at a 5 couple of letters that are from them to you with regard to 6l apparent consulting activities with the Construction Department.

7 A. I have used Management Analysis and am using Management 8 Analysis as a consulting organization on the matters.

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• 'O. What have they done with you? I O ' A. They consulted with me last year in developing a i il reorganization of construction on Catawba and have had a 12 continuing role in consulting to me in work measurement and 13 work improvement,those sorts of things. .

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14 +Q. Have they addressed the relationship between construction 15 l craf t and Quality Assurance?

16 A. I would have to say yes because one of the things that 17 they were doing was identifying who was responsible for 38 interfaces with all the departments that we do business with 39 and Quality Assurance is one of those.

20 Q. With regard to that interface, what did they do?

21 A. Simply identifying who was responsible for it, organi-22 zationally.  !

t 23 Who does?

Q.

24 A. The Engineering Manager is the principal interface with i

25 Quality Assurance.

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Q. Who would that be at Catawba?

- i 2lA. Sam Dresler, although the construction organization also 3 thas an interface and Quality Assurance is the one that's not i

1 J ^ clean in that there's not one part of the organization that 5 manages the interface that they both have responsibility.

6'Q. How about the interface between the inspector, QC 7

inspector, and craft? Did they address that? The Management a f of the System Analysis Corporation?

fA. No, this was a very general type of interface relationship. i i

G It was more like a, jurisdictional statement type interface.

Q. What else has MAC done for you?

2 ! A. For me?

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'3 ! Q. For Construction.

( i jo. Only what I mentioned which is the design and implemen-14 0]tationofanorganization,ofareorganization, and then

'$ a continuing presence on methods,primarily methods, improvement ,

17 f and reporting and things to make the work more effective.

I G ! Q. Why did you use MAC to do that?

I

!A. I have been familiar with their work for some years and 20l:have known some of the principals even before they were part i

2 of this company, a'nd I think specific answer to your question 22 is that I attended a conference in Phoenix in the Fall of 1981 23 and it was on project management and how to organize'for 24 effectiveness and Ron Stenson, the President of Management 25 Analysis Company, was'on the program,and I was impressed with {

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some of the things that they had done for other people

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.' ,in matrix type organizations, and I guess that was the seed 3' that was planted, and then I knew I wanted to come to some kind.

I J 'of an area organization that cleaned up the accountabilities 5 that are in my department, and so when I decided to do some-o thing about that, I remembered this; and as I recall, I gave f

7 lMr. Stenson a call and asked them if they had an interest in ,

3,this, and they came and visited me and outlined the plan for spending about a week with a couple of people to see what kind ;

10lof help they might could give, and that led them then to the i I

i 11 decision too.

12 Q. Who else did you understand they had done this work for

3 ' or done work for?

( 14 MR. GIBSON: Mr. Guild, I hate to interrupt. I'm

'5 having trouble understanding how this is related to Quality 16 Control and Quality Assurance in Welding. I can see some 17 general information about MAC and the involvement, but it 13 seems to me you're getting quite detailed and far afield from

the scope of the deposition. If there's.some connection you i

20 ~ can help me, and we can proceed.

21 ! Q. I think I can proceed very quickly without interruption.

l 22 l; I can give a long dissertation. The hour is late, and the

! 23 time rapidly ticking away, and I expect the most effective way i

24 is to let me finish up with the witness. Are you instructing 25 him not to answer the question?  !

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s MR. GIBSON: Absent some further-- ,

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2 Q. MAC is obviously going to be testifying in this case  ;

3 very likely and their track record and work in other areas, 4 ,particularly as it relates if it does at all, to welding on 5

the one hand and the inspector Task Force and its concerns, 3

and on the other hand the same time or shortly thereafter 7 advising Mr. Dick in Construction Department what they have a ! done in terms of advising--

MR. GIBSON: I will let him answer the question. Again, ,

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clIwantedtoseehowyousawtherelevance,andyouhavedone ii that, and I.will ask him to answer as fully and completely.

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2 ,A. Would you restate the question?

I 13 i Q. Sure. Who had you understood MAC had done work for?

14 A. Numbers of companies. Pennsylvania relative to cost, is of Susquehanna Southern California Edison relative to project to lmanagement type organization. .

17 ' Q . What facility, if you recall?

ta A. Probably Santa Nofry. I'm being careful because I'm aware

9 of people they have. worked for since I employed them, and those 20.are the only two I can think of before.

21 i

Q. All right, sir. Are they responsible for the work team 22 ' approach being used at Catawba? I may not be using the 23 right term, but a team where people from a number of disciplines s 24 work together including inspectors, to expedite and make 25 more efficient the scheduling of work. j f

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( A. I suspect one of my folks would say that he is more ,

i 2; responsible for that than we did employ MAC te do paper flow I

J' study t6 see if there was some way to oil up that machine, d

but I believe that this team probably was conceived earlier 5 in our experience and was just introduced at Catawba about the o time their reporting was being implemented.

7 Q. Did the MAC paper flow study review the nonconforming 3 item process control documents?

9 A. I don't recall that NCI's were a major part of that. ThisI l

'O was more related to how we put together the packages that il '

the erection forces needed instructions to them.

12 Q. Instruction procedures?

13 A. Well, not capital C, capital P, construction procedures.

( Id Q. Do you recall meeting with Mr. Swisler sometime in February

$5 of '82 with regard to the welding se. carate Task Force?

'6 A. I remember Mr. Swisler coming to my office to discuss that, 17 yes.

I3 Q. Let me show you a document, these are Mr. Swisler's notes l'

of that meeting. If we can perhaps either get a copy of this 20 or if we can find the company's copy. Let's mark this, these 23 notes, as 4. Mr. Dick, have you had a chance and opportunity, 22 this is Mr. Swisler's notes of that interview with you? You 23 recall it occurred on or.about the 17th of February?

24 A. That general time frame.

25 Q. John Jackson is the principal with MAC that you have known?!

21  :

b

A. Yes, sir.

[

2 Q. I'm going to follow through this. This note says 3 perception of problem not specifically knowledgeable. You ,

i I

4

, expressed you were not familiar with the problem?

5 A. That probably meant I didn't know the details.

$ ' O. What appears to be page 1 says Welding Inspectors used to 7 work for him. That refers to the point before they were moved 3 over to the QA Department when QC was under construction?

?'A. Yes.

7 10 : 0. Wonders why they never had the present problem when they i

'l (inspectors) were in construction. Then it goes on and makes 12 some observations. What did you mean by those comments? What 13 did you tell Mr. Swisler on that score?

( 14 I guess he was relating to me or perhaps I had heard from

A.

i 15 'somewhere else some of the concerns that the welders were 16

expressing, and I didn't recall that we had ever heard these i

17 before, and I wondered what the difference was. I was asking 18 him, asking if he knew.

19 Q. Did you talk about the different work relationships?

20 A. I don't recall specifically.

21 Q. How about this' point reflected in the notes no longer giving 22 directions to welders?

23 A. That's familiar phrase and a familiar subject. I don't 24 right now, I can't think how that would connect.

25 Q. Well, did you relate _an opinion that the Welding Inspectors:

1 22 i

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MII4 , , , , , . , ,

a

[ formerly when they were in construction, used to give 2ldirectionstoweldersandthatonlyhasbecomeaboneof

3. contention since they were transferred back over to QA?  ;

4

A. I'm not sure. Would you ask that again?

j 5 Q. Did you hold the opinion and maybe expressed that to  !

6 ! Mr. Swisler that when the Welding Inspectors were under 7

Construction, that it was okay and common for them to give i i

9 i directions to Welders as the note suggests here?

• A. I don't think I would have said that. l 10 Q. Were you not aware one way or the other on that subject?

11

'A. It says discussed differences, and I presume that means 12 what is different now from before.

13 Q. Yes.

( 'd A. And work relationships and one of the differences is that ,

15 the inspectors no longer give directions to welders and 16 just a simple statement of fact that is a difference. Now, 17 what conclusions we came to, I don't recall.

13 Q. Did you express the opinion reflected in this note feels  !

19 problem is 92% management, not technical?

20 A. I did not recall having said that.

21 Q. You don't rec'all using 92? ,

22 A. No, sir. '

23 Q. You didn't have that precise objective measure? l 24 A. I would be surprised if I said that.

25 Q. Did you express the view, and I'm looking at the second I 23 b  !

- 4 page now, proper use of NCI not to record preplanned variation ,i

{ ,

2 ! some design or procedure but to record inadvertent departure. '

, i 3

i A ., That, I think, is his statement since I think it said a Bob Dick agreed.

5,Q. Mr. Swisler seems to be reflecting what he is talking

$ about here?

7 A. I believe that's right.

B Q. It says here wanted to know if Tech Support at Catawba I

• [wascapable. Is that your question?

1>'A. That sounds like me. I would have been taking advantage a

fofsomeoneIknewwasanexpertandhadbeenaround, and I was,

'2 you know, getting some-- asking his opinion of the qualifica-

'3 tions of our folks down there..

! ( 14 Q. That would be Construction Tech Support?

i 15 ' A . Yes, sir.

16 Q. Did he reflect an opinion?

17 A. M? recollection is he said they were capable.

ia ,

Q. Need to work on problem with Grier to improve QC relations 19 within QA/QC and with Construction and craf ts, develop 20 cooperation not I got ya approach. Do you remember that dis-21 cussion? .'

i

! 22 A. I remember many discussions along those lines. We wanted 23 to get out of, you know, I have got either way. I make 24 mistakes. I caught you or you caught me. I don't recall 25 whether he initiated it or I initiated it because I really was i 24

(

a i

asking him what was going on and what the problem really was.  ;

(  !

2;I Q. Let's look at Number Page 1 and it has a 1 in' the right-3 hand corner, the third page in my stack. Now the note here 4 .under Number 6 Concerns, they : reflect your discussion, your i

5 statement to him?

6'A. No, sir, after reading this, I believe this is a pre-7 prepared checklist that he made to discuss with me.

3 ; Q. Let's look on the second page, Quality Awareness Program, o

.and then the note says Actions Taken By Construction to ,

10' Resolve Their Part of the Problem. Did you write him j

i 11 I essentially what you have told me on the subject?

12 l A. I'm sure if he asked me, I told him. I didn't remember 13 this specifically, but in the time frame, I'm sure I must have.

( 14 Q. Anything else that you have told him that you're aware of

'S now that you haven't discussed with me about that issue, 16 Quality Awareness Program?

17 A. No, sir, I don't remember anything else.

la Q. Well, thank you very much. That's all I have for you.

19 EXAMINATION: (By Mr. Gibson) 20 Q. Mr. Dick, in your opinion, and professional judgment, is 21 ,the Catawba Nuclear Station being safely built?

22 A. Yes, sir, it is. I I

23 MR. GUILD: Mr. Gibson, Iguessthatopensawholelinef' 2d of questions. l I

2$ RE-EXAMINATION: (By Mr. Guild) 25

( l

w. - - . - - . . -_, .. .. . - . _ - . _

. . _- . . . . . .. - . _ =.

)

s i

i . Q. What's the basis for you expressing that opinion, sir?

(

I 2 A. The basis for my expressing that opinion is that I have i

l 3 been very much involved and responsible for the organization d , that is in place there to build the plant. I know the i

5 qualifications of the people. I have for the past fifteen 6 years been involved in the development of the Quality Assurance 7 Program, although in recent years, as I have gone up in the i

3: management structure, of course I have not been associated with 9 the details; but we have a program that assures the quality.

10 I have looked at all significant issues through the years, and 11 lI know of nothing that would degrade the quality of that plant.

12 Did you investigate the Welding Inspector concerns?

Q.

4 13 A. I did not personally investigate it, although I assigned 14 a knowledgeable individual from my staff to the Task Force.

] 15 l0 What I want to be clear on, Mr. Dick, since your lawyer 16 asked you-the question in the fashion he did and that was for 17 you to express a professional opinion, you know, I can appre-1 l 13lciateyourlastresponseisthatyoudon'tknowofanything 19 and that I can understand on the basis of what you have told 20 me so far, but I want to know is when you. talked.to Mr. Swisler, 21 you expressed a general lack of specific knowledge about the 22 Welding Inspectors' concerns. There is no other knowledge 23 you have about those concerns that you-haven't told me, have j 24 you, that would give you the basis for expressing an opinion- _

25 on that-subject? If there is, I want you to tell me about it. ,

o 26 k

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~.. . ._

. . - . . - _ - -~.

s i

Let me be sure I understand what you're asking, not

( A. ,

i 2 specifically knowledgeable meant that we had a Task Force 3 that at-that time was investigating the concerns. Now, I have 4 since reviewed the findings of that Task Force. At the time 1

5 I reviewed them, I understood the technical issues that were i

6' involved and there was not anything in that investigation that 7 I felt compromised the quality of the program.

8 Q. That's on the basis of your review of their report?

• A. Yes, sir.

n) Q. You didn't do the investigation yourself?

11 A. No, sir.

12 Q. You don't have personal knowledge of that investigation 13 except for reading the report?

( 14 A. I read the report. I met with the Task Force to hear their 15 report verbally and explained.

lo , Q. That's the basis for your conclusion with that issue about 17 the results of their investigation?

is A. The results of their investigation. I asked Mr. Swisler l' if there was any technical problem in any of the concerns, 20 was there really anything wrong at Catawba.

21 Q. What did Mr. Swisler say.to that?

22 A. He said no.

23 Nothing really wrong?

Q.

24 Th't a from a safety hardware acceptability, there really l A.

25 wasn't anything wrong. [

27 g

k.  !-

1

l M

Q. He told you this when?

(

i 2 A. Yes, sir. t 3

Q. .When- did he tell you that?

4 A. During this interview.

S Q. In February?

$! A. Yes, sir.

7 Q. The Task Force hadn't completed its work then, had it?

a A. Based on his investigation to that point.

• Q. Which was talking to you and interviewing these other 10 people?

Il

'A. Yes, sir.

12 Q. That's all. Thank you.

13 14 ROBERT LACY DICK 15 16 17 18 19 20 '

21 22 4

23 24 25 28

(-

' i f STATE OF NORTH CAROLINA ) i

) CERTIFICATE l 2

COUNTY OF MECKLENBURG )

3 ,

4 I

5 I, the undersigned Commissioner and Notary Public, in 6 and for the State of North Carolina, do hereby certify that 7

Robert Lacy Dick was duly sworn prior to the taking of his 8

deposition. ,

• I do hereby certify that the foregoing twenty-eight pages

! i

'O constitute'a true and accurate transcript of the evidence given i by the said witness as taken down by me and transcribed under 12 my supervision.

'3 This the ninth day of August, 1983.

( 14 15 BARBARA V. HAAS to Commissioner and

,7 Notary Public My Commission Expires:

is April 23, 1987 19 20 21 22 23 24 25  ;

29 l

( l

1. l

. . i INDEX

_ {'

2 l

l 3 Exhi bit- 1 Page 9; Line 15

' 4 Exhibit 2 Page 10; Line 20 5

Exhibit 3 Page 15;-Line 8 I

6 Exhibit 4 Page 21; Line 20 7

1 3

7 10 i

h 12 13 i . 14 15 16

'i 17 18 19

.20 o

I

' 22 23

\.

l 24 l

25 '

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