ML20214C130

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Applicant Exhibit A-112,consisting of Partial Undated Holley Deposition Re Harassment by Comstock QC Inspector
ML20214C130
Person / Time
Site: Braidwood  
Issue date: 08/12/1986
From: Holley
AFFILIATION NOT ASSIGNED
To:
References
OL-A-112, NUDOCS 8705200562
Download: ML20214C130 (8)


Text

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3g Q

All right.

Did Mr. DeWald ever threaten you with

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any penalty, any punishment, any reprisal, termination in the 1

j event that you ever failed to achieve a certain numbYa'r of' Jr

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inspections per day?

1 A

No.

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, !6 Q

All right.

Are you aware of any situation where any

[7 Comstock QC inspector was ever threatened with reprisal or

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termination or penalty of any sort for failure to accomplish a g

particular number of inspections per day?

9 f.M g L10 A

No.

f1 Q

5 Let's turn back to Deposition Exhibit Number 2 A

@ l2 you aware of any harassment or intimidation by any constock f

13 supervisortopressureanyComstockQCinspectortoknowingg

[d14 violate established quality procedures?

15 A

Other than the Rick yder in no.

, 16

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g Q

Okay.

And that is the Rick Snyder/Saklak incident?

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. 17 A

Yes.

g is Q

All right.

We will return to that.

Are you aware

?

19 of, or have you ever personally been subjected to, 1

any "20 harassment or retalitory treatment such as threats of violence because of your expressions of quality or safety concerns?

21 22 A

No.

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!c 87 Q

Are you aware of any verbal abuse, either of

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j yourself or any other constock inspector because of the

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expression of quality or safety concerns?

s h [4 A

No.

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$ (5 Q

Are you aware of anyone who was terminated as an 6

employee because of his or her expression of quality or safety

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{ L7 concerns?

4 ?

r3 A

Yes.

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'g Q

All right.

Who was terminated because of his or her y,

fgg expression of quality or safety concerns, in your opinion?

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A Mr. Worley Puckett.

U 32 Q

And what leads you to believe that he was terminated 3

because of his expression of quality or safety concerns?

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'14 A

To the best of my knowledge, he wrote a NCR on 1;

t g5 welding procedure.

And apparently the management didn't like e

! 16 how he worded it or something to that effect.

Once again,

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! 17 everything I'm saying is just hearsay, okay.

18 Q

All right.

I appreciate that.

That was going to be 19 my next question.

20 You had no personal knowledge of the NCR which 81 Mr. Puckett may or may not have issued, do you?

22 A

No I

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i h 88 1

Q Do you have any personal knowledge of the conditions i

under which Mr. Puckett's employment with Comstock ceased?

A No, just one day I showed up and he wasn't there.

He had got fired.

e Q

so any information that you have is merely hearsay (6

or rumor.

You have no personal knowledge?

bq A

No personal knowledge, nothing in writing.

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!g Q

Okay. - You have never been given any access to any

.9 of Mr. Puckett's pesonnel files, have you?

f

'O A

No.

1

1 Q

You were never any party to any conversation that i

i2 any supervisors may have had regarding Mr. Puckett's i

l performance or the quality of his work, were you?

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A Nothing more than just talk.

15 Q

All right.

You were not a party to any --

16 A

No.

. 17 Q

-- official --

(9 A

No.

19 Q

-- conversation of any sort regarding Mr. Puckett's l

20 performance?

I.

1 A

No, nothing official.

12 Q

Anything you may have heard would have been meroly i

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L, 89 shop talk, rumor or gossip regarding Mr. Puckett?

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2 A

Yes, exactly.

,3 Q

Other than what you have just said, in response to 4

my question about Mr. Puckett, are you aware of the h)$

! N termination of employment of any employee of Comstock because f6 of his or her expressions of quality or safety concerns?

f7 A

No.

3 Q

Did you personally ever work with Mr. Puckett?

$ 9 A

Yes.

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[to Q

Can you describe what the nature of that work with t

fg him was?

i 12 A

Mr. Puckett was assigned as a Level 3 welding inspector or engineer, or whatever you want to call it, and he 24 was to help out with the welding procedure and any problems 15 thac might have arised.

And the only work that I did with him 16 was help him do a littic bit of research of the procedures, t7 especially when he first got there.

,e Me, along with several other inspectors, just showed 9

him, you know, the procedures and helped him get along with 3

it.

And if he had any specific questions about the company's interpretations, just how we would help any new hire.

1 Q

Did he spend a lot of time with him in that regard?

i

4, 90 A

No.

Maybe a total of twenty or thirty hours, but

.2 that's over a period of two months. So that's not very much at 3

all.

s 4

Q Did he have a lot of questions regarding the

'5 Procedures?

f6 A

Ch, yes.

He was always full of questions.

h Q

All right.

Did you generally have answers for him 7

1 I.3 about the procedures?

$,I g A

A No.

.v10 Q

Do you know whether Mr. Puckett was ever certified 1

,11 as a Level 3 inspector by comstock at Braidwood?

f12 A

I don't know whether he was ever certified or not.

13 Q

Did you ever go to Mr. Puckett and ask him questions 14 about procedures?

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( 15 A

Not about procedures, about -- I would ask him, you

.' 16 know, general knowledge about welding. Q thought he was very I

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',17 knowledgable in the welding area.

I l18 So, =e along with many other people asked him 19 general knowledge about welding, not specifically about our 20 own procedures.

21 Q

And did he generally have answers for you?

22 A

Most of the time, yes.

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_.... a ~ ~ w 92 not be noted because of his or her expression of quality or I-2 safety concerns?

$13 A

No.

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Q Are you aware of the assignment to any person, any i s I 75 Comstock employee, to perform burdensome or menial special d f f6 projects because of his or her expression of quality or safety

'[' 7 concerns?

/. 3 A

No.

..g Q

All right.

Let's turn now to the incident you 10 referred to before, the Rick Snyder/ Rick Saklak incident.

(11 Do you recall what happened between Mr. Snyder and t

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i l2 Mr. Saklak that you referred to several times?

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A Well, I wasn't present when it happened but from talking with other individuals, and including Mr. Snyder,

'14 Mr. Saklak apparently said some threatening remark because he 15 didn't want to sign off a specific document.'

'6 He thought it 37 was not the correct procedure in signing it off, something to i<

B that effect.

1 Okay. You did not observe the discussion between i

.9 Q

0 Mr. Snyder and Mr. Saklak --

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A No.

I wasn't aware of that --

i Q

Mr. Holley, I'm going to --

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-- until several hours later.

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2 Q

Okay.

I'm going to ask you to let me finish my r.

l3 question.

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A Okay.

5 Q

It sometimes takes me a little while to get them

'6 out, but in view of that if you don't hear what sounds like a i

h7 question mark at the and of what I'm saying just give me a few jr p3 moments to complete it.

i I 9 But, in other words, what I just understood you to U

[1g say -- and correct me if I'm wrong -- is that you were not an h

(11 observer to any discussion Mr. Saklak and Mr. Snyder may have i

f32 had regarding Mr. Saklak's request or demand to Mr. Snyder to

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3 sign off on something, and you weren't aware of that incident gli until several hours after it happened; is that correct?

o 733 A

Yes, it is.

16 Q

All right. And any information you have is based on j

/7 whatever Mr. Snyder may have told you?

1 4

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!}g A

Yes.

t l19 Q

All right. Did you ever discuss the incident with 1

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30 any other Comstock inspector?

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l 21 A

I'm sure I did with other people.

Everybody, you l

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i l12 know, would like to be aware if something happens, when l

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1 Q

You didn't ask him specific questions about Comstock

.2 procedures, or procedures that are qualified for Braidwood by 3

Comstock?

4 A

No.

5 Q

All right. So you don't know -- or, can you tell me, 6

was he familiar with comstock procedures?

7 A

After he had been there for a month, and all he did i

was sit and read the procedures I would imagine he was very

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well aware of them.

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Q Did you ever have occasion to ask him any questions about Comstock procedures?

A No.

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Q So, you are just speculating right now; is that correct?

r A

Yes.

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Q Are you aware of the transfer of any Comstock employee to an undesirable job because of his or her hli expression of quality or safety concerns?

j A

No.

Q Okay. Are you aware of the transfer of any comstock I

I employee -- by that I mean Comstock QC inspector -- or other employee to work in an area where quality deficiencies could

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