ML20214F161
| ML20214F161 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 12/05/1986 |
| From: | Mark Miller ISHAM, LINCOLN & BEALE |
| To: | Maggio J ACE-FEDERAL REPORTERS, INC. |
| References | |
| OL-A-187, NUDOCS 8705220432 | |
| Download: ML20214F161 (250) | |
Text
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December 5, 1986 Ace-Federal Reporters, Inc.
444 North Capitol Street Washington, D. C. 20001 ,
Attention: Mr. J. Maggio
- ' Re: In the Matter of Commonwealth Edison Compe.ay (Braidwood Station, Units 1 and 2),
Docket Nos. 50-456 and 50-457 .
I Gentlemen:
In accordance with the rulings of the Licensing Board on Thursday, December 4, 1986, enclosed is a copy
- of what has been marked as Applicant's Exhibit 187, the
- entire transcript of the deposition of Manfred L. Goedecke.
Copies of this deposition had previously been served on the Board and the parties.
Yours very truly, MIM:es
.LLA #%M Michael I. Miller enc.
cc Service List w/o enc.
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30a/SIG p7-6G 8 -/F7 1 1 UNITED STATES OF AMERICA ~"
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( 2 NUCIzAR REGUIATORY COMMISSION
'87. APR 22 P6 :32 3 BEFORE THE ATOMIC SAFETY & LICENSING BOARD -
CFPL.: ..
4 00CHEr,ry y _ .o r y ah t NC-!
5 ------------------t
, - 6 In the matter of: : Docket Nos. 50-456 7 COMMONWEALTH EDISON COMPANY : 50-457 8 [Braidwood Nuclear Power Station, :
Units 1 and 2) 9 :
10 ------------------x
.N.
11 Isham, Lincoln & Beale ~
- .. 12 Three First National Plaza
. 13 51st Floor l 14 Chicago, Illinois 15 March 12, 1986 16 Deposition of: MANFRED L. GOEDECKE
- l. 17 called for examination by Counsel for Licensee, Commonwealth 18 Edison, pursuant to notice, taken before Suzanne B. Young, i
19 a Notary Public in and for the District of Columbia, when l
20 -------------------------------
l 21 ANN RILEY & ASSOCIATES, LTD.
22 1625 I Street, N.W. 293-3950 Washington, D.C.
l S
i
(
- -- - - - -^ - - '
2 1 were present on behalf of the respective parties:
( 2 3 APPEARANCES: .
4 For the Licensee Commonwealth Edison company:
l 5 MICHAEL MILLER, ESQ.
6 Tsham, Lincoln & Beale 7 *Three First National Plaza
- 8 Chicago, Illinois 60602 9
10 For the Intervenors BPI, et al.:
4 11 ROBERT GUILD, ESQ. -
l 12 109 North
Dearborn,
Suite 1300 l 13 Chicago, Illinois 60602 14 15 ALSO PRESENT:
16 ROBERT L. STOBER, ESQ.
17 Vice President & Assistant General Counsel 18 NPS Corporation 19 300 Harmon Meadow Boulevard 20 Secaucus, New Jersey 07094 21 22 I -
3 1 C0NTENTS 2 -
(
3 Witness: Examination by: Page:
4 MANFRED L. GOEDECKE Mr. Miller 5, 75, 238 5 Mr. Guild 133 6
7 ***
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8 EXHIBTS Page:
9 Exhibit No. 1:
_ 6 10 Resume of Mr. Goedecke consisting of 11 4 pages.
12 f [ 13 Exhibit Nos. 2 & 3: 74
( 14 Documents entitled, " Employee Performance 15 Appraisal & Development Plan. Exhibit 2, period 16 8/1/79 to 8/1/80; Exhibit 3, period 7/1/80 to 5/1/81.
l' l
17 18 Exhibit No. 4: 75 19 A memo from Goedecke to Keegan dated 20 10/29/81.
21 22 O
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... . ._ . . ~ . _ . . . -. ._ _ _ . . . .
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1 EXHIBITS (Continued.) Page:
(
2 Exhibit No. Si 77 1
' l l
3 A form entitled, " Performance Evtluation" 4 dated 4/19/82.
1 0
l 6 Exhibit No. 6: 91
. 7 A meno from Goedecke to Biller dated j 8 4/20/82.
9
, 10 Exhibit No. 7: 94 11 Performance Evaluation for the period ,
12 4/15/82 to 4/1/83.
/ 13
[' A4 Exhibit No. 8: 128 L
15 NRC Inspection Report dated 4/16/82.
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16 17 18 .
19 20 21 22
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- 5 1 PROCEEDINGS
{
2 (10:15 a.m.)
3 MR. MILLER: I would like the record to reflect that 4 this is the deposition of Mr. Manfred L. Goedecke, taken at 5 this time and place, pursuant to agreement of counsel and the 6 witness.
.Whereupon,
[7
. 8 MANFRED L. GOEDECKE, 9 having been called for examination by counsel on behalf of the
, 10 Applicant, and being first duly sworn by the Notary Public, 11 was examined and testified as follows: ,
, 12 EXAMINATION
/' 13 BY MR. MILLER:
' I~
,14 Q Mr. Goedecke, would you state your name for the 15 record, please?
- 16 A Yes. Manfred L. Goedecke.
17 Q Mr. Goedecke, by whom are you employed presently?
18 A Presently, I am on leave of absence from Nuclear 19 Power Services, Inc. in Secaucus, New Jersey.
20 Q I would like the Reporter to mark -- before I do 21 that, where are you currently residing, sir?
22 A I am currently residing in West Germany.
( -
4 _ _ _ _ _ . - _ _ _
6 i
1 Q For how long have you been there?
2 A Since January of this year.
('
3 MR. MILLER: I would like the Reporter to. mark as 4 Goedecke Deposition Exhibit No. 1 for identification, a four 5 page document, which has Mr. Goedecke's name on the first 6 page, and it appears to be a resume of his professional 7 experience. *
- 8 [Goedecke Deposition Exhibit No. 1 9
was marked for identification.]
10 BY MR. MIIJ2R:
11 Q Mr. Goedecke, you have in front of you a copy of 12 what I have marked; do you not?
! [ 13 A Yes; I do.
l
! 14 Q First of all, I would like to direct your attention
- 15 to the heading " Education" on the first page of Exhibit
- 16 No. 1. It indicates that you art a graduate of a trade school 17 in Saarbruecken, Germany, ornamental ironworks and welding.
18 Was that a trade school that you attended as part of 19 your high school education or subsequent to high school?
20 A As part of.
21 Q How many years did you spend in the trade school?
22 A Three and a half years.
. .. . ._ . _. . _ _.. . : _ _ _ -_ _ . . __ ..L -
7
. 1 Q What year did you graduate from that school, sir?
(- 2 A In 1963.
3 Q When did you first come to the United States? -
4 A . 1964.
5 Q By whom were you employed when you first came to the
, 6 United States? .
7 A H&H Machine company in Maryland.
8 Q What were your duties with H&H Hachine Company?
9 A Machinist and welder.
10 Q Generally, what was the nature of that company's 11 business?
- cl R@ , , ,
12 A The repair and*' work,# the manufacturing of various /* /
i 13 machine parts.
t s.
14 Q How long were you employed at H&H?
15 A on and off, I would say approximately two years.
16 Q By whom were you employed after H&H?
17 A After H&M, I returned to Germany for a six month 18 period. I was employed by the German Labor Service, which 19 supplies manpower to the U.S. military.
20 Q Did you have any specialized technical 21 responsibilities in that position?
I 22 A Well, the installation and maintenance of 4
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8 1 communication devices for military use.
2 Q After this six month stay back in Germany, did you 3 again return to the United States? ,
4 A Yes; I did.
5 Q 'By whom were you employed?
6 A The H&H Machine company.
7 'Q The second tour du'ty with H&H, how long were you 8 employed by them?
9 A Again, approximately two years.
10 Q That would take'us to approximately 1968?
11 A Just about; yes.
1 12 Q Did you then leave H&H and go to another employer?
I 13 A- Yes.
I 14 Q What was the name of that employer?
15 A. Bechtel Corporation.
16 Q In what capacity were you employed by Bechtel?
17 A In the beginning, as a plumber, pipefitter, welder.
18 Q Were you a, member of the Union in connection with j 19 this job as a plumber, pipefitter, and welder?
20 A Yes, sir.
i 21 Q on what project or projects did you work as a 22 plumber, pipefitter and welder for Bechtel?
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1 A My first assignment with Bechtel was the Morgantown
( 2 Fossil Power Plant, in Morgantown, Maryland. ,
l
- 3 Q How long did you work on.that fossil plant?
1 4 A Two years, approximately. '
5 Q Did you work on any other projects for Bechtel? I 6 A Yes. My second assignment was at Calvert Cliffs l
ti 7 Nuclear Power Plant, about 1970. -
- 8 Q What were your duties? Were you also a plumber, 9 pipefitter and welder at the Calvert Cliffs project?
,- 10 A Yes.
11 Q For how long did you hold that position in Calvert .
12 Cliffs?
13 A I would have to think. I believe it was
. (
14 approximately three years.
4 15 Q During that time, were you promoted by Bechtel to i 16 'any other position?
17 A Well, previously at Morgantown, I was promoted to 18 foreman.
19 Q Were you a foreman at Calvert Cliffs?
20 A No.
l 21 Q You were back in journeyman status?
l 22 A That's correct.
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10 1 Q Did you leave Bechtel in 19737 2 A No; 1975.
3 Q You worked approximately three years at the Calvert 4 Cliffs plant. Did you have another assignment with Bechtel?
5 A I'm missing two years somewhere; right?
6 Q I think so.
?, 7 A It was various small projects connected with the 8 Union. To list those, I worked for B. ,F. Shaw for some time 9 on a fossil power plant. I worked on numerous industrial l 10 buildings. .
I
', 11 Q This was all in the 1968-1975 timeframe?
12 A That's correct, after the assignment at Calvert j ( 13 Cliffs.
I 14
+
Q I see. Did any of your duties for Bechtel
- 15 Corporation involve inspection of welds?
i 16 A Yes; they did. As a welder, you are the first line 17 inspector.
l 18 Q Did you obtain any certification as a welding 19 inspector in this period of time?
20 A No; I did not. Tnis power plant, by the way, was 21 governed under ANSI requirements, nuclear power requirements.
22 Q Which power plant, sir?
( -
l
_c 11 1 A Calvert Cliffs.
( 2 Q What'was the code you referred to? ANSI?
3 A Yes; ANSI, B31.1.
~
4 Q Is that the predecessor to the ASME code for nuclear 5 power plant construction?
6 A Yes. Let me correct that. It is not the 7 predecessor. That code is still a valid code today, except .
8 today it is called power piping.
9 Q It has been supplemented, has it not, by the ASME?
{- 10 A Today, general industry practice is to use ASME for 11 nuclear construction. Previously, it was the ANSI standard. .
12 Q You left Bechtel Corporation in 1975. By whom were 13 you employed then?
.\
14 A By Stone & Webster Corporation.
15 Q In what position?
i
, 16 A Starting out as a welder.
17 Q What projects did you work on for Stone & Webster as 18 a welder?
19 A That was the North Anna Nuclear Stations, Units I 20 and II.
21 Q How long did you work as a welder at North Anna?
22 A Starting out as a welder, approximately one year.
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12 1 Q Were you then promoted, or did your duties chsnge?
( 2 A Yes; promoted to foreman / coordinator, I suppose you
, 3 could call it. .
4 .Q .,Was that also with respect to welding?
5 A Yes. -
6 Q How long did you work as a foreman / coordinator at 7 North Anna?
8 A Well, the total was approximately three years; 9 foreman, about a year and a half.
10 Q Did you receive another job change while you were at. i i
11 North Anna? -
l 12 A No.
13 Q What was your next assignment after North Anna?
(
! 14 A After North Anna, I was employed by Daniel 15 International.
16 Q In what capacity?
17 A As a project welding engineer / superintendent.
l 18 Q At what project were you the project welding l 19 engineer / superintendent?
20 A That was the Detroit Edison Company's Fermi II 21 nuclear project.
22 Q Let me back up for a second, Mr. Goedecke, to your o
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13 1 responsibilities with Stone & Webster, as a welding 2 foreman / coordinator. If you would turn to the fourth page;of 3 Goedecke Deposition Exhibit No. 1. There is a reference to 4 your' duties as a welding coordinator / foreman, which include 5 "to inspect all welds before turning them over to the Quality 6 Contr 1 Department forcNDT/ inspection..."
7 Were those responsibilities such that you were 8 required to be' certified to ANSI N45.2.6 or its predecessor?
9 A No, sir.
e, 10 Q You were still in the production side rather than 11 the quality contrcl afde; correct?
12 A That's correct.
i 13 Q I take it that the job darcription that begins at
( 14 the bottom of page three and carries over to page four of -
15 ,Goedecke D& position Exhibit No.1, which is the project
- 16 welding engin?ar/ superintendent, is the job that you held for 17 Daniel International?
18 A That's correct.
N '
19 Q. In your responsibilities as a project welding 20 engineer / superintendent at Termi, to what codes were the' 21 welding you were responsible for accomplished under?
22 A ASMI, Section 2. Let me give it to you in a proper i
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14 1 order. ASME, Section 2, Part A, B, and C. ASME, Section 3.
2 Some responsibility for ASME, Section 5, ASME, Section 9, and
(
3 ASME, Section 11. ,
4 Q Did you have any responsibility for any welding at 5 the Fermi plant that was performed pursuant to the AWS code?
6 A Yes; I'm sorry. I got carried away with ASME. The l 7 additional codes included ANSI B31.1 and AWS D1.1.
8 Q Do you remember the edition of the AWS D1.1 code l
9 that was in use at the Fermi plant at that time?
i-10 A No. I believe it was the 1973 edition.
11 Q Again, did you have any certifications in your job .
12 as project welding engineer / superintendent at Fermi, pursuant
}
i ' 13 to ANSI N45.2.6 standard?
,14 A No, sir. It's usually not a certification that is 15 given to engineers. ANSI N45.2.6 is geared toward the quality
~
76 control / quality assurance personnel.
17 Q You are going up the resume. I see thct it says 18 your next job was project welding engineer for the Detroit l
19 Edison Company. In what year did you take on that position, 20 sir?
21 A I have to guess at that right now. I would say 22 around 1980.
o 1
15
'l Q At what project were you the welding engineer for .)
2 Detroit Edison?
(
3 A The same project; Fermi II. ,
4 Q Your resume says you were responsible for the final 5 approval ^ authority of all welding documentation. What welding 6 documentation are you referring to?
7 A Welding procedures, specifications, welding s qualification records, review of welder qualifications, review -
9 of non-conforming reports, NCR's or NRR's, as they are 10 referred to, engineering changes that were required, 11 interpretation of drawings, welding symbols, et cetera.
12 Q For how long were you the project welding engineer
( 13 at Fermi?
( 14 A Until July, 1980.
i 15 Q You then became senior engineer for Nuclear
_ 16 Maintenance Division of General Electric; is that correct?
17 A The official title was program manager.
18 Q As program manager for the Nuclear Maintenance 19 Division of General Electric,.was that a company-wide l
20 responsibility?
21 A Yes.
22 Q I take it with respect to nuclear maintenance e
I f
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16 1 responsibilities only; correct?
( 2 A Not really. I also had responsibilit'ies for old i 3 domestic nuclear power plants, to review various procedures .
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4 and specifications for all nuclear plants that General 5 Electric was the supplier of the NSSS system.
6 Q Did your responsibilities involve more than analysis 7 and solution of welding problems?
8 A Yes. It involved engineering problems, feasibility j 9 studies for the removal and repair of piping systems, et
. 10 cetera.
11 Q Is it fair to say that the major focus of your ,
12 efforts was on welding problems associated with maintenance of
. f. 13 nuclear power plants?
(
14 A That's correct.
. 15 Q How long did you hold- the position of program 16 manager / senior engineer for the Nuclear Maintenance Division?
17 A Six months. .
18 Q You were then transferred to the position of senior i
l 19 welding engineer / specialist; is that correct?
20 A To the Northeast region; right.
21 Q On page three of Goedecke Deposition Exhibit No. 1, 22 the position of senior welding engineer / specialist is e
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17
- 7. ,
1 described. It states that your principal functions were to
( \ 2 establish a' welding program for the Northeast region. What
- 3 ' sort of a welding program was established by you?' .
4 A ,
The welding program that was established was to take 5 the existing welding program, which includes welding procedure rne ciouAE.
specifications, PQR's, pa-itiort qualification records, and p M
/
6 7 revamp them and do a more streamlined type of look. In 8 addition to that, I was also involved with the general welding 9 specifications or standards, as they are referred to, which 10 gives general guidelines; not guidelines but specific
- 11 requirements. ,
12 Q How many individuals were reporting to you in this 4.
13 position as a senior welding engineer / specialist for General g
14 Electric? ,
15 A Well, it really fluctuated, depending on the work
.au.. 2* a: -
16 .poweo, the manpower load we had' required to furnish these 17 projects that we had in the Northeast region / In general,
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18 thatbidnotexceedfive.
19 Q Were all of these projects.in which you were 20 involved as a senior welding engineer / specialist nuclear power 21 plant projects of cne sert or another?
22 A Yes, sir.
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established or revamped as part of your duties.as a senior 2 l
(' l 3 welding engineer / specialist? , !
4 A The same codes I mentioned before. I would be glad 5 to go through them again.
6 Q No. I think we have them on the record.
7 How long did you work at General Electric as the 8 senior welding engineer / specialist?
9 A Six months.
, 10 Q That would take us to approximately the middle of 11 the Summer of 1981; correct?
12 A That's correct.
( 13 Q What was ycur next position after that?
( 14 A The next position after that was project welding 15 manager for Raymond Kaiser Engineers, normally called Henry 16 J. Kaiser Company.
17 Q When were you hired by Kaiser?
18 A October 10, 1980.
l 19 Q Earlier you stated that in July of 1980, you went to 20 General Electric.
21 A To the Northeast region. That would have to be 22 1981. I'm sorry.
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19 1 Q At what project were you hired as the welding
, 2 manage.r? -
3 A I was hired to a corporate position with the 4 assignment to the Zimmer nuclear project.
.5 Q While you were employed by Kaiser, did you work on
'6 any other project besides Zimmer?
. 7 A At a later de.tei yes. ,
8 Q For how long were you assigned to the Zimmer 9 project?
10 A Until 1984.
' Do you remember the approximate month in 1984?
i 11 Q ,
', 12 A I left -- the end of January.
i! [' 13 Q You left Kaiser Engineering or the Zimmer project?
14 A No; the Zimmer project, then I went to Oakland, 15 California.
- 16 Q That is --
17 A The Headquarters.
18 Q Were you assigned to some other project by Kaiser at 19 that point in time?
20 A At that particular time, I took over as the 21 corporate welding manager, which included all projects.
22 Q Did Kaiser have any other nuclear projects in early O
e B
20 1 1984?
2 A The only nuclear project that we had at that i 3 particular time was the Perry Power Plant, South Cleveland, 4 Chio. That was as a construction management role. We didn't 5 do any actual installations.
6 Q Did you have any responsibilities with respect to 7 Kaiser's activities at Perry? ,
8 A No, sir.
L i
. 9 Q As the project welding manager assigned to Zimmer, ,
.~.
i 10 can you just briefly describe the codes -- would you briefly 11 describe what your -- let's strike the question.
12~ The description of your duties as welding manager on
, f 13 page two of Goedecke Deposition Exhibit No. 1 indicates you
( 14 were responsible for the establishment of special process 15 procedure manuals. Was that a corporate-wide responsibility'
- 16 or was that limited to such manuals as were necessary at the 17 Zimmer project?
18 A In the beginning, strictly Zimmer. At a later date, 19 they became corporate. In other words, some of these 20 specifications had nothing to do with Zimmer. They were 21 geared to what other projects we had, like military 22 specifications.
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21 1 Q What responsibilities, . if any, at the Zimmer -project f" 2 did you have for welding that was accomplished pursuant to tb.e
^
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3 AWS code?
4 A The initiation or revamping of the complete welding -
5 program, concerning the installation, welding and inspection FeL 6 for all AWS components, and all disciplines.
.; 7 . Q When you say "all disciplines," what are you 8 referring to, sir?
9 A "All disciplines" meaning the mechanical engineering 10 discipline, the civil engineering discipline, electrical 11 engineering discipline. '
12 Q What was the scope of Kaiser's responsibility with '
l (; 13 respect to welding at the Zimmer Power Plant?
(
14 A Kaiser had the total scope of welding at the Zimmer 15 Power Plant. What I mean by " total scope" is all
, - 16 installations, with the exception of HVAC, which is the duct 17 work, which belonged to another company.
l 18 Q As welding manag'er assigned to the Zimmer project,
, 19 to whom did you report?
20 A Officially, I reported to the construction manager.
21 Q Was that a corporate position or the construction 22 manager for the Zim=er project?
8 f
22 1 A For the site; for the Zimmer project.
m
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2 Q You "said " officially." Was there some unofficial
. 3 line of reporting as well? ^
4 A As I said earlier, I was hired by the corporate 5 headquarters; not hired by the site directly. ,
At corporate 6 headquarters, I reported to the Vice President.
7 Q In addition to the AWS welding, was there ASME code 8 welding within the H. J. Kaiser scope of work at Zimmer?
9 A Yes, sir.
10 Q Were your responsibilities for that essentially the 11 same as those you described for the ANS welding? .
12 A That's correct.
l i
13 Q When did you leave H. J. Kaiser?
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14 A I left Kaiser in March of 1984.
15 Q By whom were you then employed?
- 16 A Nuclear Power Services, Inc.
17 Q There is an indication that you had two titles.
18 Knee you first Director of the Technical Institute and later, 19 Manager of Welding and Metallurgical Engineering? Have you 20 held those two titles concurrently?
21 A Mo. The first title was Manager of Welding and 22 Metallurgical Engineering.
P I e e
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. 23 1 Q. What were your duties as Manager of Welding at NPS?
( 2 A My duties were to consult our site engineering staff 3 on various nuclear projects and welding related problem areas.
4 Q What is the business of NPS?
5 A NPS, in our scope of work, is an architect 6 engineering firm, 99.9 percent directed towards the nuclear 7 industry.
8 Q At which nuclear power plant sites did you consult
, 9 with the site engineering staffs about welding related 10 problems in your capacity as Manager of Welding for NPS?
11 A The Perry nuclear project; Clinton nuclear project; ,
12 Braidwood; to some extent, North Anna. I have visited various other nuclear projects, trying to obtain scope of work from 13 *
(
34 nuclear facilities. Sometimes I had to consult. I did 15 consult with a client on an unofficial basis.
16 Q Just directing your attention briefly to NPS' 17 assignment at Braidwood, would you describe that for us?
18 A Yes. I submitted two welding engineers to the 19 Braidwood site. They went to work down there.
20 Q Were they consulting to Commonwealth Edison Company 21 or to one of the contractors?
22 A Phillips-Getschow.
1 . ,
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24 1 Q In connection with their work at Braidwood, have 2 these individuals had occasion to call you about any issues or
(
., 3 problems that arose at the Braidwood site?
4 A Yes; mainly code interpretations dealing with ASME, 5 Section 9 and 3.
6 Q How long did you serve as Manager of Welding and N
7 Metallurgical Engineering at NPS? ,
8 A I still serve in that function now.
9 Q I see. About how much of your time have you spent 10 on Braidwood problems or issues?
11 A Very little. ,
12 Q When did you become Director of the NPS Technical
- I 13 Institute?
I
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,14 A About two to three months after I joined NPS; 15 approximately June of 1984.
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16 Q Had the NPS Technical Institute been in existence 17 prior to the time you were named its Director?
18 A Yes, sir.
19 Q In your capacity as Director of the NPS Technical 20 Institute, do you have responsibilities that go beyond the 21 initiation and the implementation of technical publications 22 and training manuals for welding?
o S
e b isms mei-s esiim mmmmemi siem i
25 1 A Yes. They are basically covering all disciplines, 2 engineering disciplines, I should say; mechanical, electrical, 3 and civil. ,
4 Q In addition to the preparation of these technical 5 publicatkonsandtrainingmanuals,whatelsedoestheNPS 6 Technical Institute do?
7 A That is pretty well it. We offer seminars in -
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a various disciplines.
9 Q This resume indicates that you had made 10 presentations in welding', metallurgy, and failure analysis.
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11 A That is what I refer to as seminars.
12 Q Who are the seminar attendees ordinarily, if you ,
/ 13 know?
( 14 A Mainly welding engineers and quality control type 15 people, again, from various nuclear projects.
16 Q Since you have been Director of the Technical 17 Institute, approximately how many seminars have you conducted?
18 A Since becoming Director of the Technical Institute, 19 I did not conduct any seminars. I merely wrote the outlines 20 for conducting seminars.
21 Q You have not personally given the seminars. That is' 22 done by your subordinates?
O e
e
. =. : - .. a.
26 5
1 A No. These seminars are given by the utilities. I 2 wrote the manuals for them.
~ I offer them to teach the
(
, 3 seminars or they can teach it themselves, in which. case I write an instructor's manual.
4 5 Q 'Approximately how many utilities have utilized these 6 seminars, if you know?
x 7 A Let me explain the seminar thing right here. I 8 taught seminars not under the employ of NPS, I taught seminars 9 under the employ of Henry J. Kaiser company and Daniel 10 International. The manuals that wer's written were strictly
<' 11 for PSE&G.
- - 12 Q Public Service Electric and Gas company?
^
(' 13 A That's correct. They have a training facility in
( 14 Salem, New Jersey, and they utilized these training manuals, 15 which all included an instructor's manual and a student 16 manual, and the instructor's manuals are written in a format, 17 in other words, that all someone has to do is read what is 18 there and without going into any further details. Anyone can 19 teach it from that point forward, is what I'm saying, anyone 20 that can read.
21 Q Turning to the first page of Goedecke Deposition 22 Exhibit 1, somehow I have started from the bottom up on all e
O
27 1 these pages and I will continue. At the botton you talk about
~
(. 2 certifications. When did you become certified as an ASME 3 N.45.2.6 level welding inspector? ,
4 A [That's an ANSI /ASME certification. I can't give you l 5 the exact date. I would say about six months ago.
6 Q Prior to that time, had you had any level 8
- 7 certification as a welding inspector? ,
8 A No.
9 Q To which procedures are you certified as a Level III 10 welding inspector?
11 A I am not certified to any particular procedure, but .
!; 12 at NPS we have a procedure that gives the guidelines of the l . 13 requirements of ANSI N.45.2.6 which must be followed. The L (
14 original qualifications are usually project dependent. You l
l 15 can't really qualify -- this is a corporate type of 16 certification.
17 Q I see. So you couldn't go to any individual nuclear 18 power plant and become a Level III weld inspector without 19 further certification.
20 A That's correct. And again, I want to point out that 21 these certifications are geared toward the nuclear project, to 22 their specific requiraments.
O e
3
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~
38 1 Q It also says that you are a welder certified in
( 2 shield' metal arc welding and other forms of' arc welding. How b*
3 long have you been certified as a welder, sir? -
4 A Since 1968.
5 Q Let me jump up to the professional committee 6 memberships. Is this still an accurate and complete list of your committee memberships?
7 s A Yes, it is, with the exception of AWS General 9 Education Committee, which could be still current but I
! 10 requested a resignation on that one. I haven't heard from 11 them since, but that was requested, that I be removed from the 12 roster.
(* 13 Q How long had you served on the AWS General Education (s 14 ccamittee?
15 .A Approximately four years.
, 16 Q Had you had any other committee assignments with AWS 17 prior to that one?
, 18 A Committee assignments? No.
I l 19 Q You maintained your memberships in the ASME and ASTM 20 Committees?
21 A Yes, sir.
22 Q And how long have you served on those com=ittees?
l
- f 4 .
1 r,--- -,-----,,,,,,---,,,,,,,,,,-,,,--,,,---,,,,_w
,,-,-----,,,e- - - - - - , , , , , , - - - -
- _ _ _ _ = . .
e 29 1 A It varies, really, from approximately 1981 to the 2 present time. -
(
3 Q Moving up to the management training you have ,
4 received, can you just briefly indicate which organization was 5 responsible for providing the four management training courses j 6 that are indicated on page 1 of your resume?
l .
7 , A Yes. Starting with A, the management workshop, it 8
was at General Electric training. However, when I took this 7
9 training, I was not employed with General Electric. -
10 Q By whom were you employed?
11 A Daniel International. The middle management 12 development was the training course from a gentleman by the I 13 name of Louis Gallerman.
, (
l' 14 Q And by whom were you employed when you took that l 15 course?
~
16 A Henry J. Kaiser Company.
17 Q And the third is listad as effective management.
18 A That's correct. That was a General Electric 19 course. Again, Henry J. Kaiser Company.
20 Q And the KET management seminar?
21 A Daniel International.
22 Q Moving up to the courses that you completed in e
4
,,---y .
e
l-- .. . .. . . . . _ . _ . _ . _ . _
30 1 nuclear technology, I take it that the first three listed 2 under that heading were courses that were offered by General
( .
3 Electric while you were employed by General Electr4c; is that 4 correct?
5 A 'That's correct.
6 Q By whom was the fourth course, the in-service
, 7 inspection of nuclear power plants per section 11, offered?
8 A It's a company that calls itself Professional 9 Development Corporation. I don't know the exact location and 10 name.
11 Q By whom were you employed when you took that course?
12 A Daniel International.
( 13 Q I think we have earlier talked about your education,
( 14 at least in part. I take it that the journeyman' designation 15 that is indicated as a plumber, pipe fitter and as a machinist
+
- 16 were, in effect, union recognition of your status as a 17 journeyman; is that correct?
18 A That's correct.
19 Q The welding and metallurgical engineering course 20 that you took, could you describe that for us?
21 A Yes. The diploma is issued after you have 22 successfully completed five courses. These five courses are
~
m G
31 1 listed on the last page as special certifications. After 2 successful completion of these courses, you get a diploma in
(
3 the discipline that most fits an engineering discipline.
4 '
4 Q How many hours or weeks were each of these courses?
5 A ' Total time span was approximately five years for 6 these courses.
7 Q I take it that, given your other job 8 responsibilities, that this was a part-time --
9 A Yes, sir.
<i ~
10 Q can you tell us approximately how many hours of 11 classroom work?
12 A If you were to take these courses on an intensive Ii.
l '
[ 13 seminar-type application, then these courses would run 40
$ ( 14 hours per course.
l 15 Q Kr. Goedecke, I would like now to return to your
- 16 work experience at the Firmer power plant. By whom were you 17 hired within the Henry J. Kaiser organization?
18 A The project manager.
19 Q Had you known this individual prior to the time ha 20 approached you?
21 A Yes. He used to be the construction manager for 22 Daniel International at the Fermi nuclear plant.
l t
e 6
1
32
, 1 Q What is this individual's name?
I 2 A Mark F. Albertin.
, 3 Q Mr. Albertin approached you for this job? What did -
4 he describe the job to consist of?
5 A Basically the same things that I did for Detroit 6
Edison Company at Fermi-2., In other words, take over all the 7 welding controls for the Zimmer nuclear project, from both an 8 engineering standpoint and an administrative and 9 construction. In other words, actual installation procedures.
10 Q Did Mr. Albertin describe ths then current status of-11 the welding program at Zimmer?
- 12 A Yes. He told me that he was in dire need of help to 4
13 straighten out some of the problem areas that he had, 14 specifically since they were identified in an NRC survey l
15 which resulted in a civil fine.
16 Q I'm sorry. What had been identified in the NRC --
17 as you call it -- survey, or inspection report?
18 A Really a broad range of breakdowns in the welding 19 field, consisting of welder qualifications, procedure 20 qualifications, Tctual installation practices, et cetera.
21 Q You obviously accepted the job and traveled to 22 'incinnati. What was the first thing you did when you took e
6
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33 1 over as project welding manager?
( 2 A The first thing I did, I started reviewing 3 procedures, and I observed the modus operandi of the current ,
4 welding department.
5 Q At that point in time, what did the welding 6 department consist of in terms of personnel?
7 A There was one welding e'ngineer. His title really was .
S chief welding engineer. And I believe there were two welding
. 9 assistants and one clerk.
A
- 10 Q And the welding engineer was Mr. Puckett; correct?
11 A That's correct. .
12 Q At that point in time, these four individuals were
. 13 essentially responsible for the welding program for the entire
(
, 14 Kaiser scope of work at Zimmer; is that correct?
15 A That's correct.
16 Q How long did your review of the procedures and the 17 operation of the welding department at Zimmer take you, 18 initially?
19 A I have to break it down into two areas. The 20 observation of the welding department, approximately two 21 weeks. The initial review of procedures, approximately three 22 months. And I have to include here that these procedures were e
9 mens
34 2
1 reviewed by a task force requested by myself, which consisted
, 2 of the architect engineer, an engineer from the client, a 3 quality assurance engineer from our company and myself.
1 4 Q The architect engineer at Zimmer was Sargent &
5 Lundy; correct?
6 A That is correct.
7 Q Their client was cincinnati Gas and Electric?
I 8 A That's correct.
, 9 Q Were the representatives on this task force from
- 10 Sargent & Lundy and Cincinnati Gas and Electric trained as 11 welding engineers?
12 A Well, they weren't trained per se. They were in 1
j 'I I 13 their capacity individuals that had numerous years of
( ,14 experience in the field of welding.
15 Q I think you said that you observed the operations of-16 the welding department for approximately two weeks. What i
17 conclusions did you come to, if any, at the end of that 18 two-week period?
19 A That the current staff was insufficient from an 20 operations standpoint, one, and lacked tha knowledge to 21 control welding work on a nuclear site.
22 Q ,W hen you said it was insufficient, I think you said l
\ .
\ -
1 l
i 4
- - - - -.--n-.--.--r,-w,n-, ,.,.,-,,,,e...,--- ,,w,, - , w__-,.~ . men,-,,~,-,,,r
35 1 insufficient from an operations standpoint. In what way was 2 it insufficient from an operations standpoint?.
(
i 3 A It was insufficient to the point where the l
,j , 4 directions given to the construction disciplines and the ,
5 amount of paperwork required, the correct amount of paperwork 6 required lacked th's response that I would consider sufficient.
7 Let me go into it a little further.
8 The welding department at that particular time had 9 the responsibility to issue weld travelers, or KE-1 cards, as 10 they were called. These KE-1 cards give instructions to the 11 disciplines of how to install the types of materials, the 12 types of filler material, the procedure used, how to install a l
, i { 13 certain component, whether it is piping, structural or et
( 14 cetera, which welding process to use, and then they would sign 15 it and give it to the field so they could go to work.
_ 16 Now, the amount of daily activities that were 17 required or the KE-1 cards that were required to support these e
18 daily activities were lacking.
19 Q Was this in part due to the few number of 20 individuals that were assigned to the welding department at 21 that time?
22 A No. This was in part due to the lack of additional i
l 1
we ---,wem-~.-,w,v~e,,,,-,e,w, y-w-----rr, ,,,en.-mmn,-+_ , - - - - , . - n_ .n,v.---~.-na .w,v~a-,--
36 1 personnel that were assigned to the welding department.
2 Q In other words, they just didn't have enough people 3 to keep up with the workload? ,
.' 4 A That's correct.
5 Q Apart from the lack of necessary personnel to 6 accomplish the task, was there any other way in which the
,' 7 existing welding department was insufficient from an 8 operations standpoint? ~
9 A Yes. These things really go hand in hand. If you
) 10 take excessive amount of time to review the specification or a
~
11 code to fill in the proper blanks -- pre-heat, for instance, is one thing, how much pre-heat is required for this thickness.
12
+-
<d l 13
/ of a component, and you really don't know and you have to jump
(
14 forward and back before you can fill out the necessary 15 paperwork, then obviously that slows down the operations.
16 On the second hand, when questions came up whether
, 17 something is in compliance with the code, standard, 18 specification or procedure, and the response is not immediate, 19 or what I call immediate, at least within 15 minutes -- excuse 20 me, I have to look it up -- then obviously that slows down the 21 operations.
22 The individual that runs a welding department in a e
e 4
-,---w- --.m v.-.. ,- ,y ,r- .-.,.-----+---.,-w,+-----.----------.-.---.-w-
- - - - . _ - - . - , ,-r..-.e-w---- - , .- , . - . - . - - - - - - - - - - - - - -
37 1 nuclear powar plant, that holds a position c.s an engineer, has r
2 ta have as a minimum the knowledge of quickly identifying
(
3 where the problems are and to interpret the code ,quickly. In 4 other words, to find the proper space in a code and identify p
5 the pro'per code.
g 6 Q Did you observe that Mr. Puckett was knowledgeable N
7 with respect to the codes in use at the Zimmer plant?
8 A Mr. Puckett knew codes but he did not know how to 9 pick the proper code, neither how to interpret the code 10 correctly. .
11 Q When you say pick the proper code, what do you mean, 12 sir?
}; y, 13 A Depending on the installation of a component, you
( 14 may have to go to ASMI, Section 3, and the associated t' *.
l 15 supporting books, or you may have to go to ANSI B/31.1, or you /'#*.
16 mayhavetogotoAWSD.I.1./'#0' j-' 17 Now, if you have an installation or a component and 18 you can't pick the proper code -- in other words, you pick i:
19 ANSI instead of ASMI -- you obviously have a problem because 20 now you are stipulating requirements that are not in 21 compliance with the correct code.
22 Q Did you observe that that occurred during this
/
~
1 O
t
38 1 two-week evaluation period?
g 2 A Yes, I did, both from a verbal standpoint and from a i
3 written direction. '
4 Q At the end of this two-week evaluation period, what, 5 if anything, did you do to resolve these issues or problems s
6 that you had observed?
~
7 A I made a proposal to the project manager to hire 8 additional personnel and completely restructure the current 9 organization.
10 Q Was that proposal accepted?
11 A Yes, sir, it was. ,
12 Q Did you have any conversation in this two-week 13 period, or at the end of this two-week period did you have any
('
conversations with Mr. Puckett about his performance in 14 1
15 interpreting codes and so on?
16 A We had several discussions of explaining which codes 17 are applicable on -- not on a continuous basis, but once in a 18 while I did say this is the wrong code, you have to go to this 19 code for this and this reason. It was more a lecturing or a 20 directional-type discussion: This is wrong, this is the way we 21 are going to do it.
22 Q Did you tell Mr. Puckett that you were going to f
a e
J
,.,==.,y - ,c-y v- ,- , , . . - - .- = + , , - -
39 1 revamp the organization and seek additional personnel?
2 A Yes,,I did.
3 Q What was his response? ,
~
J 4 A That's what I wanted all along. He knew that there 5 was additional help required.
l 6 Q Did Mr. Puckett say anything to indicate that ha 7 himself had asked for additional help from time to time in the 8 past?
9 A Yes, he did.
10 Q - Did he say what the response of management had been 11 to those requests?
12 A Yes. The response of management up to that date was I ( 13 negatory. He did not receive the help that he asked for.
( 14 Q I think we are around late October, early November 15 when you made this proposal to management. How long did it
- 16 take to get approval for this new and increased staff that you 17 proposed?
18 A Well, the original proposal was a large increase in 19 the manpower. The approval that I obtained was a gradual 20 increase in manpower. The approval was just about 21 immediately.
22 Q Did your proposal for increase in manpower i 1 .
,-,.,-m,- . ---, - - - , --, -
y-,,----, w,- - - --- - - , - - - - , . - - - . ,.----,.--,,m,-4
. 40 1 contemplate any change in Mr. Puckett's status as project veld
. 2 engineer? .
(
3 A Yes, it did. .
] 4 Q What change?
5 A The change was to remove him from his current
'l 6 position and responsibilities and replace him with another 7 individual. -
8 Q And on what basis did you make that recommendation?
9 A As a project welding manager, I have had a lot of -
10 administrative functions'and meetings to attend, scheduling 11 meetings, et cetera, and I felt at that time that I could not 12 leave that responsibility -- in other words, the engineering I
(' ' 13 responsibilities -- to Mr. Puckett because of the various I 14 problems that we had in welding and his previous' decisions.
15 Q Did you tell Mr. Puckett about this point in time i i 4
16 that he was going to be replaced as the project welding
! i 17 engineer?
18 A Yes, I did.
l 19 Q What was his response? !
20 A Well, quite obviously, he wasn't very pleased with l i 21 my decision. Later on when I performed this evaluation, again 22 he was not very pleased with the evaluation, but in the l
I ~
_------.---..-,,---,------,.--..----.-c.,- w-, ~ - , - , ~ . ----e , w- ---,--e--- - - , - - - , - - - - - ,.-~--,-,,w,.,.,,--
41 i
1 evaluation, I clearly stated the reasons why he was replaced 2 with a new engineer.
(
! 3 Q- How long did it take you to find a new engineer to
'l 4 replace Mr. Puckett?
5 A About three to four months.
- l
- 6 Q And how was the Department run in that interim i .
.- 7 period of three to four months?
i 4 8 A It was run between Mr. Puckett and myself.
I 9 Q Earlier in response to one of my questions you said 10 that one of the first things you did, in addition to observing 4
11 the operations of the welding department, was to review 12 the procedures, and there was a task force that took
[ 13 approximately three months to review the procedures.
( 14 A That's right.
15 Q What responsibility, if any, had Mr. Puckett had for
. - 16 the welding procedures that you were reviewing?
a I 17 A As the chief welding engineer, he was responsible i
18 for the procedures, period, from all points. In other words, 19 the assignment of a procedure, the qualification of 20 procedures, the writing of procedures, et cetera.
- 21 Q I see. What conclusions at the and of the i
!' 22 three-month period, if any, did your task force reach with O
9
42 1 respect to the welding procedures that were then in effect at
[ ( 2 the Zimmer Power Plant?
3 A All welding procedures were rewritten. '
4 Q Why were they rewritten?
5 A Simply because none of them really met the Code 6 requirements.
7 Q Who had the responsibility for the rewriting of 8 these procedures?
} 9 A
- The responsibility was with the Welding Engineering l 10 Department, myself, with the additional help of the Quality 11 Engineering Department.
?
4 l, 12 Q So you personally took responsibility for the
! :. 13 rewriting of the weld procedures at Zimmer?
i (
, 14 A That's correct. Let's strike the word rewrite.
j 15 Let's make it correcting certain paragraphs or certain items J -
16 in the procedure. We didn't do a complete rewrite at that 17 particular time.
I 18 The time frame that we had really didn't allow for l 19 complete rewriting. At a later date they were completely l 20 rewritten.
21 Q over what period of time did you make these changes 22 or amendments to the weld procedures?
I
)
i . .
i I l I
._=
I 43 i
1 A Approximately from November of '81 to February of l 2 '82.
(
Did you discuss with Mr. Puckett these changes to 3 Q l
g 4 the weld procedures that you were implementing? .
b 5 A res, I did. And he agreed that there were numerous I
6 items that required immediate changes. With all respect to 7 Mr. Puckett, he did mention the fact on several occasions that
! 8 he indeed told management there were problems.
, 9 (Discussion off the record.)
10 I believe I was at the point that with all due 11 respect to Mr. Puckett, he did inform me -- that he himself
- 12 had identified the problems, brought them to the attention of
, (' 13 upper management, in his words, without success.
1
( 14 Q Had Mr. Puckett identified the same problems with
! 15 the existing weld procedures that you observed, do you know?
l - 16 A No. There was numerous problems that he did not 17 have any knowledge of until I told him these are the
] 18 problems. And that's what they are. Some of them he knew.
}
19 Some of them were brand new to him. He didn't know.
20 Q I think you said that it took about four months or i
1 21 so before you were able to find somebody who would serve as l 22 the project welding engineer and replace Mr. Puckett in his
] .
l i
( .
I i 44 I 1 responsibilities, is that correct?
g 2 A That'-s correct.
3 Q What was the name of the individual who you fI 4 ultimately found for that position?
5 A The name of the individual was John W. Flaherty.
6 Q And let's see, it would be four months from November
!. 7 would be sometime in March or April of 1982 when Mr. Flaherty l 8 was employed at the Zimmer site?
[,' 9 A I'm sorry, repeat that?
10 Q I am just trying to establish the time frame when j 11 Mr. Flaherty became employed at Zimmer.
, 12 A March or April. I don't ra===her the exact date.
[ 13 Q Once Mr. Flaherty was employed, what were i (
- 14 Mr. Puckett's duties and responsibilities?
t .
15 A Mr. Puckett's duties and responsibilities were, in 16 general terms, a subordinate to Mr. Flaherty in the beginning i'
17 in all directions. What I mean in all directions, is still 1
18 the initiation of KE-1 cards. In other words KE-1 cards --
! 19 let me repeat that again -- are instructions to the field of i
20 how to install a component. Welder qualifications and the 21 direction and assignment of -- I'm sorry. The direction in 22 the field and in correcting problem areas in velding.
t
( .
1
45 1 Q So in other words, Mr. Puckett served as sort of ,
2 Mr. Flaherty's lieutenant in the areas that you have just 3 described? -
I
! 4' A That's correct.
5 Q How long did that assignment of Mr. Puckett last?
, ')
! 6 A Approximately another month.
i- 7 Q And,then what happened?
8 A Then Mr. Flaherty got a feel for the project and he I 9 took over all major engineering decisions and assigned 10 Mr. Puckett strictly to KE-1 cards and welder qualifications.
I 11 Q So after a month, Mr. Puckett no longer had any .
- 12 responsibility for field inspection activities, is that i i i / 13 correct?
( ,14 A He still had some field inspection responsibilities, 15 but not to the extent that he had previously. At that 16 particular time we hired an additional welding engineer by the <
, i 17 name of Paul Evans, who then took over all field inspections.
18 Q So Mr. Puckett's responsibilities for field
- 19 inspections were eliminated once Mr. Evans was hired, is that i
I
.. 20 correct?
I 21 A Virtually.
22 Q And for how long after Mr. Flaherty was hired did
{
9 l
l -
l
. . - . _ . - . - , . - - - - - . . - - , - - , - - . . . . - - - . , . - . - - , = . . - - - - - - - - - - - . - - - - - . . .
....-.,..-.--.-l
l 46 1 Mr. Puckett retain his responsibility for the KE-1 or traveler 2 foras?
3 A I have to identify the word responsibility.
ll 4 Mr. Puckett still initiated the KE-1 cards and put the data
- 5 down, but the approval prior to submittal to the various jf 6 engineering disciplines lied with Mr. Flahertf and, at a later 1
7 date, Mr. Evans.
I
, 8 Q In the area of welder qualifications, what were 9 Mr. Puckett's responsibilities once Mr. Flaherty had been 10 hired? '
11 A He still had an individual in the weld test booth, l 'l 12 100 percent, that reported still to Mr. Puckett at that
~
(', 13 particular time. During this time frame, I should say. Then b
( 14 we hired an additional engineer who took over the total 1
15 responsibility for the weld test facilities, both from a
- 16 wilder qualification standpoint and a procedura qualifications l 17 standpoint, which did happen because of our review.
18 Q When you say -- what happened because of your 19 review, the requalification of procedures?
, 20 A Right. Not all of them, but certain procedures 21 required requalification.
22 Q All right, in addition to supervising the weld test i
! ( .
l t
,-------,,-nm----.------ag ,n--,-.--, , , . - -.m,-n -----e,~.-y-,, - . , , ,, - . - - , ,., -,,e,. ,re.. , , - , ,. - --,--n e----n.----- n
. l 47 l
= l 1 booth for a period of time, did Mr. Puckett have any other I 2 responsibilities with respect to welder qualifications?
- 3 A Just the documentation review that came from the 4 weld test booth. At that time, just a review of the existing 5 documenta' tion. The approval authority was, at that time, i I 6 solely Mr. Flaherty's. !
1
~
7 Q So after Mr. Flaherty was hired, Mr. Puckett had to 8 have Mr. Flaherty's approval both for the KE-1 cards and any jl 9 welder qualification documents that were issued, is that 10 correct?
I 11 A And procedura qualification.
I .
12 Q Did that chain of command continua?
, / 13 A Yes, it did.
t I
I l
,14 Q All right. Did there come a time when Mr. Puckett's 15 responsibilities, with respect to.the KE-1 cards and the 16 welder qualification records, were further changed?
l1 l 17 A That's correct.
- 18 Q Why?
i j 19 A Because there were still numerous mistakes found and j 20 John Flaherty just simply did not have the time to c'rrect o
). 21 them. So he needed someone else to fill them out and
! 22 actually, approve these Ka-1 cards. The work scopo was quite 1
i !
i !
.I i
i
48 1 massive.
2 And in the interim, we constantly hired additional 3 personnel, building engineer personnel. And as the staff l 4 increased, the responsibilities of Mr. Puckett became less and i
. 5 less. .
l .
6 Q Did Mr. Flaherty communicate his -- well, was x
7 Mr. Flaherty satisfied or dissatisfied, as best you can tell, ,
8 with Mr. Puckett's performance in filling out the KZ-1 cards
- ) 9 and the welder qualification documentation?
i 10 A Dissatisfied.
!' 11 Q Did he tell you why?
4 .
j 12 A Yes, because of the numerous mistakes that were i
13 found on them.
I
,14 Q I think we are into the year 1982. Approximately i 15 when did Mr. Flaherty first make known to you his
~ 16 dissatisfaction with Mr. Puckett?
i 17 A I would say approximately four weeks after his 18 arrival.
, 19 Q When Mr. Flaherty made these observations known to 20 you what, if anything, did you do about the scope of
- 21 Mr. Puckett's duties?
22 A At that particular time, Mr. Flaherty was
< l .
49 4 .
j 1 responsible for Mr. Puckett. I was ultimately responsible. j j 2 The scope between Mr. Flaherty and myself -- his scope further 3 changed to strictly welder qualification record review.
! 4 Q Under what circumstances was this welder f
5 qualification record review conducted? Well, why was it done? !
i 6 A Because the welder qualification records identified !
l 7 the same numerous problem areas that we identified in the !
i 8 welding procedure specifications. In other words, data, 9 conflicting data, omission of data, improperly corrected data, i 10 and so on and so forth.
11 Q What were Mr. Puckett's duties with respect to this 1
12 welder qualification documentation review?
1 I
l / 13 A Well, originally he was responsible to assure 44 correctness of these documents and signing off on these I l
15 documents, declaring a welder certified to various processes.
~
l 16 At a later date, in the review cycle, we decided to check the
{ 17 information that was contained in a welder's package, which ;
i i 18 contained the sheet that was filled out in the weld test i
l 19 booth, the weld slips that were utilised and the various l
! l 20 documents that make up a package with the cover sheet, and 1
{ 21 retype all this information on a new format.
22 The previous format that they used was a pre-typed I
c ,
I .
i 1
I 4
.-w-. . . - , , . , - , _ , . -. -,.y,--,-.~~-war.-.ve-....----w,,----,---n,c.r- , , , , . - . ,- - ,w c,--. .-,.,m-
,..,-,-.-r,_c,,-,.-------,-en,------.% ~
50
]
1 format which lent itself to numerous mistakes simply because p.
1-s 1 they were pre-typed. Sometimes these forms were used and the
(
., 3 corrections were not made on them, just additional information
- , 4 added. So now you have conflicting data on the same document.
I -
i 5 So we decided, at that time, to do away with these i i 6 pre-typed formats and every original document was filed out
{, N !
7 from scratch, in the weld test booth, in handwriting, then !
8 brought up to the engineering office. All of his handwriting
]*
9 was then transferred to the'new form, typed on a new form, .
l_ 1 10 reviewed by Mr. Puckett and then sent to Mr. Flaherty to sign -
i 11 off on.
1 12 Q 3esides reviewing the typed forms after the welder
(, .
f 13 qualification do*.umentation had been put on them, did !
I'
(' -
14 Mr. Puckett have any other responsibilities with respect to i-j 15 r
this process? t i.
j 16 A Yes, not to this particular process, but once these '
14 i 17 forms were signed off and approved Ao Mr. Flaherty, the b #dE'
}
is issuance of a welder's card was then achieved. And these 19 welder cards were filled out by Mr. Puckett, welder .
l 20 qualification cards. '
21 Q Did Mr. Puckett have any responsibility for i
22 resolving any conflicts or inconsistencies in the old welder i
i .
l
- i
~
l l .
(
I I i
i
- 51 i
1 qualification records before they were typed in the new form? '
( 2 A No.
g 3 Q So at a point in time -- when were Mr. Puckett's 4 responsibilities for this review of welder qualification l 5 records given to him?
j 6 A You'll have to repeat that.
7 Q I'm sorry. I'm trying to establish a date in -- I j e guess it would be 1982 or 1983 -- when Mr. Puckett's 1
j 9 responsibilities for this review of the new welder lo qualification forms was given to him?
11 A Well, I call this phase 1, okay. So you understand ,
j 12 there were two phases. At a later date, there came a new '
4 13 phase. Phase 1 was just taking the information and put it on i I
} 14 -- for current welders, welders that were qualified currently 4'
15 or certified currently for the ongoing project. In this phase 16 1, that is all his responsibilities were, transposing data to !
f l* 17 a new format.
18 Q Was he physically -- was he the person who i
! 19 physically looked at the old forse and wrote a draft of a new !
, t 20 form with the data that he observed from the existing records? l t
l 21 A That's correct. And then they were typed from i 22 there.
1 1
e t
lI i
L-i j '
.,,,---.-.--enn--,--,,,,n,,,---n, -,-m,- .,,,,,,,,,n - .-,,,w,.-n.,w-- - - - _ _ _ . - en--,-a.
=
52 1 Q And then he reviewed them? The typed foras?
2 A Right,. ,
3 Q Then he passed them along to Mr. Flaherty? ,
4 A That's correct.
f 5 Q And then, in addition, he was responsible for i
6 issuing welder qualification cards once Mr. Flaherty had i
- ' 7 approved the welder qualification? ,
4 A That's correct. .
9 Q Was this an increase or decrease in Mr. Puckett's 10 responsibilities from what he first had, when Mr. Flaherty 11 first came on the site?
l 12 A It was obviously a decrease in responsibilities. i
( 13 Q Did Mr. Flaherty have occasion to discuss
, ( 14 Mr. Puckett's performance, in this somewhat limited document i .
l 15 review function, with you?
1 -
16 A Yes, he did. He expressed dissatisfaction in that ;
I ,
1 l 17 capacity also.
l- 18 Q Did he tell you why?
19 A There were still numerous mistakes made. Ne could i 20 not trust the information that was contained on the document. *
! 21 He had to make another review himself and then found that !
l i
22 mistakes were still made.
i l .
1 l t ,
i
- l
i 53 1 Q Mr. Goedecke, based on your experience, would you j i 2 describe what'Mr. Puckett was doing as something that a weld 3 engineer would perform? That is, this transfer of' data and 1 .
! 4 the review of data?
l 5 A Transferring of data and review of data is not !
l 6 really an engineering function anymore. It could me performed
! 7 by any clerical-type individual.
l l
8 Q When Mr. Flaherty expressed his dissatisfaction with
, 9 Mr. Puckett's performance of what you just described as 10 essentially clerical duties what, if anything, did you do
~
1 11 about Mr. Puckett's responsibilities? ,
j' 12 A Well, at that particular time frame, that we are . i 4
4 13 discussing here, Mr. Puckett's evaluation came up. It was !
(
14 due. So at that particular time, 2 performed an evaluation on i 15 him. I wrote up my evaluation. And in this evaluation, I l 16 discussed the problem areas and I discussed the weak points of
- I 17 Mr. Puckett. I also discussed,the recommendations for his l
j 18 improvements that were required.
4
]
19 I also discussed a plan of attack of how we could l
20 help Mr. Puckett to achieve these new goals we set for him.
! 21 And discussed with Mr. Puckett the evaluation, as was required 1
i j 22 by our procedure.
J
! i i .
l .
i l
l f
. ~ -
54 1 Q I don't have the evaluation with me. I've got to go 2 get it, but let me just focus in on what happened after 3 Mr. Flaherty expressed his dissatisfaction with Mr. Puckett's
{
4 performance of these duties in reviewing the transfer of the f 5 old welder data -- the old welder qualification record data to 6 the new form.
7 Was Mr. Puckett retained in that position *or was'ha a
! transferred to some other job? I
. 9 A During that time frame, he still retained that l
)
10 position with the additional help of other engineers.
- 11 Q Until what time did he retain that responsibility,
- - 12 approximately? Mr. Flaherty came there in March or April of i
3 13, '82. Now long did he work for Mr. Flaherty?
14 A Me worked for Mr. Flaherty, I would say, for an 15 additional with responsibilities constantly changing. And I.
t 16 really couldn't nonostly say what the specific 17 responsibilities were for Mr. Puckett during this time frame 4 is because they switched forward and back as needed. That's a j 19 quantion that really needs to be asked of Mr. Flaherty because 4
20 he was in charge at that time. !
21 At a later date, the responsibilities changnd 22 again, specific responsibilities changed again. But during s
t . !
i .
~l, 55 1 this time frame, his responsibilities juggled around. Anytime 2 we needed something done we had utilised all our manpower and
\
3 effort to correct this problem, whatever came up at,the time.
4 Q In any of the jobs that Mr. Puckett was assigned,
- 5 where he worked under Mr. Flaherty's supervision, did 6 Mr. Flaherty ever express satisfaction with the job that 7 Mr. Puckett did?
- 8 A Well, I would say that is a known fact, and no one 9 can take this away from Mr. Puckett. Mr. Puckett was always 10 willing and eager to work and work hard. So in that respect, 11 when we needed something done from Mr. Puckett, with very 12 specific directions, he got the job done. And both
( 13 Mr. Puckett and Mr. Flaherty and I sat down in the evaluation
( 14 and we made it very clear that we are very well satisfied with 15 his output or his performance when it came to working, working
- 16 hard, doing anything in his power to get the job done.
17 Q Did there come a time when Mr. Puckett no longer 18 reported to Mr. Flaherty?
19 A Yes.
20 Q Under what circumstances was Mr. Puckett transferred 21 from Mr. Flaherty's supervision?
22 A We had what we called a cosplete procedural change L
- _ . - _ , . _ _ . - , _ . - _ _ . . _ . .-_.- _._ _-_,.____ - ___,,__-_. __ _ _ _ _ _ , _ - - . , , - , _ . . . , . , . . , . . .~ --
56 1 at one time, where all the procedures were completely
, e
[( 2 rewritten. 'All of the procedures, administrative procedures 3 and welding procedures, specifications, qualification of new 4 procedures or requall'fication of existing procedures.
5 Qualification of welders, requalification of welders, et s cetera.
- '7 So his responsibilities changed at one time to take a
Thishistoricaldataandtakealltheinformationcontainedin/vC' 9 a package, not from current welders but discussions we had 10 previously were for existing welders. .
11 But now we are going back into the history of the
, 12 plan) ten years back, and taking the historical data and / #45
- e,, 13 taking the information contained in those packages and 14 transfer those to this new format that we established.
15 Mr. puckett and a Quality Assurance engineer named 16 X.X. Sheraten -- and don't ask as to spell that -- I would 17 spell it just like the Sheraton Hotel, I guess. Thqsa two 18 individuals were solely responsible to take all the 19 information contained in one document, transfer it to a new 20 document, make a notation on the bottom of these documents
', 21 stating that the infor=ation contained above is a format 22 change only.
4 I
I %. -
57
- 1 Now this new document was utterly legible, was 2 attached to all the previous documents.
{
( ;
i
, 3 Q When Mr. Puckett and Mr. Sheraton were performing
- I .
l 4 this function that you just described, to whom did Mr. Puckett l
}; 5 report?
6 A Still to Mr. Flaherty, at this time. Mr. Puckett <
I 7 was then transferred, after this function was completed, , ;
[l i s
8 Mr. Puckett was then transferred to another manager that I l
) 9 hired by the name of Mike tutterworth. And he then became I
i l ,
10 what we termed a lead historical welding engineer. !
11 Q Now did Mr. Flaherty express satisfaction or ,
j 12 dissatisfaction with the way in which Mr. Puckett performed
! 11 his duties in transferring this data for, as you call it, the
!. (
[ A4 historical data with respect to welder qualifloation records?
15 A In general terms, I would say that Mr. Flaherty was l J
}.
16 satisfied, with the exception of one major incident, as we ;
4 j 17 call it, that concerned 32 records where the statement -- the 1 l le document above contains information contained in this package j !
19 and is format change only == where that particular statement !
l l
20 was omitted and it created quite a problem for us.
I 21 MR. GUII,DI I'm sorry. It was omitted?
i
! 22 THE WITNESSI Ositted, that's right. ,
l t l :
( .
l i
i l ;
j .
- - _ . ..- - - - _-. . . - - . - - - ._~. -
58 1 BY MR. MILLER:
Was that omission, on the 32 records, the reason 2 Q
(
'> 3 that Mr. Puckett was transferred to Mr. Butterworth's section?
4 A Yes, and no. Yes, by -- if you fill out an
. 5 engineering form or a document that requires the attention of i
4 . s the nuclear industry, then these forms have to be absolutely 7 correct. You can't allow any mistake on them.
- e. ,
8 At the same time, we needed additional help in this 1
9 new group that we formed, historical record review group and 10 data input -- computer data input group, where we felt that 11 Mr. Puckett's expertise and historical knowledge of the plant 12 was of help, moroso in that group than it would have been i .
( 13 in our group -- or in the other group, I should say. !
l ( 14 Q What were Mr. Puckett's responsibilities once he got 15 transferred to Mr. Butterworth's section?
l -
- is A specifically, I could not answer that question, to a 17 position description type thing. I could not answer that
- 18 question.
19 At that particular time, my manpower grew to about
- 20 150 people. He was mainly transferred, like I said, because 21 of his historical knowledge of the plant and he acted more as 22 a consultant to the various people in that particular group
] .
i .
I i
59 1 wh n th:y had o quccti n t;ith th3 t: rain logy cf comething j
2 that was new to these people.
4
(
3 You have to understand that we hired new people that 4 came from various other projects. so if KE-1 or the KE-1A .
j 5 card may not strike a bell to some people, what is that. so j 4 he explained what that was.
l 7 certain welders, welder's names, you know -- who
'l i 8 was that7 Now was he qualified? You know, historical data '
i 9 that he had on top of his head. I've got to say that he had i 10 an excellent memory bank. Me knew things that happened ten 11 years ago and he was correct in his analysis or his l8 12 statements. -
4
- 13 Q so he was essentially a consultant to these data l t 14 entry personnel?
i 15 A That's correct.
1 - 16 He was also a supervisor over a particular group ;
I
, 17 that reviewed these documents. When they filled out the form, l
18 the data entry form, he also supervised that particular group l
19 from the standpoint of yes, that's correct, or no, that's not 20 correct.
i 21 Again, we are talking terminology that was used,
- 22 that people were not familiar with.
i e r
1 I
i 1 ,
t .
l
40 i .
1 Q At that point in time he had no responsibility for j
i 2 ongoing work at the Einner plant, is that correct?
3 A Absolutely none. ,
I think you said, in response to a previous I' 4 0 j s question,'that by this time you had 150 people working for f a you? l
. 7 A Approximately, yes.
I e Q Now many of those individuals were welding . !'
9 engineers? (
)
10 A Approximately 15 to 20.
11 Q And how many of them were data entry clerks that la were involved in this entry of the historical records that ,
l [ 13 Mr. Puckett was involved with, that you just described? l j- g j 14 A I would say about 100. They were split up into j 15 various groups, akay? Mr. puckett was not supervisor of the (
l i
16 100, he was the supervisor of maybe a portion of that group, !
l 17 let's say 20. The initial transcribing of data for input.
l 18 Q once again, this job of supervising these 20 or so 19 data entry clerks, was this a job that ordinarily would be I 20 tilled by a welding engineer? [
I
- 21 A No. This was something -- it's not brand new, but i t
l 22 it was fairly new to the industry, that the function was ;
l t l l 1 !
) . .
f i
l .
, l
61 1 previously not existent.
i 2 Q Is it fair to say that the main qualification of
(
j 3 Mr. Puckett for this job was the fact that he had been present 4 at Einmer for a long period of time, as a person who had some ,
5 responsibility for welding?
j 6 A You have to repeat that for me, again. You lost me 7 on the way.
{l , ,
8 Q I'm sorry. Is it a fair characterisation to say l
9 that Mr. Puckett's major qualification for this job -- the one i I
- 10 we have just been discussing, was the fact that he had been i
11 amployed at Zimmer in various capacities for a long period of
\ -
l 12 time, involved in welding?
l 13 A That's a fair statement, yes. '
! ( f a
A4 Q We previously marked, in Nr. Puckett's deposition, i
15 Mr. Goedecke, Puckett Deposition Exhibit Number 30 which is an
~
i 16 NRC Inspection Report, number 82-10 at the Zimmer power i
j 17 plant. I think, in an earlier answer, you referred to a 18 problem with some 32 welder qualification records that j
l 19 Mr. Puckett had responsibility for?
20 A That's right.
21 Q Mr. Puckett has testified that he was, in fact, the 1
l 22 project welding engineer that is referred to in the Inspection l
e i
f 1
62 1 Report, that was involved in that incident. I'd like you to 2 take just a quick look at the Notice of Violation --
3 Inspection Report, Item Number 1-b. And then, in the details 4 of the report, at page 30. And then I have a few questions 5 for you.
6 (Witness reviewing document.]
7 A You did say a and b.
1 j 8 Q I just called your attention to 1-a to start with.
9 A Yes.
10 Q All right. If you would take a look at page 30 of 11 the detail section of that inspection report, also.
12 A Yes.
13 Q First of all, have you seen that Inspection Report
( ,14 before today?
15 A Yes, I have.
~
16 Q Did you see it at or about the time it was issued by 17 the NRC to the Zimmer project?
i 18 A Yes, I did.
! 19 Q There is a reference there to the 32 welder 20 qualification records and there is an assertion that there i 21 were alterations to those records. Are those the same 32 I 22 records that you referred to in a previous answer?
i O
I l .
~
l 63 i
1 A Yes.
2 Q To your knowledge -- well, first of all, I take it
. 3 that Mr. Puckett's assignment to transfer the records from the l .; 1
- 4 old data to this new format was done at your request?
. I 5 A That's correct.
I 6 Q Was there a written procedure that governed the way l
i i
7 in which thi,s transfer of data was to take place and what the -
a final form was to look like?
9 A No, the final form was identified in the new 10 procedure that we had written. The form itself was attached
! I i 11 to the procedure. There was no written procedure of how to
. l l, 12 fill out or transfer information. The procedure -- the new l [ 13 procedure said what this form must contain and who has i (
{ 14 authority to fill out the blocks, et cetera, and how to fill 15 out the blocks.
i It did not address the method that we were using to l 16 i l i
j 17 change data or to transfer data, not change data. l l
j 18 Q okay. There is an assertion in the Inspection .
- 19 Report, at page 30, that there were several changes apparently l
] 20 between the criginal record and the documentation that was 21 transmitted to the QA record management system, including i 22 clarification type data changes, such as coupon thickness, i
i i
j .
j . ,
i C _ . _ _ . - . _ _ _ _ _
.. . .n ,
~
64 1 band test, and it is written as travel spaced --
( 2 A It should be speed.
, 3 That was information that was contained in the 4 package which clarified previous clerical mistakes and errors 5 on the pre-typed forms. All the data that was transposed onto 6 this new format was, indeed, correct. But I'm saying if the 3
7 old data was incorrect, the old form was incorrect, but the j 8 data behind it substantiated the data that Mr. Puckett or i
9 Mr. Sheraton put on these new forms.
4 10 Q What was the disposition of this item of 11 non-compliance, if you know? ,
4 4
12 A To the best of my knowledge, it was dispositioned to
- 13 -- there was nothing wrong with it. It was accepted by the 4
(
j 14 NRC. We answered all of their concerns on these two items and 15 the FBI, as a matter of fact.
16 Q The FBI was involved?
17 A Yes, because the charges were falsification -- .
4 18 deliberate falsification was made.
j 19 Q Was Mr. Puckett the subject of those charges, that l 20 he had --
21 A Yes, Mr. Puckett and Mr. K.K. Sheraton.
l 22 Q Ultimately, though, it was found that there was, in i
I I
f
~
3
._,.---.-.~.,.------,.-.----.-------.-.-.,,.---,--_-n.n._.,.- , - - , . - - _--, - -- ,.. ~
.n-. . . , , . , . - , .
- 1 65
- 1 fact, no falsification of records, is that right?
I 2 A No fa'Isification. Only the omission of the botton-i 3 statement that should have been there, saying that the data ,
4 above is format change only and contains the same information 5 as contained in this package, or something to that effect.
j 6 Q Was that legend, the one you just described, was ,
7 that a procedural requirement?
i 8 A No , sir. It should have been, but it wasn't.
f ,, 9 Q There is also a reference in the same paragraph of 10 the detail section of the report, Puckett Exhibit No. 30, that 11 refers to some discrepancies between welder qualification ,
l 12 documents, as submitted to the State of Ohio, and as
( 13 maintained at the site. Do you recall that instance?
- s.
i 14 A Yes.
15 Q What involvement, if any, did Mr. Puckett have in
! 16 that situation?
- 17 A The submittal of the documents to the State of Ohio,
! 18 to the best of my recollection, was performed by Quality 19 Engineering. The filling out of the. data was the I
j 20 responsibility of Mr. Puckett. The changes that were noted l
21 from one document to another were changes such as band accept 22 versus two side bands.
4 j ,
1 I
l 3
66 1 In other words, it appeared that it was conflicting 1 2 data, but it really wasn't conflicting data. .The information 3 was correct, just different terminology was used. .That's the 4 best of my recollection on those things.
5 Q Was Mr. Puckett responsible for the change in 6 terminology?
7 A Ultimately; yes.
8 Q Again, was there any procedure that governed the way -
9 in which the forms that were submitted to the State of Ohio 10 were to be filled out?
11 A Not particularly to the State of Ohio. It does e
12 state that copies of the form must be submitted to the State
- ( 13 of Ohio. How to fill out the particular form, there was no
'e
( 14 change. One should have been the same as another. There is 15 no reason for a duplicate being other than an exact duplicate.
16 MR. GUILD: I'm sorry. What was your reference?
17 MR. MILLER: My reference, Bob, was that portion of 18 the numbered paragraph four on page 29, that refers to the one 19 welder, symbol KGJ, and the paragraphs that follow. I 20 MR. GUILD: Page 30?
21 MR. MILLER: It starts at the bottom of page 29, 22 paragraph four.
l
67 4
1 MR. GUILD: I see it.
2 -
BY MR. MILLER:
3 Q Mr. Goedecke, there is an indication in t a first ,
4 paragraph.under the numbered paragraph four, that the specific 5 form that was reviewed by the NRC had a change in the 6 thickness of the coupon to which the welder was qualified.
7 Let me give you a moment to look that over.
8 A (Perusing document.) I don't recall this particular 9 item in detail.
10 Q My question was, was it Mr. Puckett's responsibility 11 to see to it that the two forms were identical?
12 A Yes; it was.
l ( 13 Q Do you recall what the disposition of this aspect of i \_
14 the item of non-compliance was?
15 A I don't recall; no.
16 Q In this same Inspection Report, 82-10, there is a l
17 reference to another item of non-compliance. I call your l l
18 attention to the Notice of-Violation, item 2.a.
19 A (Perusing document.] Yes. That in fact was a 20 problem that required correction in the procedure itself.
21 Q Again, Mr. Puckett has testified that he is the 22 project weld engineer that is referred to in the item of Y
O
. I
+ .
l.
68 1 non-compliance. Do you recall the circumstances under which r
2 the NRC inspector made his observations with respect to the 3 issuance of the welder qualification card by Mr. Puckett?
I 4 A This is a separate issue of the welder qualification 5 card issuance and another occasion. This particular occasion 6 here, our procedures were that we would use a computerized 7 print-out. The' deficiency here was we didn't use a 8 computerized print-out. In fact, we had nada out a new welder 9 qualification listing, because the print-out was always late.
10 That's the problem here. It was a procedural violation rather 11 than, as you refer to, not in compliance with the code.
j 12 Q Yes, sir. I think you are referring to item of I r,r 13 non-compliance, example 2.b. I wanted to direct your
(' 14 attention to 2.a.
15 A (Perusing document.) I'm a little confused on this
- 16 particular. I believe, if I am correct, this may be the other i I
17 instance where a welder qualification was about to run out.
18 Mr. Puckett issued a new welder qualification card based on a
&2 19 welder # issue slip. I'm not positive if that is the case or /
4 I-20 not. It sounds like that particular case.
21 Q Do you recall that such an incident occurred where 22 Mr. Puckett issued a new welder qualification slip?
f I %
69
~
1 A That's correct.
2 Q A card. The NRC inspector -- was it in the presence 3 of an NRC inspector? -
4' A Oh, yes. That's the case I was referring to.
- 5 That's why I was sort of hesitant to answer. Yes, in that 6 particular instance, a welder had lost his qualification 7 card. He then went to Mr. Puckett and requested a copy of his 8 welder qualification card. His qualifications were due to run 9 out in approximately five days, if I recall correctly. He had 10 a weld rod slip with him'that he was going to use that 11 particular day.
p 12 Based on that, Mr. Puckett issued the welder a new i
i 13 qualification card, extending his qualifications for the three
(
14 month period that was stipulated in our procedure. It is my 15 understanding, by questicning Mr. Puckett on this particular 16 thing here, that Mr. Puckett instructed the welder that when 17 he had used the rod, to come back to him. He kept the card 18 extending his qualifications for 90 days in his drawer. He 19 issued him a new card.
20 MR. GUILD: I'm sorry. In his drawer?
21 THE WITNESS: Yes; in his desk drawer. In other 22 words, he did not really issue the second card. He told the
( .
70 1 welder that if he used the weld rod, to come back and he would r
2 issue him the other new card, not a duplicate card.
k 3
The welder did in fact not use the rod that 4 particular day, did return to Mr. Puckett and told Mr. Puckett
- 5 that he did not use the rod that day. Mr. Puckett still let 6 him have his duplicate, which was only good for five more
,, 7 days, in which he had time to use the process, so he could be 8 issued a new card. .
,e 9 Mr. Guinn at that time felt that was a violation of p, gg ,
.W-10 cur procedural requirements.
11 BY MR. MILLER:
i 12 Q Did you have any direct involvement in this .
I
- p. 13 situation?
. ( b- 14 A The only involvement I had was after the fact that 15 Mr. duinn came to me and explained the circumstances, and his "# #
16 displeasure with the way it was done. I questioned 17 Mr. Puckett as to how this was done, why he did it. He IB explained to me why he did it and to be quite frank, he 19 explained it wasn't quite right, but he explained it to me to a
20 my satisfaction. I did not feel that Mr. Guinn was right in 21 this instance.
22 Q Did Mr. duinn say that he regarded what Mr. Puckett b
( .
6
,----n-. -- -- -
71 0
e 1 had done as a violation of the applicable procedure?
, , ( .. 2 A Yes'; he did.
q .
) 3 Q Did you agree or disagree with Mr. Guinn? ,
4 A , I disagreed with him. The procedure didn't detail i
S 5 this kind of circumstance. You can't put in a procedure 6 everything that can happen. The procedure only stated that 7 after a welder has used the process, his qualifications will 8 be extended an additional 90 days. It didn't state what you 9 do in every case. Like I said, there was,a problem. It was h"'#~
10 done absolutely correct. I wouldn't have done it this way.
11 I would have issued the welder a duplicate .
l 12 qualification card for the five day period, not based on a rod 1
13 slip, but based on the fact that he was still qualified. The
(
24 problem would have been non-existent.
15 Q Mr. Goedecke, I think you said that when you came to 16 the Zimmer site, there were three individuals who were working 17 for Mr. Puckett; two assistants and one clerical person.
18 Did you have occasion, over the period of time you 19 were at Zimmer, to evaluate the competence and qualifications 20 of those people?
21 A They really didn't have any qualifications other 22 than clerical type qualifications. They were not qualified in i
v t
l l
\ _ _ _- _ - _ - - - - - - - - .- - - - - - - - - - ------ - -
.-- =.-._
72 1 any way, shape or form to make engineering decisions.
, k 2 Q Despite what you have just described as lack of 3 qualifications, were these individuals making engineering type ,
i 4 decisions, as far as you could tell, prior to the time you
, 5 came to the Zimmer facility?
. 6 A In my opinion, yes, they did. They were filling out x 7 these KE-1 cards, which give engineering instructions, and -
8 because of the amount of paper issued on a daily basis. There 9 is no way that Mr. Puckett could have reviewed every one of 10 them for correctness. Consequently, there were mistakes made 11 and things went out to the field with incorrect data on them..
[f 12 Q Did these individuals continue in the employ of
't 4
13 Kaiser during the entire time you were at the Zimmer site?
14 A Yes; they did, with the exception of one, who was 15 later terminated by myself. These individuals did retain 16 their employment status. They certainly did not retain the 17 status for the authority any longer.
e 18 Q Do you know whether or not these individuals had any 19 relationship to Mr. Puckett other than just simply working for 20 him at the Zimmer site?
21 A It was my understanding that two of these 22 individuals were relatives of Mr. Puckett. I was told that at f .
4 f
I
_ , . _ _ _ _ , . - .-- _.-__y _ - _ , . - - - - . ._ , _ . . , , _ _ , , , - , , . _ , , , , . -
73 1 0 tuch lotor dato. It w30 co verified that at least one 2 individual was indeed the son-in-law of Mr. Puckett.
(
- 3 MR. MILLER: Off the record. Let's break for lunch 4 at this time. '
5 '[Whereupon, at 12:25 p.m., the deposition was 6 recessed for lunch, to reconvene this same day, at 1:35 p.m.]
7 8
9 10 11 12 ,
t i 13 k 14 15 16 17 18 19 20 21 22 e
- c. , - . _ .,
74 1 AFTERNOON SESSION
( 2 [1:35 P.M.]
3 MR. MILLER: Back on the record. I have asked the 4 Reporter to mark as Goedecke Deposition Exhibit No. 2, a two 5 page document entitled " Employee Performance Appraisal and 6 Development Plan" for Mr. Puckett. The performance period is 7 indicated as August 1, 1979 to August 1, 1980. As Goedecke 8 Deposition Exhibit No. 3, the same form for the period July 1,
- 9 1980 to May 1, 1981. I believe that both of these have -
l 10 previously been marked in Mr. Puckett's deposition, but in a 11 auch less legible form, because of the copying process. ,
12 MR. GUILD: The first one is 1979/19807 i
13 MR. MILLER: Yes.
i (
14 [Goedecke Deposition Exhibit Nos. 2 15
& 3 were marked for identification.)
16 17 18 19 20 21 22 i
e e
,w-~- - - . - - ..--n, , - - - , - - - - - - - - - - - - - - - - - - - - - - - - - - - - - .- ,e , . - . - - , - , - w a- - , , - - - - - - - . - - - - - - --+ - --w-. . ,
.- .- .- . . ~ . . .
75 1 Whereupon, 2 MANFRED L. GOEDECKE, 3 having been called for examination by counsel on behalf of the I
4 Applicant, and having been previously duly sworn, resumed the '
5 stand, and was further examined and testified as follows:
6 EXAMINATION 7 BY MR. MILLER: (Resuming] .
8 Q Mr. Goedecke, I show you documents tha't have been
, 9 marked as Goedecke Deposition Exhibit Nos. 2 and 3 for 10 identification. Your name doesn't appear anywhere on there, 11 sir. I ask you whether you have seen those documents before.
9 12 A (Perusing documents.) At the Zimmer nuclear
- 13 project, no, I have not seen these documents before.
14 MR. MILLER: I would like the Reporter to mark as 15 Goedecke Deposition Exhibit No. 4 for identification, a 16 memorandum from Mr. Goedecks to Geri Keegan, dated October 29, 17 1981.
18 (Goedecke Deposition Exhibit No. 4 19 was marked for identification.)
20 BY MR. MILLER:
21 Q Mr. Goedecke, I show you a document that has been 22 marked Goedecke Deposition Exhibit No. 4 for identification. I O
e I
e l
1 l
\
76 1 I ask if that is your signature which appears there.
( 2 A (Perusing document.] Yes; it is.
. 3 Q Under what circumstances did you direct that ,
4 Mr. Puckett's salary be adjusted as' indicated in that 5 memorandum? .
6 A There was a transition period between responsible
> 7 supervision from Mr. Sandlin, who was the Project Civil 8 Manager, to myself. It was my understanding at the time that 9 the appropriate action was overdue and as the new manager of 10 Mr. Puckett, that I take some action, which I did.
11 Q The action that is taken is an increase in salary of -
i 12 ten percent; is that correct?
13 A That's correct.
[
24 Q Mr. Sandlin was Mr. Puckett's prior supervisor 15 before you arrived?
16 A That's correct.
17 Q Can you tell me whether that is the same Mr. Sandlin 18 whose signature appears in the lower lefthand corner of 19 Exhibit Nos. 2 and 3?
20 A Yes; that is Jim Sandlin. He is deceased now.
21 Q When you authorized the increase in Mr. Puckett's 22 salary on October 29, 1981, had you personally conducted any I
9
, 77 1 evaluation of Mr. Puckett's capabilities or entitlement to 2 additional salary?
{
A
) 3 At the particular date of October 29, 1981, I was at 4 the site for approximately two weeks. To really fern an
- 5 opinion of his capabilities at that particular time, other
, , 6 than realizing that there were certain deficiencies, no. I
- 7 didn't have the time to properly evaluate Mr. Puckett. The 8 increase was strictly given as a follow-up action that someone 9 else conducted. ,
10 MR. MII1ER: I would like the Reporter to mark as 9
j 11 Goedecke Deposition Exhibit No. 5 for identification, a form l 12 that is entitled " Performance Evaluation." It has a date on
/ 13 the second page that appears to be April 19, 1982. The 4
(
j 14 evaluation period is October 5, 1981 to April 15, 1982.
- .' 15 (Goedecke Deposition Exhibit No. 5 16 i
was marked for identification.)
I 17 BY MR. MILLER:
7
! 18 Q I show you a document that has been marked as l 19 Goedecke Deposition Exhibit No. 5 for identification. I ask j 20 if that is your signature that appears on the second page.
j 21 A (Perusing document.] Yes; it is.
22 Q Was this the first occasion on which you performed a 4
. 1 i
i .
I s i
4 4
____.--_.,.r_, ,.,.-._..--..._,,_..,,~,.,,..m, --
. , . , . , , - . . . . .~..,_,-,w..._.,__ ,-,,,..___,,,,,m., , , , , , , - , _ _ ~ , , , , _ , , .
l
, 78 1 formal performance evaluation of Mr. Puckett, after you 2 arrived at the Zimmer facility? '
l .
3 A That's correct. ,
4 Q There is a series of grades, if you will, on the 5 first page.of the exhibit. Can you tell me what the line item 6 number two, " knowledge of work" -- what was the basis for the l
7 evaluation?, What did you consider in forming your opinion? .
8 A The comments on the righthand side really state my .l \
9 "needs improvement" categorization. His knowledge of work and l l
j 10 the proper code interpretations; that's what I am referring to i
11 here. Not knowledge of work and technical skills, such as
, 12 actual welding technology knowledge is addressed here. Actual welding technology knowledge was quite sufficient; actual
/
13
(
,14 welding.
15 As far as actual code or engineering knowledge, that
~
16 is what I am addressing here. In my opinion, he did not 17 possess the amount of knowledge that is required.
i 18 Q Line item four, quantity of work. Mr. Puckett was l 19 graded by you as exceeding requirements.
On what basis did 20 you formulate that opinion?
- i j 21 A Again, I referred to the comments section. For the
- 22 amount of work required, Mr. Puckett does extremely well.
9 i
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. 79 i
1 What I am saying is the quantity of work that went to the I' ( 2 Welding Depart'ent m on a daily basis, Mr. Puckett had done 1 ~
- f. 3 extremely well with the help he had at the time, keeping in ,
4 mind that.in the beginning, I was just an observer and he 5 handled the whole Department by himself. He is a very 6 industrious worker. That is what I as trying to say here.
l, 7 Q I would now like to drop down to line item ten,
-l '
8 cooperation. In the comments section, it says "Several l
9 reports indicate that more cooperation is required." First of 10 all, from whom did you receive reports that cooperation was '
11 required? ,
12 A From the various department managers; civil 13 managers, mechanical managers and so on. They felt in verbal
(
i 14 communications maybe since I arrived there, he really stood on i
! 15 his hind legs a lot of time and just refused to do a lot of 16 things that before my arrival, he just signed off on.
17 I think it is quite obvious that if somebody looks
! 18 over your shoulder, you are a little more conscientious and i
19 therefore, your workload slows down considerably because like l 20 I said, somebody is looking over your shoulder.
I i 21 There were several reports.
t 22 Q Were there complaints about the technical positions j
1
~
i
, i 80 1 he was taking?
~
( 2 A Technical positions plus -- not just technical l 3 positions, but his approval of certain documents slowed down i .
4 quite a bit. That certainly helped push the complaint cycle.
5 Q In what respect was that related to your arrival as 6 the project welding manager?
1 A Well, I don't really -- I only know how to phrase it 8 one way. Since my arrival, things took a more directive 9 action approach. In other words, I made decisions on the 10 spot. Previously, it took some time to do that. The 11 dissatisfaction from these department managers was expressed ,
l 12 simply because Worley, I guess, was somewhat in a position of 13 lower capacity. I don't really know how to put it.
- 14 He quit cooperating, whether it was because I l
15 arrived or whether he just slowed down because I was looking 16 over his shoulder. I have had a lot of complaints from the 17 managers that Worley just didn't cooperate. .
18 Q Is this cooperation in tasks where there was a j 19 number of different disciplines required to participate in the 20 resolution of a problem?
l 21 A Not really. We are talking about tasks here that 1
22 involved a certain discipline. Every time you have three I ,
t
.-..m._-._,,_._____._..m . - . . , _ . , _ - _ - - . . . _ , r,_ _ , _ _ . . _ _ . _ . . _ _ _ . _ ~ _ , _ - --. . _ , . . - _ _ _ -_ -.. ._,__ -._ __ ,y . , -
81 l 1 disciplines that need to get the work done, everybody's job is e
2 more importa'nt than the other discipline.
' 3 In this particular case, it was impossible for 4 Mr. Puckett to satisfy everybody. Instead of trying to 5 continue the way he did before, trying to satisfy everybody, 6 he just stepped back and slowed down.
7 What I meant by more cooperation is required, is he .
8 should have dropped back into his old modus operandi and 9 satisfied everybody to the best of his ability, instead of 10 saying, that's it, I can't do no more today; that kind of 11 thing.
l 12 Did I answer your question?
13 Q I think so. Number 11, client relations, needs
(
!( 14 better verbal and written communications. In what respect 15 were Mr. Puckett's verbal and written communications 16 deficient, if they were?
17 A Well, I said there "see item 10 above." It really 18 relates to the same thing, his communications cycle, whether i
19 verbal or written, whether it was with our own management team 20 or the client tea =, at that particular time, his attitude was 21 not really geared toward cooperation, whether it was a 22 sentiment or by being there or whatever. Other things o
y; O. . .v r* ,i n l .
I l l
l
82 1 contributed to the fact that he fust didn't cooperate.
2 Q I would now like to drop down to the ones that are 3 marked "Not Applicable," lines 15 through 19, calling your ,
4 attention to Goedecke Deposition Exhibit Nos. 2 and 3. There 5 was a rating for Mr. Puckett in prior periods under the 6 heading " Managerial Skills" on those two exhibits. There are 7 not the same number of subordinate categories as there are on 8 Exhibit No. 5.
9 How did you determine rating Mr. Puckett for these 10 characteristics as not applicable?
11 A Simply because I took over. The managerial skills -
l 12 are administrative skills. These skills did not apply to an 13 engineering title. Previously, there was a rating for that. '
,, (
14 In my opinion, these ratings were incorrect.
15 Q I'm sorry. Which ratings were incorrect?
16 'A The managerial skills.
17 -
Q The earlier --
18 A That's correct. There should never have been a 19 rating on it, because he was not in a managerial position. He 20 was in a supervisory position.
l l 21 Q Perhaps you would define for us what the difference 22 is, in your judgment, between supervisory and managerial i
f I
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83 1 positions.
2 A Under Mr. Jim Sandlin's leadership, Mr. Puckett sort
(
, 3 of ran the Department, which identifies managerial. abilities 4 and skills. When I arrived, I took over that Department.
~
5 Therefore, managerial skills were no longer required because 6 those were my skills now.
7 Q I see. I would like to turn to page two of Exhibit .
8 No. 5. Thi first sentence says " Development progress during 9 evaluation period; Mr. Puckett is beginning to understand the 10 requirements necessary in the construction of nuclear power 11 plants."
~
12 What requirements are you referring to in that first ;
, i 13 sentence?
(
14 A The requirements are codes, standards, regulatory j 15 guides, and the current state-of-the-art installation l
16 practices.
17 Q The next sentence, after talking about "it is not
- 18 his fault," that there were several major violations of codes 19 and specifications. Do you have a recollection of what those 20 major violations of codes and specifications were?
21 A Yes. We addressed those earlier. Procedural (
22 violations; welding procedure specifications that were not in i
9
_. , ,, __,__.-__-_.-7 ._ _ _ _ _ - . _ _ _ _ - , ,, , . - , , , , . , , , . _ , - . _ , , - . , . - , -
. ,,,-y - - . , _-- ----
.-. _ .... __._ ._. _ . . . . . ~ . . _ -
i
. 84 1 compliance with the coder welder qualification records that 2
~
did not reflect the requirements of the code; weld travelers
- 3 or welding directions to the field. Specifically,'the
- 4 material requirements that require pre-heat or stress 5 relieving because of thickness, et cetera, were not addressed .
! 6 properly. Stop work was the result of some of these items.
7 Q The stop work orders that Mr. Puckett initiated?
1 8 A Stop work orders that I initiated because of
- ~
9 directions to the field given by Mr. Puckett. Stress 10 relieving operations, for instance, was my first stop work 11 order; improper stress relieving techniques. That's what I ,
12 call major violations.
) 13 Q With respect to the stress-relieving, was 14 Mr. Puckett responsible for the stress-relieving -- I had j 15 better back up.
l 16 Under what set of circumstances does the welding 17 engineer involve himself with stress-relieving at the Zimmer i 18 project?
19 A First, he initiates the time and temperature for a '
20 given component. That's the first thing he does. In other 21 words, if I have a component that is one-inch thick, I will 22 need to stress-relieve that component for a minimum of one I -
e
4 85 1 hour between a temperature range, let's say 1150 to 1200 j e
, 2 degrees Fahrenheit.
l 3 Q Does the stress-relieving operation take place ,
4 befor's, during, or after any welding operation?
5 A After the weldsent is completed.
6 Q I see. And are the circu=etances under which
!, 7 stress-relieving is to take place specified by the architect *
- 8 engineer?
9 A It's specified by the code and the architect -
} 10 engineer, obviously.
. 11 Q so the welding engineer was to -- well, what was the .
l l 12 function of the welding engineer in the stress-relieving i-
,- ( 13 function?
i' 14 A You have really three functions, to put it short.
15 Number one, direct whether or not stress-relieving is 16 required. In some cases, I found that an N/A, as "not l 17 applicable," was put in a column when stress-relieving did, t 18 indeed -- should have been performed.
) 19 In other cases, I found that the time did not 20 correlate with the thickness. And thirdly, I found that the i j 21 temperature differential that should have been maintained was l
l 22 not maintained.
i (
D e 9
- - - - . w, , , - , - , - , . , , . , - , . , , . , ,,m- - , - - . . - . - - - _ - - - ,,e, --,,,,,--,,v-w,,,,,,,__,,-. ,, -- , , , . ~ , , , --w- . .-,, , . . . , - , ,-
86 1 To answer your question directly, he is responsible g 2 to initiate 't2Ha stress-relieving operation. lHe is responsible
]' ,
3 to assure that a stress-relieving operation is po' formed r with 4 the proper time and temperature. Thirdly, to review the l
5 stress-relieving charts to assure that the time and
)'i.I 6 temperature plus the temperature differential is maintained
- i. 7 during the whole operation. If it falls outside either way, a you are not in compliance with the code. And in this case, 9 that's the way it was.
10 Q I'm sorry. What was the way it was?
a j 11 A The first stop-work order that I issued, the ,
I 12 incorrect time and temperature was given. ,
)
l , 13 Q By whom?
[
l %.
,. 14 A By Mr. Puckett. And there were several components l't involved, and there were more components to be done.
15 That's 16 Uhatastop-workorder. I could not allow for this thing to /* # '
17 continue.
i 18 Q Are there any other specific instances of violation, l
19 major violations of codes and specifications that you can i ,
! 20 recall that you were referring to in this sentence? !
l 21 A Yes. There were several welders that were employed 22 that weren't properly qualified to the code, and still i
i
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=
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, 87 1 assigned and still permitted to weld on components.
2 Q The next sentence in this first block on the second 3 page of Exhibit 5 says, "It is further understood that.if he 4 brought major problems to the past project manager, these 5 problems were never acted upon."
6 Is the past project manger Mr. Sandlin?
7 A No,. The past project manager was a gentleman by the i.
8 name of Marshal. Sandlin wau the civil manager. ,
9 Q Okay. It goes en to say -- well, how did you 10 understand that these problems were not acted upon? Is that 11 what Mr. Puckett told you, or did you have --
12 A That's what Mr. Puckett brought to my attention,
/
'. 13 that, yes, that he did know that there were problems, but
(
,14 every time he brings problem to management, nobody acts on it.
15 Q The paragraph goes on to say, "His actual technical 16 abilities meet all requirements." Which technical abilities 17 are you referring no, sir?
18 A His technical abilities as far as evaluating a ,
l 19 weldment for acceptance or rejection. And as far as his 20 ability to judge whether, for instance, amperage and voltage 21 were sufficient to make a weldment, proper setting of a 22 machine, et cetera. That's what I call technical abilities,.
l ,
l 4
_ . , _ _ _ _ . . _ ~ . - _ _ _ , . _ , , , . - _ , , , , , . _ _ _ . - , , _ _ , . _ , . _ _ . - _ _ ,
88 1 actual hands-on type of work.
e
, s 2 Q Then the major development needs, you say that i ,' . 3 Mr. Puckett needs to learn the proper application's of codes 4 and standards in the construction of nuclear power plants.
5 Which codes and standards were you referring to in 6 that sentence?
. 7 A All codes and standards, ASMI, ANSI, and AWS.
8 Q Then the development plans, you planned to have him j 9 attend some seminars dealing with the application of codes and 10 standards. Were you able to follow through on that plan? .
! 11 A Yes, sir, I did.
J 12 Q And about how much time did Mr. Puckett spend in 4
r 13 these seminars?
)
[%
, 14 A At this particular time period here, we're talking 1
] 15 10/5 to 4/15, a six-month period, he attended, I believe, only
~
16 one at that particular time, which was welding in nuclear i 3 =' 6,4 17 sknstruction. ,
18 Q Who conducted that seminar?
a i 19 A It was an outside organization. Again, it was a l 20 professional development seminar.
21 Q All right. Do you know how long the seminar I
22 lasted?
b 4
( ,
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I
. - - . - - -- .. . - - - - . . , . _ - . . . ~ . - . . . -- - - . . .
89 1 A one week.
or I
( $ 2 Q You then go on to say, "In addition, a new project I 3 welding engineer whose knowledge of code standards and 4 technical applications is excellent will help Mr. Puckett !
5 tremendously."
k .
6 Is that Mr. Flaherty that you are 'eferring r to?
i 7 A Yes. '
8 Q All right. At the bottom of page 2 of Exhibit 5 is 9 a statement with the employee's comments and what appears to 10 ba Mr. Puckett's signature,
]
i l
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11 I take it, Mr. Puckett then signed this document
! 12 when you presented it to him?
l l
- " 13 A No, sir, he did not. He objected to the initial i
( s
! 14 evaluation. He did not sign this document. As a matter of e
15 fact, he was quite upset about it. i ms 16 It was then that I first verbally addressed by. p s' C,
- 17 evaluation with him and my reasons behind it. I have then 1
18 followed up to this evaluation right here by a written letter,
! 19 and I believe it was addressed to Mrs. Keegan, or it could 20 have been at that time se=eone else, explaining my action 21 here.
1 ,
l 22 Q All right. Just a second.
O l
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i i
l 1
i
- _ .. __ . . . ~ _ _ . .__ ._
90 1 When you first showed this evaluation to
( 2 Mr. Puckett, you say that he was upset. Did he think that 3 your comments were unfair? I 4 A .Yes. Without full explanation, yes, he thought my 1
! 5 comments were unfair. Unfortunately, this document does not j 6 lend itself to explain every action you take. So that's the
!. 7 reason why you have a session with the individual after you l 8 write this, give him a chance to read it, and he has a chance i
I, 9 to make his comments, express his dissatisfaction, and you try j 10 to talk it out with him, and you try to tell him why you are j 11 taking this action.
j,, 12 Q In your oral session with Mr. Puckett, when you 13 communicated the evaluation to him, were you able to satisfy i
(
14 him with respect to the reasons for your evaluation?
1 15 A Yes, I was able to satisfy him, provided I followed 16 up in writing with what my discussions were with him after the
{ 17 fact.
l 18 Q Okay.
i
{ 19 A Which I did.
t 20 MR. MILLER: I would like the reporter to mark this i
21 as Goedecke Deposition Exhibit 6, a memorandum from 22 Mr. Goedecks to Mr. Don Biller, Manager of Personnel, dated '
\
- l
( .
l 1
i 1 .
91 1 April 20, 1982.
2 (Goedecke Deposition Exhibit No. 6
, 3 was marked for identification.]
4 BY MR. MIILER: ,
5 Q 'Mr. Goedecke, I show you a document that has been j 6 marked Goedecke Deposition Exhibit 6 for identification and 7 ask you if that is you,r signature on the second page?
e 8 A That's correct.
)
9 Q And is this the substance of your oral conversation I
10 with Mr. Puckett?
f 11 A Yes, it is.
i I believe that you have addressed already the
) 12 Q l!
!,' i 13 numbered paragraph, the first numbered paragraph, 1, on page 1 i,
(
,14 of Exhibit 6, the one that says, "Mr. Puckett is an 15 exceptionally industrious worker."
16 The second paragraph says, "Mr. Puckett has l
4 17 developed and fosters a very good rapport with all individuals 18 who report to him."
i j 19 At that point in time, how many individuals were 20 reporting to him?
21 A About four.
4 l 22 Q These are the four individuals that --
i
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l 1
)
l i
i
92 ,
i 1 A well, it was three to begin with, and I think I 2 added an additional secretary at that particular time.
3 Q I see. Some of these people were related'to 4 Mr. Puckett?
5 A Two of these people were related to Mr. Puckett.
6 Q Then (3), "Mr. Puckett's attitude in response to 7 guidance and supervision from his supervisor within the '
8 Welding Department, i.e. myself, is for all practical purposes 9 faultless."
10 I take it from that that you and Mr. Puckett got 11 along well.
l 12 A dnapersonallevel,yes.
13 Q Well, was this just a personal level, or did this 14 have to do with the way he responded to your direction?
! 15 A Well, he did. He slways responded to my direction.
16 He never -- he has never,~ever, to my recollection, disagreed 17 or refused to take guidance or direction.
L 18 Q I think you've already addressed Comment No. 4, and 19 I think we've already addressed Comments No. 1 and 2 under the i
20 heading, " Conversely, however," on the bottom of page 1.
21 Then at the top of page 2 of Exhibit 6, there is a 22 sentence that refers to Mr. Puckett being on the verge of l .
- ( .
~ . _ . - . -
93 1 locing credibility cnd tho rGepect of hio pacra in the walding
~
2 and quality assurance organizations.
3 How did you determine, Mr. Goedecke, that, in your
~
, ,4 judgment, he was on the verge of losing credibility and -
5 respect?'
6 A Well, on numerous occasions, I have had to overrule
, 7 , Mr. Puckett in his engineering decisions, and unfortunately a 8 lot of these overrulings took place in front of his peers and 9 the quality assurance organization that happened to be 10 involved in a discussion.of whether something was correct or 11 incorrect. And I believe that any time you constantly 12 overrule someone in his decision, that eventually he will lose'
,' ,' 13 respect, and I believe that's pretty common to any
~
( 14 app 11 cation. It really doesn't matter whether it's an 15 engineering application or what.
16 Q All right. Now in connection with this evaluation, 17 was Mr. Puckett -- was his salary reduced?
j 18 A No, sir.
l 19 Q Was his salary raised?
I
! 20 A No, sir.
21 MR. MILLER: Please mark this as Goedecke Deposition 22 Exhibit 7 for identification, a performance evaluation.
l
[
l
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I
, 94
- 1 Mr. Goedecke's signature appears on the second page. It's for 2 the period April 15, 1982 to April 1, 1983. ,
3 (Goedecke Deposition Exhibit No. 7 4 was marked for identification.]
5 'BY MR. MILLER:
6 Q I take it, just to and on this Exhibit 6, the 7 memorandum you wrote to Mr. Biller, that after Mr. Puckett 8 read that memorandum, he signed his performance evaluation?
9 A That's correct. .
10 Q What would have'been the consequences if he had 11 declined to sign his performance evaluation?
12 A I would have proceeded anyway. It would have gone
'I
?
i 13 in his file, and it would have gone to the corporate office
( 14 for approval.
4 15 Q Okay. Now I show you a document that has been 16 marked Goedecke Deposition Exhibit 7 for identification and 17 ask you if that is your signature that appears on the second 8
18 page?
19 A Yes, it is.
20 Q All right. The next evaluation after the one we 21 were just reviewing, Goedecke Deposition Exhibit 5?
22 A Yes, sir, it is.
IN k
( .
l
. 95 1 9 And in this one, I see that his title has changed .
)
( 2 from Project ^ Engineering / Superintendent to Senior Engineer.
3 Is there a -- what significance, if any, is there to .
4 the change in title?
- 5 A The significance is simply that he was no longer t
i 6 responsible for the project, which he previously was, from a 7 project scope type to a Senior Engineer who reports to the 8 Project Engineer. There was a shift in responsibilities from 9 Mr. Puckett to the Project Engineer.
10 Q By the time this evaluation took place in April of 11 1983, can you recall, was Mr. Puckett reporting to ,
12 Mr. Butterworth at this point in time?
13 A No. I believe at this timeframe he was still
(
14 reporting to Mr. Flaherty.
15 Q On the quantity of the~ work, he got an " Exceeds 16 Requirements." I take it that his capacity for work continued 17 to be great.
18 A Yes, an exceptional worker.
19 Q And dependability, he moved up from " Meets !
, 1 20 Requirements" to " Exceeds Requirements."
{
21 A That's correct.
I 22 Q On what basis did that increase in your evaluation ,
( .
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96 1 take place?
2 A Well, I think that Mr. Puckett seemed., at my first
[
i 3 evaluation -- and maybe he wasn't used to that kind of
- 4 approach -- that I've meant what I've said, and that I would 5 send him to seminars, that I would spend extra time, if l l
- 6 necessary, with him. That includes Mr. John Flaherty, of i N j 7 course, and at that time, Mr. Paul Evans had-arrived. We l 8 spent a lot of time with Worley explaining codes to him, and i
9 he was a willing listener, and he learned.
, 10 Q Okay. Now, line 10, " Cooperation " he moved from a ,
11 "Needs Improvement" to " Exceeds Requirements."
12 In the year from April of '82 to April of '83, were i 13 Mr. Puckett's responsibilities such that he would have had the
(
,14 interaction with supervisors in other departments that he had f
15 in the preceding evaluation period?
16 A No, he did not. What we are addressing here, 17 cooperation, is strictly intra-department related.
18 Q And within the department, your observation was that 19 he was very cooperative?
4 1
20 A Yes, he was.
l 21 Q All right. In the " Development, Progress," you say 22 that he has continuing education that he's involved himself o
4 0
f 0
-.--,,---__.w,---,,,.----~,v,,,,.-.% ~---y- ,--,,m, -,,_m. .- _,,.-.-.....-----.-_---m. .._.,-_._..m. , , , , , _ . . . . - _ - , _ - - , - - . . . _ _ _ . - - . , - - . - . . , -
. 97 1 in, which has helped him in the following areas, and then the
! ( 2 four are list'ed.
3 From the period of the prior evaluation, did you
- n 4 personally observe an improvement in Mr. Puckett's application 1
5 of the various welding codes at the Zimmer project?
l 6 A What I mean by " code application," is the proper 7 interpretation of which code is applicable. He learned that.
, 8 Q The next one is -- well, let me just ask. at this
~
9 point in time, had he progressed to where he was consistently
! 10 able to identify the proper code?
, 11 A No, I wouldn't say " consistently," but at that ,
. 12 particular time, as a minimum, ha'would, in order to make a 13 decision -- he would come and say, "This is the way I see it.
[
14 Do you agree?" And just from the way he said, "This is the 15 way I see it," I would say that he did know 90 percent of the j 16 time that it was the correct code, which one was applicable.
l 17 Q All right. No. 2 is " Procedure Preparation." In
- 18 the year that ended in this evaluation period, had Mr. Puckett 1
j 19 had any responsibilities that required him to prepara 20 procedures?
21 A I am referring to the courses he took. I'm
- 22 referring to the excellent marks he's got in the examinations i
d
( :
- -,--,.~c--w- .%, . . _ ~ - - - . , - - _ , - , - - . ~ , - - - - -- _ .. -,- e .,-,.-,-..w,w,,,------- - - . -. , ,-- - - - - . -v--.------ - - , , , , . --_y+-.,,,---,--w--,-,--,, .
98 1 that follow these courses. The examinations showed that he
{f 2 did, indeed, learn how to prepara a procedure.
p 3 Q Did, in fact, he have any responsibility in the year 4 ending April of 1983 for preparation of procedures?
i* 5 A No, sir, he did not.
6 Q Okay. The next line item is " Interpretation of 7 Code, Standards, and Specification > Requirements."
Is this 8 also an area in which his marks on the continuing education 9 courses indicate that he had improved? -
10 A Yes, sir. '
11 Q Did he have any responsibility for interpretation of 12 i
codes, standards, and specification requirements in the year eg 13 that ended in April, '83?
- ( k
,14 A No, sir.
15 Q All right. The last one is " Practical Application 16 of Welding and NDE Processes." Could you describe what that i
17 means? What is practical application of welding and ,
i 18 non-destructive examination processes refer to?
I 19 A Well, previously to these courses, he was versed in 20 the two processes that are germane to the nuclear industry;
! 21 namely,c,.o wsheatmetal arc welding or SMAW and gas tungsten arc [4 22 welding or GTAW.
i --
l l
l l
- - _ . . . - . , , . - . - , - - . . . . . - _ . - - - - . , , - , . - , . . - - . . . , - , . - - . - . , - - , , - - . - . , _ . - - ....L
, 99 1 The courses taught him, in addition to those
[
2 particular processes, the practical application and welding 3 methods in various other processes. And that's what's
- l. 4 referred to here.
5 Q JCL1 right. The " Major Development Needs" are that 6 Mr. Puckett needs to reassume a supervisor position in the 1 7 Welding Department. *
- 8 At this point in time, did you consider that 9 Mr. Puckett had a supervisory position?
10 A I considered Mr. Puckett, at this particular time, 1
4 11 for evaluation in a supervisory position.
12 Q But what were his actual responsibilities as he I 13 performed them on a day-to-day basis? A supervisory one?
(
! ,14 A He did not. I said ha needs to reassume. That does i
15 not mean he did. As you see in the " Development Plans," it !
16 clearly states that he was not placed in a supervisory 17 position, but that was my intention, to place him in one.
18 Q In a supervisory position, he would again have 19 people reporting directly to him.
20 A That's correct.
21 Q I think the Zimmer project shut down in early 1984.
22 A That's correct.
9 i
e I
100 1 Q Between April of '83 and when the project shut down, f
( 2 did you have the opportunity to place Mr. Puckett in a I
3 supervisory position in the Welding Department? '
4 A Not in the current operations Department, no, sir, I
' 5 did not, for the simple reason -- let me explain.
6 *He needs to reassume a supervisory position.
7 Ordinarily when you place someone in a supervisory position,
- s you -- at least it's my practice -- I give them the least H 9 responsible supervisory position to see if he can handle, 10 number one, the people that report to him; number two, how his 11 technical evaluations aret and three, how does he apply what 12 he has learned. How does he apply? Does he apply it properly .
l , 13 now, or does he refer back to his old mistakes?
l 14 It has always been my habit and position to give
!6 j 15 someone a second shot, and Mr. Puckett certainly deserved a 16 second shot, because as I said, he applied himself. I don't 1 i e-17 mean that he was always correct, but he applied himself. Non' g/40 is one is always correct.
i l 19 However, this supervision position never did open 20 up. It was really -- it didn't really land itself for his .
l 21 capabilities, let's put it this way.
22 Q In Mr. Puckett's deposition at page 62, i
, k I
1 i
___.__.-_____-_._.m_ _ _ _ . _ . _ _ _ _ _ _ _ , . _ _ _ . . _ . . . _ _ . _ _ . . , , _ , . _ , , _ _ _ _ , _ _ _ , . _ _ _ _ _ _ _ _ _ _
4
, 101 1 Mr. Goedecke, he was asked the following question and gave the l l
2 following answers:
[ l i
- i 3 Question: "And what, if anything, did he" -- and the reference is to a man named DeWald, who was the quality 4
j i 5 control manager at Comstock electric at Braidwood - "tell you
! 6 about the position you would be asked to fill?"
l
} -
7 Answer: "He told me I would be filling a Level III 1 -
8 QC inspector's position." '
i' 9 Then later on at page 64, the question was asked: ,
, 10 "What else, if anything, did Mr. DeWald tell you I
- l 11 about your duties as a Level III?"
I .
! 12 Answer: " Basically what he told me was that my job I. -
( 13 would be to work closely with the other weld inspectors, the
(
j 14 Level II's, and that in some cases I may be called on if they
}' 15 had a conflict in the field with an inspection, such as a weld i
inspector thinking a weld might be rejectable, the welder l 16 i
l 17 thinking that the veld might be acceptable, that I might be
- 18 called on to go out and look at the weld and make a final j 19 disposition on whether it was an acceptable or a rejectable ,
20 weld."
21 Then at page 65, the third question, another l
l 22 question was asked 4
S l
1 I
i
102 1 "All right. Anything else that he told you about
. 2 your duties? .
3 Answer: "No, not really, other than the fact that I
=,
4 would be responsible for all weld-related activities."
5 Mr. Goedecke, based on your experiences with l 6 Mr. Puckett at the Zimmer facility, do you have an opinion as l 7 to tihether or not Mr. Puckett was qualified to be' responsible
+
8 for all weld-related activities and perform the functions of a 9 Level III as he understood them for Comstock at the Braidwood 10 site?
11 A We are basically dealing with three questions. I
, 12 will take one question at a time.
i t 13 Q Okay.
(
- 14 A The first question, was he qualified -- and I mean 15 qualified, not certified but qualified -- was he qualified.
1 -
l 16 to perform the functions of a Level III? My answer is no. To l
17 explain my answer of no, a Level III is the ultimate, ultimate 18 supervisory level that is required to make any judgmental 19 calls on a nuclear power. The ultimate person. In that 20 capacity, I would say no.
) 21 The second question was to make judgmental calls of 22 acceptance and rejection of weldments, actual visual i
103 1 examinations. To that I would say yes, he could make
( 2 judgmental calls. That is, by the way, the grayest area in
- I -
3 the industry. What anyone accepts, I may reject, or
') ,
- 's 4 vice-versa. But to make calls, yes, because his practical
~D 5 experience as a welder, as far as I am concerned, is
' 5 unquestionable.
!:s -
l 7 Item 3, whether or not he was capable of handling
! i 8 all welding-related activities at a nuclear project and be
!" solely responsible for it, my answer is no, based on what I 9
\ '
^
j, 10 have known of him when he worked for me. This was his first 1
11 job, the way I understand it, after he left Kaiser.
l -
12 You could take it a step further, if you like, based
,4 13 on his phone calls to me.
l {
j) 14 Q We will get to the phone calls in just a second. .
15 A Well, that is just to point out that the phone calls l,
16 that I received, he was still not able to make decisions on I
i 17 his own as a person that is in charge of a nuclear project 4
!' 18 should be able to make.
19 Q You understand that Mr. Puckett was not going to be 20 responsible for all welding activities for all contractors,
] 21 just for the electrical contractor's scope of work.
t j 22 A I understand.
i 2 ,
e l
i l
1 .
i
104 1 Q W:uld that change your answers in any way?
2 A No. You are still dealing with a code and we are 3 still dealing with specifications. ,
- 4 Q And what is 3,t about dealing with the code and *
, 5 specificitions that leads you to conclude that Mr. Puckett 6 would not be qualified to be responsible for all weld-related activities for the electrical contractor?
i 7
8 A His questions to me via telephone calls, questions 9 that are quite obvious as far as the answers are concerned, ,
10 and did not require a phone call to me. He should have just 11 stood by his decision. Assuring himself, assuring someone 12 that he is correct and getting a third party involved, to me
( 13 it shows a sign of insecurity.
( 14 Q Let me put the phone calls to one side, and I would 15 ask you, if you can, in your answer to put yourself in the 16 point of time where the Zimmer project ended, and let's 17 hypothesize -- by the way, did anyone from constock contact !
18 you and ask you for your opinion of Mr. Puckett prior to the 19 time they hired him?
20 A No.
21 Q All right. Let's assume that that took place and 22 the person from Comstock said, in effect, we are going to make e
. 0 l
i
105 1 Mr. Puckett responsible for all weld-related activities. My
( 2 question is, on the basis of what you knew about Mr. Puckett's 3 qualification from your experience with him at Zimm'er, do you 4 believe that he was qualified for such a position at 8
5 Braidwood?
. 6 A No.
l 7 Q And what is the basis for that opinion, sir? ,
8 A The basis for that opinion is that, in my opinion, 9 Mr. Puckett still did not have full control of code t,
10 requirements and interpretations of the ccde.
11 (Discussion off the record.) ,
h 12 BY MR. MILLER:
iI i
/ 13 Q Mr. Goedecke, when did you leave the Zimmer site
! (
- K4 after the job was terminated?
e 15 A About the end of January of 1984. !
16 Q Was Mr. Puckett still employed at that point in
) 17 time?
18 A No, sir.
19 Q He had been let go sometime before then?
20 A I believe so. I believe he left about a week or two I left in the end of January but I came back. I 21 before I did.
l 22 only went to Oakland for a week to review some corporate i
3 I
I
. _ . - . _ . . _ . ~ . . _ , - . - - ..,___.._y. _ _ - . . _ _ . . , . - . _ _ . . _ _ _ _ . _ _ _ _ _ . . _ . _ . , , . . , _ _ , . . . , . - _ . , _ _ _ _ _ . . _ , _ .
106 1 documents.
2
( Q After Mr. Puckett was let go after the Zimmer job 3 ended, did you see him again? -
f 4 A I don't believe so, no.
6 5 Q Did there come a time after Mr. Puckett had -- well, 6 did you know that he had obtained a job with L.K. Comstock at 7 Braidwood? -
- a A Yes, he told me that.
9 Q When did he tell you?
i 10 A It must have been his first week or second week .
11 there because he called me at headquarters.
12 Q When you say headquarters --
i 13 A NPS.
14 Q Can you tell me what you said to Mr. Puckett and 4
15 what he said to you in this first telephone call? -
- - 16 A Just that he had found a job, because I was trying 17 to place Mr. Puckett with some companies. That is, I was la really trying to help him get employment somewhere, on a 19 personal level. That is just my nature. If somebody needs a j
20 job, I try to help them out.
21 Q What types of positions had you attempted to get 22 Mr. Puckett a job?
t =
l
107 1 A In welding. Welding engineering.
,' ( 2 Q Do you recall -- did he leave a resume with you?
'3 3 A Yes, he did. He sent me a resume. ,
4 Q .And to what organizations did you show the resumet 5 do you remember?,
6 A I submitted his resume to General Electric, my 7 former employer. -
a Q Anybody else?
2 9 A I don't think so. I think that's it.
10 Q Do you now what General Electric's response was?
11 A well, at that particular time they didn't need .
12 additional help.
( 13 Q Did they ask you for your evaluation of u
14 Mr. Puckett's capability? ,
j 15 A I sent a cover letter ~with his resume to the 16 district director of General Electric.
17 Q I don't suppose you have a copy of that letter with is you by any chance, do you?
l 19 A No, I certainly do not.
4 20 Q All right. So, returning to this first telephone 21 call, he told you he had a job. Anything else?
22 A The first time, no. It was just very casual
. 4 f
] .
l
108
, 1 conversation.
( -
- 2 Q How soon after the first telephone call did you have 3 your second telephone conversation with Mr. Puckett? -
4 A Now, the timing is not crucial, obviously. I can't 5 answer that question to say how soon it was. I would say 6 approximately two weeks later.
'l 7 Q And can you relate the substance of that second ,
8 conversation?
9 A The second conversation did deal with a code interpretation, and by code interpretation, I mean strictly I 10 11 and from here on fo/ t to be strictly dealing with the AWS '
D1.1 code, with no edition or addenda being menticned.
, 12 I r
13 dealt with a code question. Which particular one, there were
(%
14 several codes, and which particular one came first, second or 15 third, I don't recall.
16 Q Maybe the way to get at this is how many telephone 17 calls did you and Mr. Puckett have while he was employed at 18 the Braidwood site?
19 A I would approximate that question to four or five.
20 Q And that includes the first phone call, which was 21 just a casual conversation to tell you he had a job?
22 A well, it could have been five or six then, yes. In
%e a e
109 1 general I would say around five, give or take.
2 Q Now long did these telephone calls last? I mean
[
i 3 were they short? ,
D 4 A No, some of them were quite extensive. Some of
's *l
. 5 these phone calls lasted half an hour. By the time I got my l 6 copy of the code out of my closet and I went to the right i x !
g 7 section that we discussed and gave my interpretation, some of i
a them lasted half an hour. .
l 9 Q Without necessarily having them in the right order,
. 10 can you tell us the subject matter of each of the telephone -
l 11 calls in which the code was discussed?
12 A Yes. Qualification requirements of welding I
( 13 procedures per AWS was the general topic, and sometimes welder !
(
14 qualifications did come in because of qualification of 15 procedures. Obviously, it goes hand in hand sometimes. One 16 topic was -- and there was one general that had nothing to do 17 whatever with qualifications. One general question was is AWS 18 D1.1 applicable to materials greater, equal to or greater than !
19 one-eighth inch? There was one question. My response was !
20 yes, based on the 1983 edition of the code, which, for 21 clarification, I strictly deal with the latest edition, and 22 when someone calls me, whether it is ASME, AWS or ANSI, I !
p O
e
j 110 i j 1 always refer to the latest edition of the code at the time k 2 that the conversation takes place. That was one.
1.
i 3 Another one I recall is materials not listed as
! 't i
I ' 4 prequalified, do these materials require qualification under
- 5 AWS DJ,.17 Again my response was yes, these materials do b
6 require qualification.
]
- I
- l. 7 Another item he called me about was does stainless j
8 steel fall under this particular qualification requirement, l
9 and I said yes, it certainly does. It is not listed -- the l 10 AWS code does not address itself to stainless steel materials, j i f 11 and therefore it requires qualification. .
i r , 12 Another item that he called me about was the 13 position of qualification. Does a 5G position, for instance,
{
14 qualify as all positions, and the answer was no, it does not.
l 15 Q Anything else that you can recall?
1
, 16 A Well, there were some specific materials that were i
) 17 mentioned under the materials not listed, such as A446, the l
p 18 unistrut materials, galvanized materials, stainless steel l
i 19 materials, like I mentioned earlier. To the best of my I
i 1
20 recollection, no, that is about the extent of the phone calls.
j 21 Well, yes, there was another phone call that dealt 22 with a large amount of procedural problems and welder i j .
j .
i l
i
.I e
.-. , . , , . - , - , _ _ , , , . . , , . , , , , . . , - . , , _ , - - - , - . _ . , _ , , - , , , , - - , - , . _ .,,-,,_,.-._,,n,,.._.n,.,,,.n._,,_.
111 1 qualification problems, similar to what we had at Zimmer.
l ,
2 obviously, I can't give an answer to that because without
. 3
- looking at the problems, I can't make a disposition of how. !
) 4 serious a problem is.
-)
5 Q bLatmebackuptowhatyoucharacterised,Ithink, 4
- 6 as a general question as to whether or not AWS D1.1 is i
., 7 applicable to materials equal to or greater than one-eighth of
. 3 .
I 8 an inch. I think you said that you responded that yes,. it l
2 I
9 was applicable for equal to or greater.
l' 1
10 A+ Yes. Anything less, obviously not.
- 11 Q All right. In other words, for materials of less 12 than an eighth of an inch in thickness, AWS D1.1 code is not '
( 13 applicable, is that correct?
2
( 14 A If you strictly go by code, yes. This code is not 15 intended ~for materials less than one-eighth of an inch 16 thickness.
17 Q Forgive me. My notes are incomplete. But when you 1
l 18 answered this question in one of your telephone conversations 19 with Mr. Puckett, what version of the AWS Dl.1 code were you
, 20 referring to?
i 21 A As I mentioned earlier, I always relate to the
- 22 latest edition of the code, and at that particular time, the i
l l
l l
l 1 - . - - - . . - - . - - - . _ - _ _ - . - - - _ - . . - - _ _ _ - - _ - - . . . .
112 I
)
- 1 1985 edition was not out, and the only one.that I had in my
( 2 possession was 1983.
, l8 3 Q What was the code that was applicable to materials
,f 4 less than one-eighth inch thickness under the 1983 code or ,
3 5 codes?
4 6 A AWS D1.3.
j 7 Q When Mr. Puckett called you on this issue, did he
! ~l
! 8 identify which edition of the code he was asking about? '
i, 9 A No. No, sir. -
[ 10 Q Do you know, Mr'. Goedecke, when the AWS D1.3 code ,
11 was first published?
., 12 A I believe it was about 1973 or 1974.
-s
! 13 Q 1.37 5 (
il .14 A Yes. I am not positive about that date. For some 15 reason, '76 also sticks in my mind. But like I said, I'm not
! 16 positive about those dates.
t 17 Q Do you know whether the AWS D1.1 code for 1975 is i,
18 applicable to materials less than one-eighth of an inch in 19 thickness?
20 A could be. I'm not saying it is, but yes, it could be 21 applied. The 1975 edition does not address the one-eighth i
j 22 inch thickness limitation by paragraph.
l 4 # ,
e r .
i 1
I l
_ . _ . _ . _ - _ _ _ _ _ . _ _ _ _ . . _ . _ . __ _ . _ -_ _ . . _ ~ . . . - . . . _ . - ._. -. . _.. __ _ .. ._ _.__..___
113 1 Q But in the '83 edition that you referred to in your
(- 2 telephone cali with Mr. Puckett, there is a specific -
3 reference?
8 4 A -That's correct.
i 5 Q Did you tell Mr. Puckett in this telephone j 6 conversation that you were looking at the 1983 code? .
] 7 A Yes, I did tell him that the only reference that I 1
! 8 have right now is the '83 edition of the code, and -- I don't I'
9 know if I made that statement before, and I want to again
! i 10 clarify it for the record. When I answer a code question, I *
- 'I -
11 answer a question to the latest edition and addenda at the ,
! 12 time the question is raised. That is typical for any code i
l
( 13 committee member unless you, the questioner, identify my
' 76, '78 or '80 edition of the code.
14 ll question is to the 1975, l
15 Q And in this question to you, did Mr. Puckett
!, 16 identify the specific edition of the code?
- i 1
17 A No, he did not.
18 -
Q Now, from the tone of your responses, I take it you 19 get questions -- you didn't gat questions just from i
20 Mr. Puckett, but that you get questions fairly, well,
- 21 regularly.
22 A From all over the country and sometimes from all -
l
! (
l
..-------,-,---,varn,ww,--,n a----nv---.m.----.-----, w,,r, n,-,,-,-r, . , - , . ,vnr.,---,n,v,, , , - - . ,,w,. - - . - . , ,- - - - , - , , ,- - , , . - . - + , ,-----,,------r----,.,
. . 114 l
1 over the world, yes.
(g 2 Q And these are addressed to you in your capacity as a l
~
h 3 member of the code committees?
4 A of the AsME code committee, that's correct.
i 5 Q Did you, since you have taken your position at NPS, I
6 get any questions besides those from Mr. Puckett that dealt l
7 with the AWS code? .
a A Yes, I did. It's a pretty regular thing.
,j 9 Q I think another topic that you said you discussed i .
1 t
10 with Mr. Puckett involved whether materials that are not -
- j. 11 listed as prequalified materials require qualification. ,
I .
U 12 A That's correct. . ;
I 13 Q Under the AWS c* e, are there certain materials Ad#
t 14 which are prequalified?
1 l' 15 A Yes, there are. There are quite a few, as a matter i
l- 16 of fact.
17 ,
Q And is there, to your recollection, a specific code 18 provision that provides for the prequalification of certain j 19 types of materials?
- 20 A Would you repeat that?
21 A I said is there, to your recollection, in the AWS I
22 D1.1 code a specific provision that provides for the 4
1 l ..
i
- s. ,
185 !
( 1 prequalification of certain types of materials? l e
2 A Okay.
]
- (A -
If I understand your question correctly, yes, !
l9 3 the code identifies materials in a prequalified status as .
iI
, 4 materials that have been proven to be readily weldable with a
, i 1 6.s. . : ..,6
' 5 certain weld--in process with a given filler metal, and that is b
} /'
I
! 6 basically what the code was written for, to eliminate
- -) 7 redundant qualifications. -
, j J
j 8 0 When Mr. Puckett asked his question with respect to '
whether or not materials that are not prequalified, as to 9 -
i' I
10 whether they required qualification, did he identify for you ,
!I 11 which materials he was discussing? '
l ,
! 12 A Just the one base mate. rial, and that was == at that t
- ., 13 particular time he called : unistrut, which is an A444 >
4' p
14 material, general, or it's also referred to as 71000.
15 Q And you and he both knew that unistrut material is 16 always made of that material, the A4467 i
,I
- i 17 A Well, it's not always made of that, but for l r
18 electrical application, that is the most common material, i 1
l 19 right.
I i
I 20 Q Unistrut, in fact, is a brand name for a type of ;
t
! 21 strut material.
j 22 A That's right.
4 i
I % ,
.t l .
}
! t i
Ils 1 Q And I think another topic of questioning was does :
(
2 stainless steel material require qualification under the AWS R 3 D1.1 code? -
!' 4 A That's correct. !
,6 -
5 Q I take it that there are no stainless steel
- s materials that are prequalified in the code?
i 7 A That's correct. -
a Q The next had to do with the question of whether the '
s 5G position qualifies a welder to weld in all positions; is -
l 10 that accurate? -
1 11 A That's correct, and/or the procedure.
\
l 12 Q And then you also discussed with him the question of i
~
g 13 welder qualification problems, I think you said, comparable to 14 Einmar.
J 15 A Right. . Documentation-type problems.
l*
i Unqualified
]
16 welders. '
17 Q The words " comparable to timmer," was that his 18 description of the situation or is that your understanding of l 19 what the situation is? '
i
! 20 A That was his description. I couldn't have known 1
- 21 that, so it had to be his description.
22 Q After he described the facts to you, did you concur .
i l - .
c<
! . I
)
1 i
117 1 with his opinion that it was, in fact, comparable to 2immer?,
2 A Well*, the description of facts, to the best of my 6
l 3 recollection, was omission of data, band tests. Y4s, it was .
,i .
. 4 pretty we11 the same as we had at timmer, from his 5 description.
6 Q Now, for some of these issues that we have been
! 7 discussing.on the record, he had specific questions that he 8 asked you about the applicability of the AWS D1.1 code and the 9 prequalification of materials and so on. Did you understand 10 that he had reached a decision himself on these issues and was
.l -
11 seeking confirmation? .
I 12 A Yes.
13 Q From you?
(
l- 14 A Yes.
15 Q Did you understand that he had communicated his
, 16 opinion to anyone else before he got the confirmation from 17 you? ,
l 18 A No. I did not get the impression that he had 19 discussed it with someone else and gotten into an argument. I 20 got the impression that he was looking for confirmation of his 21 own opinion and the interpretation of the Code.
22 Q Mr. Goedecke, I am going to show you a document that I .
l I
- _ _ - - -. _ . .. _ _ - .____ __ . .- _ _ _ _ . ~ _ - . - _ . ._
ils
]
1 has previously been marked as Puckett Deposition Exhibit 4. ,
i
( 2 It is an NRC inspection report for the Braidwood site. It is
! ' 3 number 85-09. I would like to have you look at each of the 4
. 4 allegations and tell me whether they were the subject of a l
! 5 telephone conversation that you had with Mr. Puckett in the i .
4 suaner of 1984.
r
- l. 7 -
MR. GUILD: I will just state for the record that if i
a you intend to do that, it is 3 o' clock now and we are 'E l 9 embarking on quite a long process, Mr. Miller. '
l 10 NR. MILLER: Well, I hope that's not the case, but 4
)'
11 there is one way to find out.
I 12 BY MR. MILLERt
/ 13 0 I
I will tell you what. Maybe rather than having you
(
,14 read them into the record, I will simply refer to them by the L j 15 letter and number designation that they have in the inspection 16 report, and if you can recall whether they were the subject of 17 a conversation with Mr. Puckett, I will have some further la questions. If not, we can just go right on.
) 19 I will show you what has been identified as 1 .
l 20 Allegation 2a in that inspection report.
r
! 21 (Witness reviewing document.)
{ 22 A 2.a; yes. You don't want as to respond to the NRC i (
t l
l
119
- 1 -
review?
{
2 Q No. ,My only question is whether or not you ,
J 's 3 discussed it with Mr. Puckett. ,
4 A 2.a; yes. 2.b; yes. 2.c; yes. 2.d, by reference;
't 5 yes. 2.e; no. It starts with allegation two.
a 6 Q There are separate allegations under "e," acre than 7 one.
8 A Allegation two; no.
9 MR. GUILD: How about e.17
! 10 THE WITNESS: No.
11 MR. GUILD: Thank you.
l 12 THE WITNESS E.2, as I said previously; no. F, I e ( 13 said no. It was addressed very generally at one time, but not
(
14 specifically. G; no. Ms yes, in general terms. J; Il no.
15 no. J.1; no. J.27 no. J.31 no. J.4; no. K.11 no. K.2 16 dealt with the general description of welder qualification i
17 records. I would say no to the specific question, I say yes l
l 18 to the general description. 3; no. L; no. M; no. N; no.
19 0; no. P; no. Qt no. Rt no. 5; no. T; no. U; no.
20 How do you want as to respond to item 3 --
21 BY MR. MILLER:
22 Q No. That does not involve Mr. Puckett.
e
120 i
1 When Mr. Puckett discussed the pre-qualification of
( 2 certain materials, did he tell you that the materials he was I i 3 concerned about, was the welding of A446 to A36 material? .
! ) 4 A .No; he did not.
He referred to it as the P441 i,
5 material -- P446.
l 6 Q Which is the unistrut material; correct? s 7 A Right. The unistrut matarial deals with two of the-l 8 items in question, one, the thickness. Unistrut may be less
- 9 than one-eighth inch in thickness. Two, as a pre-qualified l,, 10 material.
1 11 Q Just dealing first with the qualification issue, if .
1
- l 12 Mr. Puckett had told you that his concern was whether or not l (- -
13 welding A446 to A36 material required specific qualifications,
)
- , 14 what would your answer have been? '
] 15 A My answer would have been yes.
16 Q They are not pre-qualified?
I '
l 17 A That's correct. Not "they." One material is not l l 18 pre-qualified. 1
! 19 Q Which material is that? '
i' 20 A The 446. A36 is pre-qualified.
i 1
21 Q Did Mr. Puckett tell you there were qualified i
22 procedures for welding A446 to A500 material?
l -
i t
4 O
l
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1
, 121 1
I 1 A No; he did not.
1 2 Q If Mt.. Puckett had told you there was-a qualified
(
S 3 procedure for welding A446 to A500 material and asked you I: ,
! 4 whether additional procedural qualification was required to j4 .
5 weld A446 to A36 material, what would your response had been?
) .
j 6 A No; no additional qualification would be required.
7 Q That is based on your reading of the AWS code; 4
l 8 correct?
, 9 A That's correct. -
10 The next allegation is ab," about the welder being Q
i.
) 11 qualified in only -- I'm sorry. The procedure being qualified 12 to the SG weld position only, but.the procedure was used to
!, ( 13 weld all positions. When Mr. Puckett brought that concern to 4 ,
(
14 your attention, what was your response to him?
15 A My response was the procedure was not properly l 16 qualified in accordance with the code and that was, by the 4
17 way, his statement also, the way I see it, it is not, what do i 18 you think, and I agreed 100 percent, it is not.
e 19 Q Allegation 2.c deals with a procedure used to make l 20 bi-metallic welds. Can you describe for us the substance of i
l' 21 your conversation with Mr. Puckett on that subject?
\
22 A Well, yes. I guess I keep repeating myself to i
l I
o .
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1 122 I 1 people that I don't particularly care for the term
,f 2 "bi-metallic." I refer to it as " dissimilar." There is no 3 such thing as a bi-metallic weld. '
- p 4 Q When you talk about the joining of carbon steel to 5 stainless steel.
' - 6 A Which are not bi-metallic. They are dissimilar.
N 7 When you say a bi-metallic weld, you are talking about the 8 weld and not the base materials.
. 9 My response was the stainless steel, regardless of 10 the carbon steel side, does not h' ave a pre-qualified status i
) 11 under AWS Dl.1, and therefore requires qualification. ,
I
- l. _
12 Q If the welding of two dissimilar materials was in
-r 13 fact taking place at the Braidwood site by constock, a ,
f, A4 qualified procedure would be required?
15 A That's correct.
16 Q The next allegation, 2.d, talks about the 17 L. K. Comstock weld procedures are filled with errors and 18 inconsistencies. I think you said by reference, you discussed 19 this. Did Mr. Puckett tell you the precise nature of the
- 20 discrepancies he had observed? l i
- l. '
j 21 A No; he did not. He basically again referred to 22 things similar that we had at Zimmer.
f 9
l l
_ __._ .1 _ _ ___ _ __ _ _ __ _____ , _ _ _ , _ . - _ .
. '^L_.~ : : ~_. ~ ^ ^ ^ - .:. . -
~ ~
. - - -- - - - - - - ~
123 1 Q Did Mr. Puckett tell you what his solution to these 4
2 errors and inconsistencies in weld procedures.vas?
'{e 3 A The previous ones we discussed? The general ones?
4 Q When you say that he described these weld procedures '
. 5 as being' comparable to what you had at Zimmer, did he discuss 6 with you at all what action, if any, he planned to take as a 7 result of seeing these errors and inconsistencies?
8 A A stop work order was discussed. Nonkconforming 9 conditions, et cetera, were discussed. I also pointed 10 Mr. Puckett to the architect engineer in a lot of these 11 things.
1 12 Q When you say that you pointed him to the architect ll g 13 engineer, what do you mean?
( 14 A some of the items we were discussing here, the AWS 15 code is what I consider an engineering code. An engineer may 16 use that particular code in whole,.in part, come up with a 17 different design analysis and the engineer may or may not 18 accept the previous qualifications on some of these items.
l 19 Again, I am quoting 1983, which these items are {
20 clearly defined that the engineer has the prerogative. The 1 21 title " engineer" again is defined as the owner's engineer or 22 the owner's agent engineer, which in common terms today would i
e
- 4 1
I l
i
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. . - z. - ' . . . . - . . ...:- - - :. . . . . . . -
2._ .- . . . . . . :.. . . -
4 124 1 be the architect engineer, which would be the owrer's agent,
(
2 obviously, that he may or may not accept previous 3 qualifications. -
4 Jf I have a procedure that is qualified, for 5 instance, to the 5G position problem, if our procedure is 4
6 qu.?lified in SG under ASME and it just happened to be a 7 stainless steel procedure, if the architect engineer takes 8 that PQR from that procedure, puts it with an AWS application, 9 now you would have under AWS, by the engineer's discretion, a lo qualified procedure. That's what I am really trying to 11 explain to him. '
I 12 Q Did you describe that circumstance to Mr. Puckett I 13 when he discussed the issue of the 5G position with you?
.' l 14 A No. What we did discuss was ASME qualifications as 15 a reference. I said, remember we used ASME qualifications to 16 ba 2 up AWS applications. If the architect engineer approves 17 of that, that is okay. In other words, you don't have to 18 qualify all positions if you have an ASME qualified procedure.
19 Q The next allegation which I think you said you did 20 not spt:cifically discuss, is allegation f, Comstock does not 21 have any control of construction materials in terms of heat 22 numbers or other traceability. Even though it wasn't I .
125 1 specifically discussed, did you-have any general discussions i
2 with Mr. Puckett on that issue?
l' 3 A Yes; whether or not heat number. traceability in the ,
' 4 AWS code,is a requirement, and my answer was no. It is.not a 5 requirement. It was then no, it was not a requirement. It is 6 good engineering practice, but it is certainly not a 7 requirement of the code.
8 Q What was the situation at Zimmer? Was there in fact 9 heat number traceability?
10 A On structural steel? I don't believe so. On the 11 electrical side of the house, that is what we are discussing .
12 now; right?
( 13 Q Yes.
14 A No. On the electrical side of the house, I don't 15 believe so.
1 16 Q I think you said you discussed generally the 17 allegation that welder qualification records have 18 inconsistencies which make welder qualifications 19 indeterminate. Did Mr. Puckett describe to you the types of 20 inconsistencies which he had observed in the L.K. comstock 21 welder qualification records? l 22 A No, with the exception of saying similar to what we 4
- 9 a
9
126 l 1
1 had at Zimmer. This indeterminate means it is neither
( 2 rejectable nor acceptable. It is in a gray ar~ea that requires i
^
3 resolution to a problem, but it's not a rejectable' item or an 4 acceptable item. -
5 MR. GUILD: Are you saying " indeterminate?"
6 THE WITNESS: Indeterminate; right.
7 BY MR. MILLER:
8 Q I think in response to an earlier question this 9 morning, I think my notes are correct, you said one can't 10 allow any mistake on the records.
11 A That's correct.
12 Q In your experience, Mr. Goedecke, are there clerical
< 13 errors that do happen?
(
14 A Yes; there are.
15 Q What is the appropriate correction for clerical
- 16 errors and transpositions and other things that make the 17 records .st completely accurate?
18 A Well, there are numerous things, starting off with l 1
19 very light mistakes, typographical errors, instead of saying j 20 E7018, somebody puts in F7018. We all know there is no such 21 thing as F7018. There is only an E7018. It is a 22 typographical error. You leave it or correct it on another 4
O r m
127 1 document.
t
( ,
2 If you have like this one case I glanced at a minute 3 ago, Mr. Puckett stated, it is impossible to perform work on s '
4 face bends on one inch thick material. He is absolutely l l
5 correct. Somebody took data that was incorrect and put it on ;
6 that form. Since it is impossible to do so, if it was one 7 inch thick material, it had to be either for side bands or 8 the material was indeed only three-eights of an inch in 9 thickness.
10 In this case, I'go back to the records. I take a 11 look at the lab records. They had to bend those materials.
j .
12 The lab records say we have bent three-eights inch material, I 13 so obviously the original record was incorrect, because the
(
14 material was only three-eights of an inch thick.
l 15 It is quite possible to reconstruct a document from
- 16 supporting documents. That would have been my action.
17 Q In the two cases you have just given us -- I guess 18 they are a little more than hypothetical. That is the i 19 typographical error, the "E" being typed as an "F" or the type 20 of band test for a specific material.
21 Once you had done this further investigation, would 22 you consider that the records were indeterminate?
9 e
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I 128 ;
1 A No longer; no. Now they would be acceptable.
A ce r ks 2 Indeterminate would be if I say I had bent a hook and face 4 3 bend on one inch thick material and there is no o'her t 4 documentation, even though I know it is impossible to do, 5 there is no other documentation available to support the 6 mistake that was made on the docyment. If there is no other 7 mater,ial, then I would put this.particular item in an .
8 indeterminate category.
9 I would initiate a non-conformance report and then 10 have the engineers disposition it, to make it either
. 11 rejectable or acceptable.- ,
12 Q I would like to ask you about --
- 7 13 MR. MILLER: I would like the Reporter to mark as 14 Goedecke Deposition Exhibit No. 8 for identification, an NRC 15 Inspection Report. The cover letter is dated April 16, 1982.
~ 16 It is Inspection Report 82-02 on the Zimmer facility.
17 (Goedecke Deposition Exhibit No. 8 18 was marked for identification.)
19 BY MR. MILLER:
20 Q Mr. Goedecke, I show you a document that has been 21 marked as Goedecke Deposition Exhibit No. 8 for l
, 22 identification. I ask if you have ever seen that document !
l i
/
I - .
I i
l l
l e
129 1 before.
' . i I 2 A (Perusing document.] Some of the items, I am >
3 familiarv1th;anumberoftheitems. .
4 Q I would like to draw your specific attention to 5 Section two of the Details portion of the report. It has a 6 numbered page six on it. It was prepared by K. D. Ward, 7 reviewed by D. H. Danielson. Numbered paragraph two on that 8 page relates to the closure of an unresolved item, dealing 9 with the presence of a QC inspector in the weld test shop.
10 A That's correct. I remember this one.
11 Q My first question is was there a requirement at the -
12 Zimmer plant that a QC inspector be present 100 percent of the 13 time while welder qualification tests were being. administered?
14 A At the particular time this item was initiated by 15 the N2C, there was no procedural requirement. There was only l 16 a project directive or a project memo that was issued by 17 myself, to assure that the quality assurance engineer or 18 control inspector would be present 100 percent of the time.
4 l
19 Q What caused you to issue that directive at Zimmer?
20 A There were previous allegatione that other people
- 21 then the responsible valder made welds for that particular
! 22 welder. In other words, somebody else was welding for the A
e e
130 I person that was qualified or certified.
( 2 To resolve that issue, I said, we will have no more 3 of this. We will have quality control down there i00' percent ,
4 of the time.
i 5 Q To your knowledge, is there a code requirement that 6 a quality control inspector be present 100 percent of the time 7 during welder qualification tests?
8 A No, sir.
9 Q Did the requirement at Zimmer later become 10 incorporated into a procedure?
, 11 A That's correct, which closed this item. .
12 Q Mr. Goedecke, when was the first time you and I met?
t
+
i 13 A I believe it was approximately the middle part of
(
. ; 14 December; early part of December.
15 Q Where?
16 A In Secaucus, New Jersey; our headquarters.
17 Q Do you recall what we discussed at that time?
4 18 A Not in detail, but basically our discussion centered 19 on what in my opinion were the qualifications of Mr. Puckett 20 and was he qualified to manage or direct a nuclear facility
, 21 solely in welding engineering.
i
- 22 Q Do you recall who else was present at that meeting-i l
l *
( .
131 1 bacidoc ysu cnd 007
, 2 A Yes; the young lady, Elena Kazelis, and another k 3 lady.
4 Q Rebecca Lauer? '
5 A That's correct. Myself; Mr. Behan, Mr. Palladino.
6 Q What is Mr. Behan's position?
7 A Mr. Beh,an is Vice President for NPS.
Is Q Mr. Palladino?
4 9 A Mr. Palladino is an attorney for NPS.
10 Q After that conversation, do you recall when you and 11 I spoke again?
12 A Yes. It was -- I suppose the first time I was '
{ ,
13 contacted was sometime in the middle or latter part of 1.4 January. You and I, no.
( I spoke to a young lady at one time.
15 Q Was it Elena Kazelis?
l i
i
- 16 A No. It was someone who spoke German fluently.
I 17 Q It was the secretary in this office named Heidi 18 Rixecker. By that time, you had taken your leave of abs'ence j 39 from NPS and were back in Germany; correct?
2 20 A That's correct.
, 21 Q She was calling to arrange for your deposition; is 22 that right?
4 0
]
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- , , _ - - . - . - . _ . . . , . , - . . . , _ _ _ _ . , - - _ - _ _ _ _ _ ~ - _ _ _ _ , _ _ _ . , _ , . - - , . _ _ _ _ . . _ _ _ . . - . . . , _ , . - _ _ . . , , . . , _ . . , , . , _ _ . _ - , . . ,
132 1 A That's correct.
2 Q Ultimately you and I sp'oke about thos's arrangements l
, 3 on the telephone on a number of occasions.
~) 4 A That's correct.
)
5 Q When did you arrive in Chicago?
6 A I arrived this last Sunday, the 9th.
4 1
7 Q On Monday, you and I met; correct?
I 8 A That's correct.
9 Q Can you describe for the record what the substance 2, 10 of our conversation was?
11 A The substance of our conversation in general terms ,
f 12 was what my purpose was to be here to begin with, and second, 13 to review some documents that were in your possession, I guess
(
t 14 these documents I'm looking at, to refresh my memory.
15 Q Did we meet again yesterday, Tuesday?
- 16 A Very briefly.
17 Q Again, what was the substance of our discussion?
18 A Basically, back-up support, did you refresh your 19 memory.
20 MR. MILLER': I have no further questions at this 21 time. Let's take a brief recess.
22 (Brief recess.)
e
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133
, 1 EXAMINATION
. 2 BY MR. GUILD:
k 3 Q Mr. Goedecke, we havo not met until today. My name, 4 for the record, is Bob Guild, and I am Counsel for the 5 Intervenors in the Braidwood Licensing proceeding.
6 I am looking at Exhibit 1, which is your resume, and 7 I recall your testimony this morning about your certifications d
8 to ANSI, ASME equivalent N45.2.6, Level III, and I believe you 9 stated that those were to an NPS procedure.
I' 10 A That's correct.-
11 Q And I understood your testimony, your explanation of i .
12 that, to be to the effect that your welding inspector Level j / 13 III certification was to NPS' program, correct?
( ,14 A That's correct.
i '
] 15 Q And that that is distinct from a Level III welding i
16 inspector certification that would be applicable to a specific
.j 17 nuclear construction site, for example, correct?
18 A I'm sorry. You will have to repeat that question.
1 19 Q Sure. Your certification with NPS as a welding 7
20 inspector, I4 vel III, is distinct from the certification of a l
l 21 Level III at a particular nuclear power plant site.
t l 22 A That is correct.
( '
i
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- e 9
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134 1 Q And at a particular site, you would certify to
( 2 whatever levei under the ANSI standard under that particular
-n 3 site's programs and procedures, correct?
- 4 A That's correct.
5 Q All right. !!ow you understand, don't you, that i
6 Mr. Puckett was hired for the position of Level III welding )
l 7 inspector under the Braidwood and Coastock's, the electrical '
l l
8 contractor's, QA programs and procedures, correct?
)
9 A That's correct. That's what I understood.
10 Q And that the position that he held at Braidwood was 11 a Level III position as defined by the Braidwood site QA ,
i 12 procedures, correct?
13 A I didn't understand that, no. To me, if you want to l l (
I
. 14 qualify or if you want to certify on a nuclear project, '
15 besides being specifically certified to the existing program 16 at a specific site, under ANSI N45.2.6, you must, as a 17 minimum, meet the qualification requirements as stipulated 18 prior to taking the additional testing that is specific to a 19 site.
20 Q Yes, but the Level III position at any site is l
21 defined by those sites' own QA program and procedures.
22 A That's correct.
l T
i f .
I i
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_ _ - - = .. .. - . .. - . - . . - ___ __ _ _.
135 1 Q And all I mean to ask is that you understood, didn't 2 you, that Mr.,Puckett was hired for the Level.III position as 3 that position is defined and described by the Braidwood site
- 4 procedures.
5 A iThat's correct, yes.
6 Q Have you reviewed the Braidwood site QA program?
7 A No, sir, I did not. . .
8 Q Have you reviewed the L.K. Comstock electrical -
9 program at the Braidwood site? .
10 A No, sir, I did not.
L 11 Q Have you reviewed the L.K. Comstock procedures for
- i .
- i. 12 quality control inspection at the Braidwood site?
13 A No, sir, I did not.
t 14 Q Have you reviewed the L.K. Comstock procedures as 15 they define the. duties and responsibilities of the Level III
~
16 QC welding inspector at.the Braidwood site?
i 17 A No, sir, I did net.
i 18 Q But those procedures -- and by that, I mean the l
1 l 19 L.K. Comstock Level III procedures -- those are the procedures 20 to which Mr. Puckett was hired and to which he would be i
21 qualified as a Level III, correct?
- 22 A I would agree with that, yes. Procedures and j
i
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5 1
- - , . . ~ . . - . . - . ~ . . . . _ - . - . - . . . _ - - . - . . . - . _ - . . . - . - . . . - - . . . - - . - . . . - - - . . - . . . _ . . . . -
136 1 program.
2 Q And program.
3 A Okay. ,
- 4 Q Do you know whether or not the L.K. Comstock at 5 Braidwood has any -- strike that. ;
6 Do you know whether or not the L.K. Comstock Company 7 -
at Braidwood, at the time of Mr. Puckett's employment, had any i
8 other person who were certified Level III QC inspectors to the !
i i 9 ANSI standard? i l 10 A No, I did not.
! i l 11 Q Do you know whether or not, for example, the Quality'
) -
- . 12 Control Nanager was certified as Level III weld inspector?
l / 13 A No, sir, I did not.
( 14 Q Do you know whether or not -- well, you wouldn't
{ 15 then know if there were any other persons certified to Level 16 III at Comstock.
17 A That's correct.
i l 18 Q Okay. Are there Level III certifications that, in i 4
19 your experience, Mr. Goedecke, are customarily held by persons i i '
! 20 who perform essentially a managerial function or a supervisory 21 function and not a specific quality control inspection 1
i 22 function?
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_ _ . . _ _= -. - .
137 1 A If I've paraphrased your question properly, the
( 2 Level III pos'itions in inspection are strictly -- usually 3 strictly technical in nature, not administrative. ,
! 4 Q So your answer is no?
5 A My answer would then be no, if I updorstood your
- 6 question correctly.
i I-7 Q Well, let me make sure. Maybe I'm not being clear.
1 8 Are there, in your experience, as a matter of
,, 9 practice, Level III certifications held by persons who would 4 , 10 he in the position of Quality control Manager, who hold the 11 position by virtue of their managerial status? .
' 12 A 4
Yes, I'm aware that there are some.
13 Q All right. And in that capacity, is it customary, i 14 under those circumstances, that that Level III certified i
~
15 manager would not actually perform field inspections, for l
16 example, field inspections of welds?
t 17 A I would not say that's customary.
18 Q There are a couple of double negatives and perhaps
{-
- 19 your answer. .
j 20 Would you agree that it would ba customary that a i
- 21 manager certified to Level III would not actually do field
- 22 inspections; would you agree with that?
{
L
( _
l l
1
138 1 A Yes. A manager would not perform field inspections, 2 right. .
3 Q And that that manager perhaps wouldn't actually 4 review disputed Level II inspector judgments? I'm including 5 that as one of the possible duties of a Level III, for 6 example.
7 A Right.
8 Q A manager who might hold a Level III inspection ;
, 9 might not perform that duty, the review of a Level II 10 inspector judgment.
i 11 A Might not, only if there is another Level III, a 12 technical Level III, present at the site. Somebody with a i f I 13 Level III certification has the ultimate judgment.
t Okay.
,14 Q 15 A Because he qualifies Level II's. We have to 16 understand that.
17 Q Right. And you have to have a Level III to do that.
18 A Right.
19 Q All right. Well, for example, at Zimmer in the 20 program -- let's take the program that you found when you came
- 21 to Zimmer.
i 22 Were there persons who held Level III certifications t
e l
l I
l
139 1 in welding inspection who performed essentially supervisory or 2 managerial duties?
- 8 3 (Pause.) .
4 A To the best of my recollection, no.
8 5 Q IR>wasyourebuilttheweldingprogram--andIuse 6 that sort of as a paraphrase of what you've described earlier N
7 'today -- did you employ the custom of having persons certified 8 as Level III's who performed essentially managerial or 9 supervisory functions?
10 A No, not in my department.
11 Q okay. So you didn't follow that custom of having g
12 persons certified Level III's except persons who actually did I
( 13 Level III technical work?
( 14 A Well, let me define the function -- my function at 15 Zimmer again.
- 16 Q Sure.
17 A My department handled engineering types of efforts, 18 not inspection type of efforts. i 19 Q I see. I wasn't thinking properly about your scope 20 of work.
21 Do you know whether or not, then, at Zimmer at the 22 time you came on, there were Level III's who performed l
~
j .
J
. 140 i 1 managerial functions in the welding program at all?
2 A
( Not to my knowledge.
l 3 Q All right. After you came on, whether within your
, 4 area of responsibility or not, did the Zimmer welding program 5 amploy Level III's who held essentially managerial positions?
6 A To clarify your statement, the Zimmer welding 7 engineering program did not. '
8 Q All right.
9 A The Zimmer quality assurance program, which governed 10 as the final inspection agency, yes, they did. They had to 11 have a Level III.
i 12 Q All right. Now focusing on, then, the Zimmer 13 quality assurance program, their organization, did they have
( 14 -- they had a certified Level III?
15 A That's correct.
16 Q okay. Did they have more than one in the welding 17 area, visual inspection of welds?
Visual inspection of welds, there was no Level III 18 A 19 per se. Our Level III was certified SNT TC-1A, which is 20 non-destructive examination, which is a national examination 21 that is conducted for UT, RT, PT, MT, et cetera.
I
! 22 Q Including visual.
t e
141 1 A Including visual, right.
2 Q so you had a single Level III person certified as 3 you just described? -
4 A That's correct, to the best of my knowledge, right.
5 Q Did you have anyone who held a Level III position 6 who performed essentially managerial duties, as opposed to N
7 technical?
8 A Not to my knowledge, no.
9 Q Okay. What other sites, if you know of any, have 10 followed the custom of using Leve'l III's who perform 11 essentially a managerial function? Can you give me examples' 12 of other sites you're familiar with?
~
[ 13 A Yes, I can give you examples of other sites. If you
(
14 vant,ma to name other sites --
15 Q Yes, please.
- 16 A But before I do that, I can tell you right now, I do 17 not know of any Level III's that are strictly managerial. Now 18 I can name you sites, if you still need them.
19 Q All sites that perform code -- well, nuclear sites
- 20 that perform code welding -- have Level III's.
21 A Right. But the question was managerial, and my 22 answer is no. To my knowledge, no other site employs a Level I
( .
4
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__,m - . _ . . . , _ . ___ ,-< ,+-. _ . --_-
142 1 III strictly in a managerial level, because they couldn't 2 afford it.
4 3 Q Okay. So you're not aware of any site that follows 4 that practice.
5 A That's correct.
6 Q All right. Do you know whether or not L.K. Comstock 7 at Braidwood employed a Level III welding inspector at the 8 time Mr. Puckett was employed or was hired?
9 A Not to my knowledge. Not to my knowledge then. I 10 read some of these documents, and I found out, yes, indeed, 11 there was a Level III prior to Mr. Puckett. ,
12 Q All right. What documents are you referring to,
. 13 Mr. Goedecke?
(
14 .A I don't exactly recall which one of these documents.
15 Q Something that Mr. Miller made available to you?
16 A Yeah, I believe that's the Puckett deposition where 17 he said there was a previous gentleman before him that held 18 that position.
19 Q You read Mr. Puckett's deposition?
20 A That's correct.
i 21 Q Okay. So if you knew, it was only through reading 22 Mr. Puckett's deposition?
( .
,w-- n. , - - - - , , - - , -- - , - --- - - ------ - ,,- . , ---+ , , ~
14.3 1 A That's the only way I knew, right.
( 2 Q Mr. Goedecke, take a look at your resume again, if"
\
3 you would, please. Just to be clear, let's look at the second 4 page. The first two positions that appear with the 1 5 underlinings running from the top going down, those are both l 6 with Nuclear Power Services, correct?
7 A That's correct.
8 Q All right. Now the third position, it's underlined i
9 and it's entitled " Welding Manager for a large engineering 10 firm."
11 Which position is that? ,
l 12 A That is the position with Henry J. Kaiser company.
13 Q All right. Including the position that you held at 14 the Zimmer site?
A5 A That's correct. That would be the second paragraph 16 under that heading.
17 Q All right. At the bottom of that same page, the 18 position is described, " Manager, Technical Engineering." And 19 with whom did you hold that position?
20 A Henry J. Kaiser Company.
21 Q All right. And was that before or after your 22 position as Welding Manager?
e l
i
144 1 A After. That was in the final stages of the project.
l l 2 Q All right. That was at Zimmer?
1 .6 3 A That's correct. .
1 4 Q .0kay.
And when did you hold that position?
5 A I really don't recall the exact date, but I would 6 say that it started approximately the middle of 1983.
[ ,
7- Q How did your duties change from that of the Welding 8 Manager? '
- 9 A The duties changed to the fact that I now had 10 responsibility for all engineering disciplines, as stated --
i 11 mechanical, electrical, civil, and the Welding Engineering .
.) 12 Department.
I /
13 Q Okay. That was additional responsibilities over
(
14 your previous position?
I 15 A That's correct.
1 -
16 Q All right. And did you have additional people 17 working for you in the subsequent position, the Manager of 18 Technical Engineering?
19 A That's correct.
l 20 Q All right. How many people did you have working i
21 for you in the latter position?
22 A In the latter position, I would guesstimate -- these I.
h
^
! ( .
i i
- . . - - . - - ~ - - . , . . . ~ - -
. - - - . _ - - - - . . - . . . . _ . - l---- - --- . . - - ~ . - - - - - -
145 1 are all engineers I'm talking about now; we're not talking 2 about the clerical staff, et cetera -- the latter position I 3 would guesstimate about 25 engineers. .
o .
4 Q Okay. And how many additional, if you were counting 5 others, clerical and others?
6 A Clerical and others, including the whole welding f
7 organization at that time, I would say approximately 150. -
8 Q And that included, I think you said, approximately 9 100 clerical people who were doing historical weld -- '
(
j 10 A That's correct.
t i
11 Q And did you hold that position until the project was j
p 12 shut down?
' 13
{' A That's correct.
o
( A4 Q You stated earlier that on more than one occasion, 2
15 Mr. Puckett informed you that he had previously identified 16 problems in the welding program and had communicated those i
i, f
17 problems to management, correct? I 18 A That's what he stated to me on several occasions, 19 right.
- i. 20 Q And that I think to* complete the description, that I
- 21 management, in short, had not responded positively to his ,
I j 22 expression of concerns, correct?
l t
l J
( .
l
_ _ .~. _ __ .
b t
,, 146
- c. 1 A That's correct.
(' 2 Q Did you have any independent information, aside from
, s, 3 Mr. Puckett's statements to you, to that effect that would '
i i
4 either'onfirm c or tend to confirm what he told you or that
! 5 would refute --
6 A No, I do not. Neither way.
- 7 Q All right. Did you ask for or did Mr. Puckett make 8 available any documentation reflecting identification of .,
9 problems or management response to problems in the past? -
10 A Yes, he did.
!! 11 Q All right. And can you identify that documentation?'
4 '. p .
12 A I requested, but there was no documentation
}
e
( 13 available that identified problems.
2 -
14 Q And who did you request that from?
15 A Mr. Puckett.
1 j 16 Q All right.
17 A It happened that when a problem was identified, ha 18 would say, "That's one of them that I had a concern with-l 19 also," or he would bring a problem to me, and he says, 1, "I 20 de think this is a problem. What do you think?"
And I says, f,g g;, ;
! 21 "You're right. We have a problem," okay, and those are the i 22 kinds of things he said, "I brought previously to other people l
1 J
i a
_ _ 1- _ . . . _ . _ _ _ _ _ . . _ _ _ - - _ . _ _ -
. .~ . ..- ... - - - - . .-- - - - - -,. .. _ _ _- _-. _ _ _ _ __ _ _ _ . _ - . .,_
I 147 1 and they were not acted upon."
( 2 Q Okay'. Did he tell you who he brought the problems 3 to the attention to?
- 4 A . Yes. The name, Marshal, who was the Project 5 Manager, was frequently mentioned by Mr. Puckett.
6 Q All right. Did you have any contact with h 7 Nr. Marshal?
8 A No, sir.
- 9 Q Where was Mr. Marshal at the point you came on the 10 job?
) 11 A I really couldn't tell you. I don't know. .
l 12 Q Was he still working there?
I 13 A No.
(
14 Q Had you had any contact with Mr. Marshal when you
- 15 took the position at Zimmer?
i
! 16 A No. Mr. Marshal was replaced by Mr. Mark Albertin 4
17 at the time I got there. -
4 18 Q Had there been a -- well, let me approach it 19 differently.
j 20 At the point when you agreed to come on the job, was i
21 there in process a broader management reorganization going on l 22 at Zimmer?
4
. g G
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4 148 1 A Just prior to me getting there, yes, there was what
{ 2 they considered a major shakeup, starting with the Project i
3 Manager. -
4 Q All right. And did that shakeup extend beyond the 5 welding area?
I 6 A Yes, it did. Not necessarily in removing managerial .
7 positions other than the Project Manager,' but by supplying ,
]
4 additional people to all departments. I 9 Q Okay. So there were changes in other departments as
- 10 well as welding. They may have consisted of the addition of i 11 people instead of their replacement?
12 A That's correct. As a matter of fact, the Acting QA e 13 Manager was replaced at the Zimmer site.
(
14 Q All right.
- 15 A I just remembered that one.
~
j 16 Q And who was the man in the QA position who was 17 replaced?
18 A The name of the person that was replaced?
19 Q Yes, if you recall.
20 A Not right offhand, I don't recall his name.
i 21 Q Do you recall who replaced him?
l 22 A Yes. A gentleman by the name of Walt Hedzik,
( .
k l
149
~
1 H-E-D-2-I-K. -
2 Q How about other persons who were in the position II 3 that I think you described as department managers? Were they 4 now?
5 5 A No.
6 Q How long had they been on the site?
7 A Some of them from the beginning. -
8 Q All right. When you were speaking of the persons '
9 that Mr. Puckett had interaction with after you came on the 10 site when you were describing this in the context of answering
- 11 Mr. Miller's questions regarding Mr. Puckett's evaluation on' 12 tha area of cooperation, do you recall the testimony?
~
( 13 A Uh-huh.
14 Q All right. Those persons that he interacted with, I 15 think you described them as department managers. They had -
- 16 been there for some time?
17 A That's correct.
18 Q All right. Those are persons that Mr. Puckett had 19 previously dealt with in his capacity as Project Welding 20 Engineer?
21 A That's correct, in addition to senior-type-level i 22 engineers.
e
,. .,.,._.,,..-__.._m__. _
150 l l
1 Q All right. Can you give me any of the -- can you l l
{ 2 provide me any names of persons who fall into the category of 3 those from whom you received reports or complaints on the 4 subject of Mr. Puckett's cooperation? -
5 A Yes, I suppose I could. I'm not so sure that that's
, 6 appropriate.
7 Q ,
Well, I'm afraid whether appropriate or not, I'm ,
8 going to ask. Can you identify any of the people who provided
- 9 you with the information that you relied on for the basis of
- 10 your evaluation of Mr. Puckett?
11 A Yes, I can.
12 THE WITNESS: Is that appropriate?
13' MR. MILLER: There's no basis not to answer.
3 A4 THE WITNESS: Well, the reason why I'm asking 15 whether or not it's appropriate, it's not because I am 16 reluctant to give you names. I am reluctant to use someone's 17 .
name who is not present here.
18 BY MR. GUILD:
1 19 Q Well, Mr. Puckett's not present here either, and 20 we've been talking about him all day, Mr. Goedecke. So with 21 all due respect, I will ask you to provide me with the basis 22 for any information that you've previously testified pretty e
. .-I
- . . - . . - =-- .... - - - ------- _ _ _ _ _ _ _ _ _
151 1 freely about regarding Mr. Puckett.
( 2 A Okay.
1 3 Q How about the names of these people, please? ,
4 4 A .,Okay. Norm Vitale.
I 5 Q Can you spell that, please? -
{
't 6 A Yes. V-I-T-A-L-E, I believe.
6 7 Q And what position did Mr. Vitale hold?
8 A Mr. Vitale had the position of Quality Assurance t
9 Engineering Manager.
il
, 10 Q All right.
11 A Mr. Jim sandlin, his previous manager that gave him .
- ) 12 the highest marks.
I 13 Q I'm sorry. He gave him what?
(
) 14 A He gave him high marks on his evaluation.
~
I 15 Q Gave Mr. Puckett?
- 16 A Yes. That's the same gentleman.
17 Mr. T.R. Bietsch.
18 Q Beach?
19 A Bietsch.
20 Q B-E-A-C-H?
21 A B-I-E-T-S-C-H.
22 Q All right. Thank you.
152 l
1 A He was the Project Mechanical Engineer.
2
( I'm trying to think of the Project Mechanical ,
3 Engineering Manager, but I really can't recall it right l 4 offhand.
5 Q A person held that position?
6 A That's correct. x 7 Q. Mechanical Engineering Manager? -
8 A That's correct.
9 Q All right.
10 A Well, I'm sorry. His title really was Mechanical
~
11 Manager. ,
12 Q All right.
I 13 A And I might recall his name at a later date.
(
,14 Q The title helps. That's fine. Any others who 15 provided you the basis for your evaluation of Mr. Puckett on 16 the category of cooperation?
17 A Yes, I had some complaints about Mr. Puckett from 18 Mr. Charlie Stanfield, Construction Manager.
19 Q Okay. ,
l 20 A I've had some complaints from the Project Manager.
21 Q Who was that, now?
22 A Mr. Mark Albertin.
1 l
k .
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153 1 Subsequent to Mr..Vitale, there was another Quality
( 2 Assurance Engineering Manager, and the name eludes me right 3 now also, but he frequently complained about Mr. Pdckett.
! 4 Q And when did that gentleman take that position?
5 After you arrived?
l 6 A After I arrived, yes. And I really can't -- right 7 now, I really can't recall anyone else.
8 Q All right. And these persons provided information 9 that you previously described in response to Mr. Miller, for
10 example, regarding Mr. Puckett?
11 A That's correct. .
t 12 Q Now again, Mr. Vitale apparently was replaced by 4.
/- 13 another gentleman, Mr. Sandlin. What happened to Mr. Sandlin?
(
i 14 A Well, maybe we should strike him, because the 15 gentleman is deceased, and it's not appropriate to use his 1
l 16 name, I don't think.
, 17 Q Well, did he stay on the project at the point when 18 you arrived?
19 A Yes.
20 Q In what capacity?
21 A The same capacity. He was Manager of the Civil 22 Department.
l w g- m ,=w -,-wm esws---u--n-- ,----o-e--------- ----r v,-w-w,----- , - --~w ,-e ye---m---o,--,e.,,,,-,--,-------e -- .,~---u------- w--v-e-ww<,,----r-, 2 m- r v-w=w vr w am----
154 i 1 Q All right. And Mr. Bietsch? He had been there i 2 before you arrived?
~
3 A I believe so. .
4 Q .And Mr. Stanfield?
, 5 A He was there a long time, yes.
6 Q And Mr. Albertin? He was the new Project Manager?
i 7 A But he was there before I arrived also. I think 8 maybe three or four months before.
9 Q Did you have any reason to doubt that Mr. Puckett 10 had requested help -- I think that's the tera you used -- in 11 the past, more staff, for example? *
,- 12 A I have no reason to doubt that at all.
l.
13 Q It was apparent to you from what you said that he 7
. 14 needed more staff, correct?
i 15 A That's correct.
16 Q And I think ultimately you said that the Welding 17 Department, after you restructured it, consisted of 150 18 people? '
19 A Not in the engineering capacity, but in the overall '
20 department, yes, approximately 150 people.
i 21 Q And how many of the overall department at the time 22 that you came to the site and Mr. Puckett had been in charge?
l l
l
155 1 A Like I said, about three.
2 Q Three.
3 A Which was two assistants and one clerical' person.
- , 4 Q You mentioned that a couple of those persons, you
"' 5 understood, were related to Mr. Puckett.
6 Can you identify those people, please?
. 7 A I'm having a hard time with those names. John 8 Farris. That's F-A-R-R-I-S. I can't think of the other 9 person's name right now.
10 Q And who was the gentleman that you terminated or was 11 terminated that you referrad to?
12 A The same gentleman.
s 13 Q Mr. Farris?
14 A Right.
15 Q And what was the basis for his termination?
16 A Excessive absenteeism.
17 Q Do you know what relation he is to Mr. Puckett?,
18 A I believe he is the son-in-law.
19 Q Had you previously known Mr. Flaherty prior to 20 Mr. Flaherty coming to Zimmer?
21 A Yes, I had.
22 Q In what capacity had you known Mr. Flaherty?
I I
1 1
l l
\_ _.
156 1 A Mr. Flaherty was the Project Welding Engineer for oneofthesdbcontractors;namely,Wismer&Becker,whohad k 2
)
3 the mechanical contract at the Fermi Nuclear Project. .
I 4 Q ;And was he there during your tenure at Fermi?
i 5 A Yes, sir. He did not work for me, okay.
., 6 Q Yes. At Fermi. -
7 A That's correct.
8 Q Had you known Mr. Sandlin prior to coming to Zimmer?
9 A No, sir.
10 Q Let me direct your attention to the Zimmer 11 inspection report that you discussed with Mr. Miller, and that ,
i h 12 is 82-10.
I4 13 Let me get you to look, if you would, Mr. Goedecke,
- 14 to the appendix, Notice of Violation.
1 15 A Okay.
16 Q I direct your attention to Item 1.b.
17 A Okay.
18 '
Q And the supporting detail in the report, which l 19 appears at page 30.
1 20 Now the statement at page 30, bottom of the second !
21 full paragraph, reads as follows: "The new records were not i
22 signed by the record originator or equivalent." Do you see D
( .
T
. 157 1 that, page 307 It's the second full paragraph, the next one 2 down.
(
(Witness reviewing document.]
3 ,-
p 4 A Yes. .
5 Q Now was there a Zimmer procedure that required that 6 these records be signed by the originator or equivalent?
l 7 A I believe that the procedure required any changes be j* .
l 8 initialed and dated by the originator.
j- 9 Q That's changes to the original documant?
, 10 A That's correct.
i 11 Q These were not changes to the original document. ,
g 12 These were retypings of the rewritten document. -
13 A R'ight. Well, in that case, I know of no requirement
(
14 that required the originator to sign these documents.
15 Q Were these changes -- or let me put it this way.
{
l 16 Were the retyped versions of the documents otherwise 17 authenticated? By " authenticated," I mean verified in any
. 18 fashion to be complete and accurate.
19 A That's correct. By the current Level III, namely a 20 gentleman by the name of K.K. Sheraton.
i
- 21 Q Okay. And he's the Quality Assurance Engineer that 22 you referred to who worked with Mr. Puckett on this task?
3 T I
4 l I
I l
i
1 158 1 A That's correct. .
I 2 Q All right. Now were they performing this task under 8
3 your direction? ,
4 A Under my initiation. I cannot direct quality I
e 5 assurance engineers.
6 Q All right. What was the purpose of this task? Why did you direct them to do it or you initiate the ta'k?
7 s , (
Y 8 A To achieve a clear and precise document that l l
- 9 accurately reflected all the pertinent data that should have !
- I 10 been on the record to begin with, !
11 Q Why was it necessary to retype the documents? !
, 12 A Because we came out with a new format, and all of ll
( 13 these records required an additional review by our Records l l
14 Review Group to ease their or make their job more expedient, i
15 and we came up with this clear, precise format that was
. f 16 readily readable.
17 It was a nicety. It was a beautification of a 18 document. It was not a change of pertinent data.
19 Q All right. Well, I guess what I'm unclear about,
. 20 remain unclear about, is why there were -- I understood there i l
21 to be three steps involved in the process that you described !
l 22 in response to Mr. Miller's question.
l f .
9
j 159 1 The first was the compilation of the original welder
- 2 qualification. record.
3 A That's correct. .
4 Q At the time the welder actually qualified.
5 A That's correct.
6 Q All right. The second was the compilation of a 7 handwritten document in the new format that extracted -
i 8 information that was in the welder qualification record 9 packet, correct? ,
1 10 A No. The second~was the handwritten format that came .
l 5
. 11 out of the weld test facility, which obviously it's a very 12 filthy facility usually. It's very dirty. The people that
- 13 work down there have dirty hands, et cetera.
f'; ,14 Q All right.
1 15 A Their handwriting may not be as nice as someone 16 else's. So my direction to them was, "You will handwrite it.
17 You bring it up, and we'll type it up in the office."
18 Q All right. Now the handwritten version, was that 19 prepared contemporaneous with the welder's qualification?
20 A That's correct.
21 Q All right. So it was a document that existed -- it 22
) was a historical document that was written at the time the 9
i
.___,__,______,___._._.__s __. . _ _ , . . _ _ . _ _ . . . _ . _ _ .
160 I welder qualified?
2 A Historical, yes, some of them were historical. Sose
! 3 of them were very current. The first task was welders who
- *4 were presently qualified. You take those documents, bring 5 them up to the office, and they would then be put on a
- . 6 typewriter, a clear and precise sheet, and put in plastic so 7* they won'$ get dirty, so we had a nice, neat, clean package.
j s Q Maybe I just misunderstood your earlier description.
j 9 There are two steps, then. One was to take the 10 existing qualification records which included handwritings and j 11 documents that were dirty because they were done in the field, 12 in the shop.
1 I
i s' 13 A That's correct.
,14 Q All right. And to retype those records, and that's i
l 15 the second step, the retyping in the format that was clearer.
16 A That's correct.
i 17 Q And it was Mr. Puckett and the Quality Assurance ,
18 Engineer who were responsible under your initiation for i i
- 19 performing that task?
20 A That task was actually the second task. We had two 21 tasks. One, to verify existing welders on the project. ,
i 22 Q Yes.
i ( .
i
- l
! l I
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161 l l
1 A okay. Take those records, whether they were <
2 qualifying or,not, take those records and put.them in a i 3 format. Task Two was to take the historical documents from
)! 4 either existing welders or welders that had long been 5 terminated or whatever and put them into the same format, so i
! 6 that when one reviews a record, he always r'aviews the same j 7 record -- I mean, the same format.
l .
j 8 Q All right. Now directing your attention to the
- 9 violation in question, 1.b, 32 welders in question here, which i 10 class did they fall in? '
[3 11 A To the best of my recollection, these welders fell l 12 into the current qualified welders category.
! ( 13 Q All right. So what tasks were performed by l I
] ,
14 Mr. Puckett and the other gentlemen that were associated with i
15 the 32 welders that were the subject of this violation?
i 16 A Their task was to take the handwritten document and
) 17 put it on -- you know, have it typed, and then review the j 18 typed sheet versus the handwritten sheet to make sure all the i
i 19 data was there and correct, and if any modifications or l
20 changes or corrections had to be made, they could do it then l 21 and there via the backup documentation.
l 22 That was the main reason for one of the quality i ( .
I -
1
. ~ _ - _ _ _ - _ - . _ . _ - - . . _ _ _ - _ - -
162 1 assurance engineers to be there, to assure that 0,91 ding
( 2 Engineering d'id not pull any dirty punches.
And did Welding Engineering pull any dirty punches?
3 Q ,
. 4 A . Absolutely not.
5 Q And by that, that was Mr. Puckett?
6 A That's correct.
7 Q And that's the purpose of having the quality 8 assurance engineer there, to verify the --
1l 9 A To give credibility to what we were doing.
l
- i. 10 Q All right, fine. Was there backup evidence to 11 support the changes that were made? .
l 12 A Absolutely.
13 Q And that evidence was retained in the quality
(
14 records for the site?
j' 15 A That's correct.
1 l 16 Q These retyped versions were kept -- the original l
i 17 records were kept along with the retyped versions?
j 18 A That's correct. And the retyped version on the 19 bottom stated that the above changes or the above identifies ,
l 20 the same records contained in this package. So there was a
- 21 statement always made, and this particular one here, besides '
22 being -- some of these problems, besides not being signed by j
e 9
e 4
_.4 __,___.-_._--__.,_---,,.----yw-__ . ,___,_-,e,.-_. , , - . . , . , . _ . - - , . , - .--.,,.--,.,,,,,m.-..- . . - - - . . , . . , _ --._-___..__,~-,_.--+e,---_.-m -
j 163 1 the originator, were that these did not identify that 2 statement. Somehow they slipped through the cracks.
(
3 Q All right. Was it apparent to anyone looking at I.
g 4 these packets that this was a retyping of information that was II 5 in the original document that appeared --
6 A Yes, it was quite apparent.
- . 7 Q Was it apparent to the NRC inspector who reviewed ,
1b this matter?
S i i
}.' 9 A Yes.
1I l'
10 Q Did you bring it to the NRC inspector's attention?
l
) 11 A Yes.
i
! 12 Q If there was an omission of the statement that --
l'.
!:l 5
/
13 the pro forma statement that this was a retyping of the
(
i-A4 original, or words to that effect, was that simply a clerical jl i
15 error?
- f j 16 A Yeah, I would say so. The secretaries or the clerk i
j 17 typists simply forgot to put it on there, and it slipped by l
i 18 somehow. The fact that it was written up for clarification, +
i 19 the fact that it was written up is because that statement was
- 20 missing. Otherwise, I do not believe the question of the
- 21 originator signing this document would have ever come up. It ;
22 appeared, because it wasn't signed by the originator, that l
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i 4
164 1 somebody had changed data or somebody had -- the accusation 2 was falsification. That accusation in no way, shape, or form,
. (
-8 3 as it was proven later, was true. This item was resolved, 4 Q But that was apparent to anybody that looked at the -
y i 5 packet of documents, wasn't it?
4 . 1 6 A I would certainly say so. Obviously it wasn't 1 7 apparent to the NRC inspector, because he wrote it up.
i 8 Q Well, did the originator sign any of these records 9 that were retyped? '
1 10 A I believe he did some, while he was still there.
}
, 11 Q Was that only coincidental, if he happened to be 12 there?
i} -
. 13 A If he happened to be there. See, the gentleman
,14 resigned and went to Korea, so it was impossible for us to 1
15 have him sign the records again. Therefore, K.K. Sheraton, 16 who was also a Level III, who was a Level III at this time 17 with the same authority, signed these records.
18 Q What help did you provide Mr. Puckett in performing 19 his duties at the point where this item was identified, if 20 any?
21 A I supplied Mr. Puckett with secretarial help for the 22 typing, also clerical staff for the copying of the information i
e s
+
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. - - - . _ - - w,, - - . - _ , _ , - - , - , _ . - - , , - _ , _ -- --
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_. 2 .-u____-..m.- , -mm a a m2 - , ,, .g, d
165 1 that was retained in Welding. The original was sent to the 2 vault, a copy there of the completed package, because 3 sometimes documents get lost in transit. To make copies of l 4 these documents. I supplied Mr. Puckett with John Flaherty, 5 who reviewed these documents. Again, after it was all done, 6 he reviewed, as a minimum, a large sample, and otherwise there 7 was no -- in my opinion, there was no additional help a required, for the simple reason it was just transfer of data, 9 you know.
10 Q Let me ask you this: Here is Mr. Puckett, and I 11 think from your testimony I understand that his primary .
i 12 strength was that he had long experience at a welder. He had 13 quite a bit of technical experience as a welder, correct?
j i
,14 A He also had apparently quite a bit of experience in f 15 welding inspection, physical welding inspection.
~
16 Q Okay. So you've got a gentleman who is experienced 17 as a welder and as a welding inspector. Why on earth was it l 18 appropriate to assign him the rather monial task of extracting
! 19 data out of a file and typing up foras? '
20 A Well, he did not type up the forms. Somebody else l
i 21 typed up the forms.
- 22 As I mentioned earlier, we had numerous fire drills i
l <
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-n,e---- , - , - - - - - --------n- - - - - ~ , . - - - - - - , - , - - , , - - , - - - - - - , - , - , - , . . , - - - - - - - - . , - - - - - - -
,-----,.-,-,,----,n, ,-,-,-n---a.-,,----n--,
. 166 1 1 that we had to do. The inspections in the field, at that 2 particular timeframe, weren't as great, the amount of work l 3 wasn't as great to assign somebody full time. ,
.i i 4 This was an immediate need. It had to be done.
] 5 Mr. Flaha'rty reviewed some packages; I reviewed some 6 packages. It was not just a Worley Puckett job. Everybody in 7 the Welding Department jumped in, because these things had to l 8 get done, and they had to be resolved as soon as possible.
! 9 Q so it wasn't just Mr. Puckett and -- I forget the
- 10 gentleman's name -- the QA engineer that were doing the review 1 11 of these records?
12 A That's correct. Ultimately they lined up with them, t
[ 13 because somebody had to correlate all the information.
14 somebody had to have control and put down on paper, "Puckett l
t j, 15 reviewed Walder so-and-So," you know, acceptable, rejectable, j
16 indeterminate, whatever.
17 I don't want it to be understood that this was a
! 18 clerical task.
l 19 Q Well, did you consider this an appropriate task to j 20 give to a man who was an experienced welder and weld 21 inspector?
j 22 A At that particular time, yes, because we needed i ,
i
( .
I i
i
--y+- - ,.se-n--w--w ee -,y- .,-----------ww---w-,-.---.mwc---, w.,-s-,--y,_,--m--vw,-,---,--w-w---w -----,vw--
167 1 these things done.
2 Q All right. At that time, the time of the violation 3 involving Item 1.b in Inspection Report 82-10, were you p 4 responsible for welding document procedures?
5 A Yes.
6 Q All right.
7 A What we called administrative procedures.
~
8 Q All right. And so the adequacy of procedures for
)
9 the maintenance of the welder qualification data was within 10 your area of responsibility?
11 A That's correct.
f -
a 12 Q Also in the same inspection report, Item 1.a, this
! / 13 has to do with a coupon thickness, documentation o.f the coupon
(
I
, ,14 thickness, Mr. Goedecke.
15 A Yes.
i 16 Q Do you know whether there was any objective evidence 17 of the actual coupon thickness involved in the welder 18 qualification records for Walder KGJ, the subject of that 19 violation?
, 20 (W'tness reviewing document.)
21 A I bel eve there was objective evidence.
22 Q Was there an X-ray readout sheet reflecting the e
i
168 1 _ actual thickness of the coupon?
( 2 A Sinc's this was a pipe qualification, yes, I would 3 say there was a reader sheet. '
4 Q And would the reader sheet show whether or not it 5 was a five-inch Schedule 160 or a six-inch Schedule 40?
I 6 A That's correct. It would show that, because when 4 , .
7 you take an X-ray you have to shim for the appropriate 8 thickness.
i - ,
9 Q Shim? S-N-I-M?
10 A Yeah. If you don't do that, you don't get a correct
, 11 X-ray. Prior to X-raying a coupon, the RT people would put .
12 down the thickness before they shoot it i 13 Q Right.
(
,14 A So there was objective evidence of what the coupon 15 was. Right now, I don't recollect whether it was indeed an H
~ 16 coupon dated July 9, 1982. If that indeed was the date that 17 the test took place, then I,would assume that it was an H
!, 18 coupon at that particular time.
! 19 Q Is that the thicker or the thinner?
20 A That is the thicker. H standing for " heavy wall."
21 Q And wasn't it, in fact, the practice to qualify 22 welders to the heavy wall, so that they would have I
t
( .
,-.-,.,n~,--,-.--an ,.,--,.,,a-- v--- ,- , , , - - , . - , - , - , _ _ , , - ,------,.--_,-,,n,rw_,,,,-,----,-,m-,m--g,,-e, - - - - - , - - - , y en -
f 169 l 1 qualification up to that thickness?
( 2 'A Unlimited, yes. .
3 Q Unlimited, as opposed to using the thinner wall.
! 4 A That's correct, which would limit his 5 qualifications, right.
6 Q Do you know whether or,not the objective evidence in l i . .
l 7 this instance, say the X-ray readout sheet, was made available 8 to the NRC inspector?
'! 9 A Yes. Everything was made available to the NRC
, 10 inspector.
11 Q All right. Now what was deficient, if anything, ,
j 12 Mr. Goedecke, about the mL.tner in which the line-through or 13 change was made to this qualification record?
14 A Well, ANSI N45.2.9 says that any change to a 15 document must be performed by a single line correction, 16 initialed and dated, and if I recall this particular -- as it 17 says up here, "Has been changed by line-through to indicate I
18 the weld had been qualified" -- the change had not been made 19 in accordance with ANSI N45.2.9, which indicates to me that 20 maybe it wasn't initialed and dated. I don't remember exactly 21 what took place here.
22 This was not unique to this one situation, by the i .
1
~~, - - , , . - . - - - - - - . . . . - - _ - - - , - , - _ . . - _ , _ - , _ . _ _ _ . . , - - - . . . . . - - _ . - - _ - - _ - _ _ -
j 170 j 1 way. It was numerous. And again, we have to understand that 2 documents went out at that particular time and before the old i .
(
3 documents where we only had Mr. Puckett. There's no way 4 possible he could have checked every single document. He had 5 to rely on other people also. There's no way he could have
- 6 done that.
7 So in both of these items here that we discuss in -
t I 8 here, I want to make it clear that, number one, Mr. Puckett 1"
l,' 9 was correct. There was no violation as such. There was, as a Le 10 maximum, a minor incident that overlooked the situation, just
- 11 simply overlooking an item. '
. 12 Q Leaving out the notation that these were simply 1
' i g 13 retypings?
l
( 14 A That's right. And on the above data, I don't 15 remember whether it was a current item or whether it was an 16 i
item that was really a historical item. I really don't recall 17 that.
18 But I do want to point out that this particular 19 incident here that was described was one incident out of many.
! 20 Q The 1.a you're talking about.
21 A Yeah.
1 22 Q But in that instance, your belief is that there was G
} l 4
171
. 1 objective evidence as to the actual thickness of the coupon on
(
2 which the welder qualified?
3 A In my opinion, it was 99.9 percent of the cases, -
4 4 there was objective evidence of what the actual coupon 5 thickness was.
- 6 Q And do I understand correctly that the practice that 7 is reflected by this example, and that's the 1.a item, the j
{
8 line-through of the coupon thickness was to correct an obvious 9 clerical error to reflect the results of that objective 10 evidence that was also available to the reviewer?
11 A That's correct. '
12 Q You were describing Item 2.b, Mr. Goedecke, in 13 response to Mr. Miller. I believe he was probably asking you
- . '14 about 2.a at the time. But this has to do with the a
15 computerized listing of qualified welders.
I 16 I believe I heard you say that you weren't employing 17 that listing because the computer was slow in getting the s
! 18 printout to you.
l 19 A Right. And the printout, the computerized printout, j 20 was always late, okay. We got a computerized printout a week i
) 21 later, but by the time we got that computerized printout to I 22 send welders to the field, the thing was obsolete, because now i
i . .
i
=
I i -
i 172 1 we had changed it again.
( 2 so we came up with an Activa Welders List that
,! 3 accurately reflected on a daily basis who was qualified, .
4 rather than using the computerized aheet.
5 The mistake here that was made, that has nothing to 6 do at all with Mr. Puckett, the mistake that was made here, if 7 anyone's fault, it is my fault because I did not incorporate
- l !
! a this particular item in WCP-2, as I should have. {
9 Q You didn't change the procedure?
l' 10 A I did change the procedure, but by the time it goes "
i i 11 through a cycle of approval, it takes four weeks sometimes. -
- 12 Q All right. At the time the NRC identified this
(
13 item, the procedura change had not been completed?
(
l 14 A I was responsible for initiating these procedures.
15 Q All right. Item 3 on the Notice of Violation, was i
16 Mr. Puckett involved in that matter?
l I
! 17 A I do not believe that had anything to do with us,
! 18 no. This is a quality assurance problem.
i
} 19 Q All right. It has to do with welder qualification, i
20 but it's under the QA area of work, their responsibility?
I l 21 A That's correct.
22
{ Q All right. Item 4 of the Notice of Violation --
e '
I I .
-.-. _..._ _ -. ._,.._-. -.-.,-, - _,_ ,.._ ,,...,_.._._.. _ ._-.- _.__ _ - ,_....,,____-._.,_....--.-,m_
l 173 !
1 A Let me go back to Item 3. Let me clarify this item.
2 Q Okay.
- 3 A That is a quality assurance function that you 4 identify via a document whether it is an NR, some people call
)
5 it NCR, or a CAR, a corrective action report. It is a 6 function of Quality Assurance to initiate these documents if t, ;
7 any deviations are noted.
a Welding Engineering does not -- Welding Engineering i
l 9 dispositions these deviations if they are welder-related, but '
I 10 does not initiate these d'ocuments. ,
l 11 Q All right. And it was the responsibility of the l 12 quality assurance organization in this item.
! ~
), ( 13 A That's correct.
l (
i' 14 .Q Item 4, who is the welding task force chairman who l
i 15 is identified at page 4 under Item 4. "
l 16 A The welding task force chairman identified was a 17 gentleman by the name of -- we called him Woody Wagner, Woody i
j 18 being, I guess, not really his appropriate name, but that's 19 what he went by, and that's how he signs documents.
- 20 Q His last name?
! 21 A Wagner.
22 Q W-A-G-N-E-R?
1 I !
i i
I i
.1-. -y-,_ _ _ . .,_,_...-,m. - , - . , - - - - , . . -- - - -,y -...-,-,-.s- . . , _ . , - - , _ - . - _ - . . _ , , _ . . - - . . - , - - - . , , . . - _ , . _ - - - .
I 174 1 A You got it.
( 2 Q Okay. Was this the task force that you organized to 3 -- -
4 A No. This was a different task force. This task -
5 force dealt with RIFs, as we call them, Requests -- or RFIs, 6 Requests for Information. This document was initiated if 7 there were questions that no one was sure of, whether it was a a violation of something or another. These people wrote right 9 there, their question on a piece of paper, and then it would i 10 he dispositioned by the task force and signed by the task .
11 force chairman.
12 This particular case here, again, it does not i 13 at all involve Mr. Puckett in any way, shape, or form.
t
, ,14 Q What was Mr. Wagner's position, aside from the task 15 force chairman?
16 A Besides that, he was a quality assurance engineer.
I 17 Q All right. Item 4.c, it appears on page 5, has to 18 do with the subject of weld filler metal control in the test 19 shop.
20 (Witness reviewing document.)
21 A That was a procedural violation, yes.
22 Q The procedure called for the control of filler metal
=
l
.i 1
1
175
$' 1 by c,ount?
I t
2 A That's correct.
- 3 Q All right. And who was responsible for the *
'I D 4 ' initiation of that procedural requirement?
5 A I was.-
)
j 6 Q And was that a change to existing procedure? !
f
- l. 7 A The WCP-3 was a new procedure. . ,
j,, 8 Q Well, the control of filler metal by count, was that
~
i
{, 9 a procedure that you implemented?
r' l
, 10 A That's correct. l 11 Q And previously how had filler metal been controlled? "
!t 12 A By weight.-
4 j 13 Q And why did you make that change?
(
I
'14 A Because of the " ifs," what if, and I also made that i
15 change because of some pressure from the NRC to establish 1 16 tighter controls.
j* 17 Q Was the control of filler metal by count instead of I
[ 18 by weight an enhanced control?
i 19 A Yes, very, very stringent, because now you count not
- i l
20 only how much rod goes out, you count how much rod comes in 21 and how many stubs are they.
I l 22 Q stubs reflecting the use of a stick of filler 1
f- ,
1 i ( . l 1
1 i
i l .
176 ,
l 1 material?
g 2 A Yeah, leftovers. Now you have triple checkpoints.
!I i
3 Q All right. Did the NRC require the use of the weld 4 rod count control procedure as a matter of regulatory 5 requirements?
6 A The NRC, in my opinion,Ncannot dictate how to
- 7 control filler metals. However,,if you write a procedure and ,
i a they get to review it, if they think it's inadequa.te, they can 9 then make comments against that procedure.
10 To assure that everybody on the project was fully l
,.. 11 satisfied with the way we do business, I took the most *
]
4 12 stringent approach possible, and that's count.
l s' 13 Q All right. Now the control procedure, did that
!, ,14 apply to AWS welding?
i j 15 A Yes, it applied across the board. There were no
~
l 16 deviations in any way, shape, or form.
Ii 17 Q So it was for ASME Code welding as well as AWS Code L 18 welding?
l -
l 19 A That's right. The title of that procedure was i
c 20 " Control of Filler Metals" or " Weld Filler Metals." It i
j 21 doesn't matter.
22 I am not sure that when this item was written up, i
I , ,- ;
i n \
(
l
- i
177 1 whether or not Mr. Puckett was really responsible for the weld ,
1
( 2 test facilities at that time. I would say no, looking at the
) -
3 date.
' 4 Q He was no longer responsible as of that date?
i 5 ,A That's correct, sir. I don't really --
! 6 Q Do you know who was responsible for the weld test 7 shop as of the date of the violation?
8 A Yes. I believe that a Mr. Charles McCormick was 9 responsible at that particular time, if I read the date 10 correctly. What I'm trying to say is, I don't know why it is i
11 an issue with Mr. Puckett. ,
12 Q I'm not suggesting that it is, i
) i/
~
13 A Okay.
(
14 Q With respect to Item 2.a in this Notice of 15 Violation, that has to do with-the issuance of the duplicate
~
I 16 card.
17 Did I understand correctly that the welder's 18 qualification -- the qualification of the welder who had lost 19 his card was not in doubt?
20 A That's correct.
21 Q It was substantiated by a copy of his qualification i 22 card that was on file?
I
( .
/
9 0
, . - - . ,--.,-,e . . - - - - , - - -,- . - - , - - - , - . - . , . . . . , - - -
,,,-.-n-en-,.m- ,,- ,,- -- - . - , - , , . , , - , . _ . , - - - - , , - - - - - - - - - . - - - - - - . - ,
178 1 A That's correct. We keep a copy not only of the
( 2 qualification card on file. We also keep copies of his
> :) . .
3 welding activities, and that's where that Active Welders List ,
l 4 comes from, okay.
5 Q Was there a procedure in place for issuance of 6 duplicate cards?
7 A *The procedure did not address a person losing his 8 card, to the best of my recollection. The procedure only 9 addressed how do you issue a card and how do you maintain your lo qualifications, and after the 90-day period, you would issue _a P
11 new card, had a welder used a given process during that 90-day '
12 period.
/
13 Q Was there any change to the procedure made as a
.14 result of this item of noncompliance?
15 A No.
16 Q Was there any change of procedura needed?
I 17 A No.
18 Q Exhibit 5 is one of Mr. Puckett's performance
- 19 evaluations, one performed by you, Mr. Goedecke.
20 A Yes. ;
21 Q Under Item 1, " Professional / Technical Skills," you 22 note that Mr. Puckett meets requirements, but in the
179 1 " Comments" section, you state, "Needs more exposure to proper
( 2 code interpretations."
$I 3 How did you employ the term " exposure" there?
I 4 A By " exposure," I meant that he either studies the 5 code or seeks help from others to interpret the code.
6 Q Do you know what training Mr. Puckett had been given 7 by Kaiser or the client.or others at Zimmer in code 8 interpretation?
9 A Prior to my getting there? '
10 Q Yes, prior to your getting there.
11 A I have no knowledge of whether -- I do not believe 12 that he had any for the simple reason that there's no way he f
i i 13 could have taken the time off to do so.
(
14 Q Given his work responsibilities?
15 A And the load, the workload.
~
16 Q All right. Did you review Mr. Puckett's training i 17 record at the time that you came to Zimmer? ,
18 A I didn't have a training record on Mr. Puckett, 19 because there was no training record within the welding 20 organization at that time.
21 Q Okay. So to your knowledge, he had no prior 22 training at the Zimmer site in code interpretation?
I
.,,__m-m -
180 1 A To my knowledge, no.
2
( Q And you provided him some training, as you've -
3 testified in response to Mr. Miller's questions? ,
I 4 A .That's correct. After this evaluation was 5 performed.
6 Q Did you provide Mr. Puckett with any training in the 1
7 AWS Code?
8 A Yes.
9 Q All right. And what was the nature of that 10 training?
11 A The nature of that training was the AWS course that .
12 we mentioned at a later date in welding inspection and quality 13 control, which I believe would be marked on his second
(
,j ,14 evaluation that I performed.
15 Q Yes. I'm looking at Exhibit 7, the evaluation for p 16 the period April '82 to April '83.
17 A That's correct.
18 Q That's what you have reference to?
19 A Yes, sir.
20 Q All right. Now what AWS Code training was provided 21 to Mr. Puckett?
22 A A complete review and exams on AWS Dl.1, and I e
9
181 1 believe at that particular time, it was the '82 edition of the
( 2 code.
3 Q All right. The review consisted of what, the review ,
4 of the AWS Code?
j 5 A The review consisted of the requirements of AWS.
6 The review consisted of the different categories of AWS, the ,
7 responsibilities of these different categories of AWS, code
- 8 interpretations of the code, and all of these were established t
i s 9 by examinations, which -- I believe I've seen an exhibit l
10 somewhere, which I believe Mr. Puckett received a mark of 100
. 11 percent on.
12 Q All right.
13 A So on the exams, he did an excellent job.
I 14 Q All right. Was this a course that you --
- 15 A Taught.
I 16 Q You taught the course?
I 17 -
A Right.
18 Q Was this a course that you developed?
, 19 A No, sir. This was a course that was developed by 20 ASM.
21 Q And who is ASM?
22 A The American Society for Metals and.the American I .
I l
l l . - . . _ .
182 1 Welding Society, AWS. It was a jointly developed course.
( 2 . Q And how long did the course take?
3 A Forty hours.
4 Q A 40-hour course.
5 A That's correct.
6 Q All right. And as a result of taking that course 7 and taking the examination which you've described, did '
8 Mr. Puckett receive any sort of certificate?
9 A That's correct.
10 Q And what certificate was that?
11 A It was a certificate of completion which carried ,
12 five CEUs.
i 13 Q And what is a CEU?
. (
14 A Continuing Education Unit. By the way, which is the ,
15 only recognized unit for professional people outside of a 16 university type of credit.
17 Q All right. Well, help me understand what the 18 significance of five CEUs is. What level of training is that?
19 A You usually issue a CEU for ten contact hours, 20 okay. In this case, we issued five, because there is an 21 additional amount of homework required prior to taking the 22 examination, which the exams were on a daily basis. We went 9
i l
i
! 183 l
l 1 through a chapter, and we give the exam the following morning
~
(
2 or at the end of the session the following night.
.l 4 -
3 Q Who else took this course besides Mr. Puckett?
2 4 A I would say a total of about 260 people. This 5 course was given first, obviously, to the Welding Department,
- 6 because this department, I figured, needed it the most, since 7 they dealt with the code extensively, and then it was extended 8 to anyone on the project that had a desire to learn something, 9 so that everybody spoke per se the same language when they 10 talked about code.
11 Q And ultimately 200 people took the course?
, 12 A Approximately.
. ( 13 Q Mr. Puckett scored a perfect score on that 14 examination, 100 percent?
15 A I'm not sure he scored 100 percent on alluof them.
16 There was fifteen exams and a final. I would say that 17 Mr. Puckett was in the middle to high range of a 90.
18 Q And how did that compare with the population of
- 19 those who took the course? How did Mr. Puckett's score 20 compare?
21 A Above average.
22 Q Far above average or just above average?
. i l
I t
. 184 1 A Above average. Because of the nature of the way i
( 2 conduct training seminars, if I give them an exam basediately 3 after we discuss a chapter, anyone who has any retention of -
l 4 what I said should be able to do -- achieve a fairly high
'l 5 score. It is not usual for some one to achieve a 98, for 6
instance, or to achieve 100 on every exam I give.
7 As I said in the other evaluation, I believe I used 8 the word he had done " exceptionally well."
9 Q All right. Do you know if anyone else scored 100, g 10 for example, on the test that Mr. Puckett scored 100 on.
11 A I don't believe anybody scored a perfect 100.
- 12 Q Except him?
13 A !
(
No, no, no. I mean, the final exam, you take all l 14 the exams previously given. You take the total score, divide 15 it into 15, which gives you the percentage, the final i 16 percentage, okay.
i I
17 Q I see.
I 18 A Mr. Puckett received 100, to the best of my 19 recollection, on numerous exams of the 15. He may have missed 20 one or two questions in some of the exams.
21 Q Well, let me ask you this. On the composite score 22 for the entire course, how many people scored higher than 4
e
185 1 Mr. Puckett?
A
( 2 Not very many. Not very many. Maybe' 10 percent.
I 3 As I pointed out earlier, Mr. Puckett is very quick 4 in retention.
5 Q You spoke of an instance that you identified earlier 6 in your tenure at Zimmer, Mr. Goedecke, in which Mr. Puckett,
- 7 as you stated, specified incorrect time and temperature 8 parameters for heat treatment. Do you know what the basis was ,
9 for Mr. Puckett's specification?
4 i 10 A Yes, not for his specification, but for his His basis was incorrect' 11 judgmental setting of the criteria.
12 interpretation of the code, by choosing the thinner part of 13 the metal that required post-weld heat treatment. You had
(
14 a very heavy component on one side being joined to a thinner 15 component on another side. He_ judged his time or temperature 16 on the thin component, where the code clearly states that time 17 or temperature is determined by the thicker part of the 18 component.
19 Q What portion of the code clearly states that?
20 A ASME, Section 3. If I remember correctly, it is 21 around NB4600.
22 Q Was this liner plate?
)
k .
l l
- 186 1 .A No, sir. It was a stiffener ring on the main steam
( 2 system.
3 Q That was the nature of the additional work that you -
4 had the stop work order applied to? ,
l :, 5 A That's enrrect.
6 Q Other work on the same sort of installation?
7 A That's correct.
8 Q You identified more than one instance where 9 Mr. Puckett N/A'd a requirement for post-weld heat treatment.
10 Do you recall that? '
L 11 A And/or pre-heat; yes. .
12 Q What were those instances?
/' 13 A Again, those were instances where the code required
(
,14 post-weld heat treatment. I don't know why he did it. It 15 could have been that he was too busy to review the record 16 properly and somebody else filled it in. It didn't have to be j 17 Mr. Puckett that N/A'd. Let me clarify that.
18 The document could have been filled out by someone 19 other than Mr. Puckett. It was Mr. Puckett's responsibility 20 to review the data that was contained on his document and sign l 21 it.
22 Q Because he reviewed all of the KE-1 forms?
l I .
e .
l
187 1 A That's correct.
( 2 Q Thes's were travelers that were filled out by someone l 3 else?
4 A .could have been filled out by someone else.
5 Q Were they generally filled out by someone else or by 6 Mr. Puckett? N 7 A I would say the majority was filled out by someone-8 else.
'.4 9 Q It was his responsibility as the sole welding 10 engineer to review and sign?
11 A And sign, along with the Level III quality assurance.
12 engineer.
13 Q Did the Level III quality assurance engineer approve 14 the N/A of the post-weld heat treatment on these travelers?
15 A He didn't approve the N/A. He approved the l
~
16 document.
17 Q He approved the N/A in the same sense that 18 Mr. Puckett approved the N/A?
19 A Correct. I stand corrected.
.l 20 Q I think you testified earlier that the specification i 21 of welding parameters on the KE-1 cards, the veld travelers, 22 represented in your opinion an. engineering function; correct?
9 1
I .
5
188 :
1 A Ident;ification of the specification that should have
(
2 been on the KE-1 card. In other words, it is a welding 1
3 procedure specification that a welding engineer specifies for -
4 this mate' rial, he will use this specification for welding; I .
5 yes.
6 Q In short, the completion of the travelers is an 7 engineering function?
8 A That's correct.
t 9 Q That function was being performed by the three or l 10 four person organization you described, that Mr. Puckett 11 supervised when you came on the job? ,
f' 12 A That's correct.
( 13 Q To the extent that persons other than Mr. Puckett
... \.~
14 completed those weld travelers, that engineering function was 15 being performed by non-engineers; correct?
i -
g 16 A Some of it; yes. Let me, for the record, clarify 17 something. Portions of a KE-1 card, as the information is ,
i l 18 applied, for the majority of cases, by the principal !
4 1
19 engineering groups of a given discipline, Mechanical 1 20 Engineering would look at the drawing and say, we are going to I 21 make field weld number one, drawing number so and so, material 22 thickness according to the drawing is this, this and this.
O e
4 1
l
189 1 We then look at this, the base metal, whether it is ,
2 A106 grade, B, or whatever it may be. We then look at the
. 3 thickness of the members and we then assign the welding
- 4 procedures. We then assign whether pre-heat is required. We 5 then assign whether the post-weld heat treatment is required.
. i The Level III will then assign the NDE requirements 6
7 and certain hold points that he wants to witness or his 8 quality control inspector witnesses during the actual welding.
9 The total block.is not,all filled in by welding 10 engineering.
i 11 Q The specification of the welding procedure and weld 12 parameters is the portion that is the welding engineer's
( 13 responsibility?
14 A Right; all the welding activities, pre-heat, 15 post-weld heat treatment and welding specification.
. 16 Q That function was being performed, at least in part, 17 by non-engineers at the time you came to Zimmer?
18 A I would say that is a correct statement.
19 Q Could it have escaped, in your opinion, the 20 attention of project management at Zimmer, that Mr. Puckett {
21 and his three other associates, were the persons who were 22 completing all of the KE-1 weld traveler foras?
, t G
l l
, . , ,-.,,,-e---
.,,- , , . - . _ - - , , - , , , , , - , , _ . , _ _ . , _ . . _ , . _ - - . - . , , . - ,_ , ,--._,,a..-,.,-,-, - .,w._
190 1 MR. MILLER: Objection to the form of the question.
2 Go ahead and answer.
3 THE WITNESS: Could it have escaped? -
4 BY MR. GUILD:
}
5 Q Let me put it another way. Was project management 6 aware that this function, that is the speci,fication of welding procedures and parameters on KE-1 forms, that function was-7 8 being performed by non-engineers?
9 A If they weren't. aware of it, then there was 10 something obviously wrong. There is no way that the welding 11 engineer can do all of that by himself. We are talking about *
. 12 a huge amount of documentation, on the average of 50 weld
( 13 travelers going to that office, along with other. functions.
su.
14 Q On a daily basis?
15 A On a daily basis.
16 Q It would have been apparent to Zimmer project-17 management that Mr. Puckett personally could not have done all 18 that work?
19 A That's correct.
20 Q Do you know a man named George Orlov?
21 A Yes, sir; I do.
I 22 Q In what capacity do you know Mr. Orlov?
, l I _
I
- i. 1 l I
191 1 A Mr. Orlov was in the CGEE quality assurance 2 organization 'and my first contact with Mr. Orlov was that'he 3 was not only in the quality assurance engineering organization .
4 for CG&E, but he also was -- I wouldn't say responsible -- he 5 was certainly involved to a large extent in the welding side 6 of the house.
7 Q In what manner was Mr. Orlov involved in welding?
8 A Like in the review of CAR's; corrective action
, 9 reports, the initiation of CGEE type corrective action 10 reports. For instance, if HHK Co. did not initiate a i
11 document, Mr. Orlov would,.if in his opinion we were not .
12 complying with the code or whatever.
i, 13 Q Was Mr. Orlov, in your opinion, knowledgeable of 14 ASME and AWS code interpretation?
15 A Mr. Orlov was knowledgeable in code interpretation; 16 yes.
17 Q Did you ever have any occasion to question 18 Mr. Orlov's understanding, application or interpretation of 19 either the AWS or the ASME codes?
- 20 A I would rephrase that by saying there were times
! 21 that we had differences of opinion.
l 22 Q Can you give me an example where you and Mr. Orlov s
l
+ , - - - - - - y yer g- ww. - , - - -
e --- - - - - . , - - , , , , , - - - - - , - - - , - - - , . w-,-,wv--,--w r, ,,_,--,-,w--w.,.-r,
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i 192 ,
I had a disagreement about the interpretation of the AWS code?
i 2 A Not right.at the moment; no. I would have to really I 3 search my memory banks. ,
4 Q ,How about the ASME code?
- , 5 A Same thing; not off the top of my head.
6 Q Did you ever make any statements to others critical 7- of Mr. Orlov's qualifications, knowledge of the ASME or AWS 8 codes?-
( 9 A Not to my recollection. I made statements of 10 dissatisfaction, but again, that was personality -- not a 11 personality problem, but it was a problem where we didn't see .
12 eye to eye on certain things. Obviously, I am sitting down
+- -
13 frustrated and I'm saying, dann it, how can this guy do this, i (
14 or whatever. That is a daily occurrence.
15 You don't accept certain solutions to a problem that 16 comes from the other side of the house, especially the quality 17 side of the house. The quality side of the house, in general ,
18 is the most critical observer of any activity. They certainly l 19 look at the more stringent requirements that you could l 20 possibly look at, where the engineering side of the house, i
21 from a construction standpoint not necessarily looks at it 22 that way.
i -
O
,-,,,,,.,,._r.., _ . . , .%,... -, _ _ . ,_ _ _ _ - . - , . . - - . , , , . ,
)
193 l l
1 Q Did you ever make any statements that were critical H
( 2 of 'Nt. Orlov's qualifications to perform a job he was 3 performing at Zimmer?
4 A .As my frustration levels rise, sometimes I could 5 have, but I don't recall a particular instance.
6 Q Do you recall the substance of a criticism that you 7 made of Mr. Orlov's qualifications?
8 A If it was any kind of a critical statement of 9 Mr. Orlov -- I don't really remember the degree Mr. Orlov 10 has. I believe it was in civil engineering. Maybe the 1
11 statement was what does a civil engineer know about welding, .
12 something to that effect.
13 Q Were you aware of Mr. Orlov's experience in nuclear
(
14 construction at the point where you encountered him at the 15 Zimmer plant?
16 A No; I was not.
- 1. 17 Q Do you know if he had any experience in nuclear 18 construction prior to his employment at Zimmer?
19 A No; I did not.
20 Q Do you know whether he had any experience as a 21 welder?
22 A No; I do not.
8 9
( .
i I
l I
l 194 1 Q Did you ever have any conversations with Mr. Orlov
( 2 concerning Mr. Puckett?
I 3 A well, yes, I believe on one or two occasions. That ,,
1 4 falls into the category of criticism that we discussed j 5 earlier, where Mr. Orlov voiced his dissatisfaction with the 6 way Mr. Puckett conducted business. I suppose my response, as 7 it always is, is that particular thing is my concern, and if 8 he has a problem, he should come to me.
9 Q What was the substance of the statements Mr. Orlov 10 made reflecting dissatisfaction with Mr. Puckett? '
11 A Just general comments. .
12 Q On what subject?
/ 13 A Welding. Don't ask me to go into details, because I l ,14 don't recall. I do recall that there was critical comments 15 made by Mr. Orlov concerning Mr. Puckett.
16 Q Do you recall the nature of the criticism at all?
17 A No, except it was a general statement, such as how 18 can you let this guy continue, or something to that nature.
I 19 Q What was your response to Mr. Orlov?
20 A That was my responsibility, not his.
21 Q Do you know whether or not Mr. Orlov, prior to your 22 coming to Zimmer, was aware that Mr. Puckett was performing 1
( .
l .
-~ , - - - - - , - - - , -- - - - . , _ . , . - - , - , . - - . - -- - _ _ . , . . . , , . . - . - , , , - - , - - - , - - - ,
= . _ _ _ _ .-___- -_-- . _ - _ _ _ _ _ _ _ _ _ _ _ - _
l
, 195 i l
1 the engineering function that he was performing with the staff
( 2 he had, with 'espect r to the completion of weld travelers?
- I 3 A I believe Mr. Orlov arrived after me at the Zimmer .
4 project., Yes, Mr. Orlov was well aware that Mr. Puckett 5 filled out weld travelers.
6 Q Orlov was there after you?
7 '
A After me; right.
8 Q Did you testify before a Federal body with respect 9 to these record classification questions?
10 A I have testified before the Office of Investigation 11 on numerous items concerning the Zimmer velding activities in ,
12 general, which included possible falsification of records, et 13 cetera.
,14 Q It included the subject of the retyped welder 15 qualification records?
16 A I'm not so sure that came up. That issue, I 17 believe, was resolved. That could have been brought up. I 18 would have to really research my records. I'm not sure it 19 came up.
20 Q How about the FBI? What did you have to say to the 21 FBI?
22 A I had no dealings with the FBI.
e 4
, . . -. _ _ - - ~
e 196 l 1 Q You used the word " FBI" this morning.
' ! 2 A The FBI was conducting an investigation concerning
. 3 these 32 welders, a gentleman by the name of Woody Wagner. .
4 Q What about Mr. Wagner?
5 A Mr. Wagner was the one that reviewed in detail this
. 6 particular item and came up with the resolution to the items.
7 He investigated everything concerning this item.
- 8 Q The 32 welder qualification records?
9 A That's right. From my understanding from .
10 Mr. Wagner, the FBI visited him regarding falsification of 11 records, specifically this particular item. ' l 12 Q You had no contact with the FBI?
13 A No, sir.
,14 Q Turning to the matter of Mr. Puckett's contact with 15 you after you both had left Zimmer, his calls to you from 16 Comstock. When.did those occur? Were they spaced over a 17 period of a month? Did they occur during a period of three or
, 18 four months?
19 A ,-I would say they occurred over a period of maybe 20 three months.
1 21 Q To refresh your recollection, I will ask you to I 22 accept that Mr. Puckett was on the Comstock payroll from let's
( .
i
, - - .___m _ _ , _ _ _ _ _ . . , _ _ , _ _ _ ,
. l l
l 197 i
1 say May of 1984 until August oY 1984, roughly that period of
,- I 2 time. Were the calls over the span of that period of time, to 3 the best of your recollection? '
J 4 A .Yes.
5 Q Did Mr. Puckett ever send you any documents?
l 6 A No; he did not. .l 7 Q Did he ever relate to you any disagreements with his 8 management at Comstock?
. 9 A In the conversation period, yes, I believe he made 10 some remarks about management at Comstock. l l, 11 Q What did he say to you in substance? -
12 A I suppose his basic statement was that he can't get
, (
13 people to understand what the problems are. In a couple of 14 case's, he was seeking my interpretation to reconfirm his 15 understanding of the code.
16 Q Who do you mean by " people?" His management? i 17 A I would say so.
18 Q That is how you understood it?
19 A Yes.
20 Q How do you mean " problems?"
21 A The items he asked me about, that we discussed l
22 earlier.
0
( .
1 i
198 1 Q Did Mr. Puckett ever state to you in effect that he
?
(. 2 found problems with the Comstock welding program that were 3 similar to the problems that had been identified in the Zimmer ,
4 program,-and that he was trying to bring those problems to his 5 management's a,ttention in order to correct them and improve 6 the program, or words to that effect? .
7 A Not words to the effect that he was trying to bring 8 it to his management's attention. Words to the effect that he 9
identified problems or he sees the same problems that we had 10 at Zimmer and what corrective action would I take. On a 11 couple of occasions, I told him that my corrective action was.
T 12 stop work. From the way it was explained to me, I would have 13 stopped work.
14 ~Q In order to take effective corrective action for the 15 problems?
16 A Immediately; right. You don't wait until next year, 17 you do it now.
18 Q I gather from what your response was to Mr. Miller 19 that you were not aware of whether he had brought his opinions 20 regarding these matters to the attention of his management 21 before he asked you for your opinion on these code questions.
22 A That's right.
4 -
199 l 1 Q Do you know whether or not, in the instances that he
^
(
2 brought to you, Mr. Goedecke, Mr. Puckett had reached a f
3 conclusion, communicated his opinion to Comstock management,
- 4 recommended a course of action to correct the problem and had 1
5 been rebuffed by management at Comstock, at the point when~he 6 brought these matters to you?
- 7 A No.
8 Q You stated earlier that you thought that simply 9 raising these questions to you, asking your opinion, was !
10 evidence of insecurity on Mr. Puckett's part, it shows a sign 11 of insecurity. Might it be the case, Mr.' Goedecke, if in fact' 12 Mr. Puckett had made a decision about a code interpretation,
(
13 made a decision about the need for a particular corrective 14 action, had put all that before his management at Comstock and 15 had essentially seen that it fell on deaf ears, that they 16 would take no action, might it reflect instead of insecurity, 17 simply a legitimate effort to try to get additional guidance 18 or support from somebody he respected?
19 MR. MILLER: Objection to the form of the question.
20 Go ahead and answer.
21 THE WITNISS: The insecurity portion comes in when i
22 I, for instance, make a decision whether or not something is a I
i
t .
200 1 code violation, that I would not go outside an organization to
( 2 a fellow that in no way, shape or form could effectively 3 persuade his management to take some kind of action. The .
4 ins'eeurity comes in -- I'would have simply put it in writing, 5 issued the stop work and took it from there. That's what I 6 mean by insecurity. N -
7 -
Let me clarify what I am really trying to say. In a 8 position of authority, if you as a responsible engineer do not 3, 9 have the authority, then I would have resigned period. That's 10 the way I operate. If I gave you a problem and you say it is 11 a non-problem, I put it in writing, and it is up to you to -
. 12 take corrective action, if you do not act on this thing, you 13 leave me no other resource than to resign.
(
l A4 BY MR. GUILD:
15 Q Do you know whether or not Mr. Puckett put these
~
16 problems in writing to his management at Comstock?
i 17 A No; I do not. He didn't tell me he put that stuff 18 in writing.
19 Q Do you know whether he in fact had the authority to i
20 take corrective action such as issuing a stop work order at '
i 21 the time he identified these problems? l 22 !
A I do not know if he had the authority or not; no. '
201 1 My recommendation was when he asked me, what would you do, I 2 said, you know darn well what I would do, you have seen me 3 operate at Zimmer, I stop work. .
4 Q Do you know whether or not Mr. Puckett was in fact 5 terminated by the Comstock management precisely because he
, 6 took that sort of action, and I mean stuck to his guns and 7 said, you should stop work until you fix these problems?
8 MR. MII1ER: Objection to the form of the question.
9 Go ahead.
10 THE WITNESS: It was my understanding he was 11 terminated because of that, from Mr. Puckett; yes. -
12 BY MR. GUILD:
13 Q Did he talk to you after he was terminated?
14 A Once.
15 Q What were the circumstances of that conversation?
16 A simply that he called me and told me he had been 17 terminated.
18 Q What did he tell you about the reason for the 19 termination?
20 A Precisely what was just discussed.
21 Q What did you say to him?
> 22 A I believe I said something to the effect that, well, 4
- 4
. - . - , . - . , , -_ - - . , - . . , _ - - - , ,.,---_.-m--n-.,
202 1 that isn't right, or I will help you get another job, just
~
- 2 send me your resume and I will see what I can do for you.
3 Q Did he send you a resume? '
4 A Yes; he did.
5 Q Did you try to help him get another job?
6 A Yes, I did. I submitted his resume to General 7 Electric. Company.
8 Q Do you know whether they were hiring people with his
, 9 qua.'.ifications?
10 A I had a very close personal relationship with the 11 responsible person at General Electric. At the time I. ,
12 submitted his resume, there was no additional help required.
, / 13 Q I cut you off a minute ago.
( 14 A Did you? I don't remember that you cut me off.
15 Q You mentioned in response to Mr. Miller that prior i
16 to Mr. Puckett taking the job at Comstock, you had transmitted i 17 his resume to General Electric. Do you recall?
18 A I don't know if it was prior or after. .
19 Q Did you do it more than once? You said you had a 20 cover letter you sent to General Electric.
21 A Right. I don't really recall whether it was sent 22 after his termination from comstock or prior to Comstock. I O
( .
i l
i
- . _ _. =. .. - . . - - - - - - - - - - - _ - _ _ . _ _ _ _ - _ _ _ _ _ _ . - _ - - -
~
203 1 don't recall the exact date.
( 2 Q What*was the substance of the letter you transmitted 3 to GE7 4 A The substance basically was that GE in general hires 5 welding supervisors, people that go out and actually help a 6 welder correct his mistakes, train a welder in the actual 7 welding. I felt Mr. Puckett was perfectly suited for that 8 type of position.
9 Q He was a highly qualified welder?
10 A Yes.
11 Q You described a conversation with Mr. Puckett ,
12 regarding the applicability of AWS D1.1 to thin gauge --
13 A That's correct.
(
14 Q What is the purpose of the publication of the D1.1.3
^
15 code?
16 A specifically to deal with thin gauge metals, sheet 17 metal. ,
1 18 Q Is it a general practice in the industry to use D1.3 l l
19 when working with sheet metal, as opposed to D.1.1? l j
- 20 A Yes. At a later date, it is the general practice.
, 21 You have to understand that the D1.3 code upon issuance, in 22 the beginning when it was first issued, and I believe it was G
1
- , ~ . - . - . . . - - . . - , . . _ . - - - . - .- . - - - . _ . .. . ---.- - - .- - . - - - - . .
204 1 around the middle 1970's when it was issued, and it could have
' -(
2 been 1973, 1974, 1976, these dates sort of stick in my mind, 3 that even though a code is issued, before it is recognized as
- 4 a code, a certain time span lapses. In other words, a code is 5 issued and nobody really takes notice that.there is something 6 like this issued.
7 Q In your opinion, is it more appropriate to qualify 8 welding procedures that are to be employed on sheet metal 1
9 principally, to the D.1.3 code than the D1.1.7 10 MR. MILLER: Objection to the form of the question.
11 THE WITNESS: Yes. It is quite obvious that the 1
12 Dl.3 is more appropriate for use for sheet metal applications.
( 13 BY MR. GUILD:
14 Q You understood that the Comstock Company,' the 15 electrical contractor, primarily does its welding on sheet 16 metal, thin gauge metal, cable trays?
17 A No. I am not aware of that fact. As a matter of 18 fact, unless you join the two metals together, the majority of 19 welding and the electrical applications join thin gauge to 20 heavier gauge materials.
21 Q How would you classify unistrut to cable pan? ,
i 22 A That's what I classify thin gauge to thin gauge.
i .
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, . . _ . . ~ , _ , , _ . . , , ,-- -,,gg -. ,y- , . - - . - , , - - - - , . . , . - - = , - - , - -
F 4
. 205 1 Q Procedures that would specify welding unistrut, it
~
( 2 would be emplo'yed in welding unistrut to cable pan, would they 3 be more appropriately qualified under AWS Dl.3 rather than 4 D1.17 .
5 MR. MII1ER: Objection to the form of the question.
6 THE WITNESS: That really depends on the cable pan
~
7 or cable tray itself. You have cable treys or cable pans that 8 are above the one-eighth inch we are talking about, 1
9 approaching up to a quarter inch in thickness, in case the 10 D1.1. would be the appropriate code. The only time Dl.3 11 really comes into play even now today, is if you are typically, i -
12 a sheet metal manufacturer, someone that for instance
! / 13 manufactures duct work, like in HVAC applications, now you are
( -
,14 strictly dealing with thin gauge metals.
i 15 The electrical contractor may have an application 16 for thin gauge metals, but he certainly is not limited to thin 17 . gauge material applications because he welds it to his eye 18 beams. He welds heavy clips to an eye beam from where the l
19 cable trays and wire rods are connected, bolting situations, 20 where your main connections -- the only welder connections are 21 three-eighths up to one inch, inch and a half thick materials.
22 I think I answered your question. I'm not sure.
O 4
l I '
i i -
i
.206
, 1 BY MR. GUILD:
N 2 Q I guess the one point I missed was to the extent 3 that we are talking about thin gauge material,,less than
- 4 one-eighth inch, the D1.3 code is the more appropriate code to 5 qualify procedures to?
6 MR. MILLER: Objection; asked and answered. I e
7 object also to the form of the question. Go ahead. .
8 THE WITNESS: Welding thin gauge materials, the D1.3
'. 9 code -- if I was the architect engineer, I would use the 10 Dl.l.3 code; that's correct. For the record, I do want to.I/4 6~ i.
11 make it clear that it is the architect engineer's
- 12 responsibility to dictate the code that is used. If you take
( 13 a typical nuclear power plant, in the early issues, the 14 contract date for ordering a nuclear power plant, in the early 15 1970 vintage, it is impossible to specify D1.3, because that 16 code was not existing at the time.
17 Obviously, D1.1 would have been stipulated. Like I 18 said, the 1975 edition of the code stf'l did not address the 19 limitations. It is quite cr: mon that D1.1 is used.
20 BY ER. GUILPs 21 Q Did you e= ploy the D1.3 code at Zimmer?
22 A I do not believe so. I believe I employed D1.1 1 4
i - -
i
207
. 1 because it was stipulated by the architect engineer.
2 Q You s'tated in earlier responses, Mr.'Goedecke, that
- 3 there was an explicit -- I understood you to say there was an 4 explicit code provision in D1.1 that spoke to the one-eighth 5 inch thickness applicability.
6 A That's right. That was only in a later edition, not
]
7 the 1975 edition.
8 Q Do you know what edition of the code the D.1.1 code 9 first used that express limit?
P 10 A It could have been the 1976 addenda. Without
- 11 further research, I couldn't really tell you that right now. .
12 I do know for a fact -- I believe the 1976 addenda brought it 13 out -- in my capacity, I jumped from 1975 code to the 1980
(
14 edition of the code at Zimmer, at my insistence, because it 15 clarified a lot of points that were previously not clear in
. - 16 the earlier editions.
4 17 I know for a fact that in the 1980 edition, that 18 stipulation was clearly identified in there.
19 Q When you speak of the addenda, is that distinct from 20 the annual edition of the code?
21 A Yes. It is a supplement to the code.
22 Q In an annual supplement, in the addenda, from what i .
,- , ----,~y ..--.-.---,-y---- . , , - . - , , , , _ , , , . , , , - - -- .-.- . -. ----.-,,,-,- - .,-,-,-<,w...
208 1 year was the limitation to one-eighth inch first employed 7
(
2 A I don't wish to be quoted on this. The 1976 --
3 Q That is your belief? .
4 A .Yes; addenda to the code. I don't know if anybody 5 got a 1976 edition. Do you have the 1975 edition there?
4 6 could I see it for a secoud?
- - 7 '[ Perusing document.]
8 Q Mr. Goedecke, Mr. Miller asked you some questions 9 concerning NRC Inspection Report 85-09 for the Braidwood 10 facility. It has been identified as Exhibit No. 4 to 11 Mr. Puckett's deposition.
- 12 He first asked you about the subject of the 13
( pre-qualified materials. I think you agreed with him, as I 14 understood, that if Comstock had a procedure that had
- 15 qualified welding A446 to A500,' that would have established 16 the qualification of A446 to A36.
17 A That's correct, since both A500 and A36 are 18 considered pre-qualified materials. From a chemical and 19 physical standpoint -- including A446 -- they do not 20 differentiate that greatly.
21 Q Are A500 and A36 the same material?
22 A No; obviously not.
O e
- . . . - - , - . . - - . . - . ..-.n-- . - - . - - . . - _ , , _ . . - - _ - - . . _ , _ . . - - , . , - . - , , - ,. . - , - . , . - - - _ , , - - - . , - , - - . -
i 209 I 1 Q What is the difference between A36 and A5007 2 A ' A500 is a finer grade material.
3 Q What provision of the code would establish that ,
4 pre-qualification -- strike that.
5 What provision of the code would. establish that the i 6 qualification of A446 to A500 establishes the 7 pre-qualification of A446 to A36?
8 A The code does not establish the pre-qualification of
^
9 A446. You have to qualify A446. You do not have to qualify 10 A36 and A500, since they are the materials that have a 11 pre-qualified status. If I weld A446 to itself or A446 to any" 12 given other material that has a pre-qualified status, tested 13 in accordance with the code, now you have a qualification of.
14 the A446 material.
15 Q Let me be clear and bear with me, because I am not a 16 metallurgist, a welder or a code expert.
17 A446 is not a pre-qualified material?
18 A That's correct.
4 19 Q Do I understand that if you have qualified A446 to j 20 any material that is pre-qualified in the code, the velding of 21 A446 to any of these materials is itself qualified?
22 A That's correct.
~
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'_ _ _ _ , . _ . _ _ _ _ _ _ _ . _ . , . , _ - _ _ .--____.m._., . _ , , . . . . . _ . . . . _ . _ _ _ _ _ _ _ , . _ . . _ . , _ _ _ _ _ _
. 210 1 .Q Without any further qualification or testing?
. 2 A Thats correct.
i 3 Q What sort of applications is A500 material'used in, 4 typically? !
l 5 A I don't know typically. If I had a choice of l l
6 materials where I require a more dependable material than A36 7 -- A36 is a material that allows numerous impurities in the 8 metal itself, where A500, even though compatible to A36, 9 requires a finer grade material. It requires less 10 impurities. From an ASTM manufacturing standpoint, one has to 11 look at ASTM to really compara the two, as far as requirements ,
12 are concerned.
( 13 Q What significance in terms of welding procedure and
~
14 technique -- let me strike that.
15 of what significance,'in terms of welding essential
- 16 variables, would welding of a base material to A500 as 17 contrasted with A36 be?
18 A None. There would be no change.
19 Q You mentioned that Mr. Puckett brought to your 20 attention of the existance of errors and inconsistencies in 21 the Comstock welding procedures. I think you characterized 22 those as similar to the errors and inconsistencies that had l
l 1
211 l_ 1 been identified in the Zimmer procedures; correct?
( 2 A That's correct.
Did he make that characterization by use of any 3 Q 4 example of errors or inconsistencies?
5 A No, except the ones we discussed already, just non 1 .
6 pre-qualified materials and stuff like that. I 7 Q What were the applications in which the Zimmer ,
'- 8 program required heat number traceability for materials and j 9 components?
10 A Again, I have to make something clear. At Zimmer, 11 we were the general contractor. We didn't have a procedure *
- 12 for electrical applications by itself. Our procedures dealt i i 13 with all disciplines. Therefore, our requirements were more
(
i: 14 stringent than ordinary requirements for an electrical i
15 contractor. Ordinarily, an electrical contractor does not 16 maintain traceability of stock material. That's just put on j 17 the drawing. We will use A36 and A36 is used.
18 Q My question was, what was the scope of the heat i
19 number traceability requirement at Zimmer? I think you just 20 answered it was a general requirement applicable to electrical j 21 as well as other disciplines.
i
! 22 A It was a requirement that applied to every i
I i
i i
i
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.,_....,,,,...,,,,.--..-.m.m-,. .,.-...-,,,___-.c., -a--
. 212 i
1 discipline. Our requirement was you traced the item to the
( 2 point of installation.
3 Q You required heat number traceability to the point 4 of installation for electrical discipline work at Zimmer; i
j 5 correct?
6 A We did not differentiate, as I said earlier.
7 Q What is the requirement of the AWS code with respect 8 to quality control verification of two things, first, welder l 9 qualification tests and then welding procedure qualification
- 10 tests?
3 11 A In my opinion, there is no requirement in the AWS i -
12 code that requires quality assurance or quality control to i 13 witness a test.
i 14 Q What is the requirement, if any, with respect to 15 quality --
i 16 A To perform the NDE portions.
l 17 Q Does that include visual inspection? !
1 18 A Visual prior to destructive testing, obviously.
19 Q Do you distinguish that requirement from the i 20 requirement for a visual inspection of the complete weld 21 performance?
22 A Yes. I would make a distinction between the two.
e 6
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213 1 Q Are you suggesting that the code requires only NDE
( 2 inspection of'the product , of the coupons?
3 A NDE or destructive testing, "NDE" meaning' 4 non-destructive examination or destructive examination.
5 Destructive obviously would be bending of a specimen versus 6 non-destructive being an X-ray or RT requirements of a coupon.
7 ,Q In your opinion, the AWS cctda then would not require 8 a QC verification of fit-up for welder qualification or 9
,2 welding procedure qualification?
10 A That's correct.
11 Q or QC verification of pre-heat? ,
12 A That's correct.
13 Q Even if pre-heat is one of the parameters specified 14 in the welding procedure?
15 A That's correct.
~ 16 Q or the position in which the weld was performed?
17 A That's correct. All of these things have to be done 18 by someone, but what I'm saying is it does not have to be a 19 quality control individual. Usually, in the industry, it is a 20 welding engineer or welding superintendent's responsibility to ,
1 21 assure that these things are done.
22 Q In your opinion, the AWS code does not require any l
O
_ . , ~ . , - , . . . - - , - . - , - , . . - . , - - - - --,.,,,,.,..-.,_-,,.,,.-...,--r--..-.,-._,e,--- , - , ,--c.-m .- .+-r ,,.c ,,,--e.------- -, _ -v,
214 1 quality control verification of those steps in the welding
( 2 process?
, 3 A That's correct. :
4 Q .what is your opinion of the requirements of 10 CFR 5 Part 50, Appendix B, with respect to quality control
. 6 verification of welder qualification testing and welding 7 procedure qualification testing? .
- 8 A I suppose it depends whether we are talking about a
. 9 safety related item --
10 Q Let's assume it is a safety related item.
11 A Then 10 CFR 50, Appendix B, and I believe it is -
12 Criterion nine, which states in part measures shall be 13 established to control special processes, which welding
- 14 obviously is part of. That dictates that your program that 15 you write establishes those measures, not.the code, the 16 program you initiate.
17 If your program dictates that quality control serves 18 the function to witness examinations of welders, then 19 certainly you have to follow that program. It is really up to 20 the individual. organization to establish those controls, to 21 the satisfaction of the NRC.
22 Q In your opinion, can those controls be established e
9 l
215 1 other than by use of a quality control inspector verification
( 2 of each of the steps in the welding process?
3 A You will have to repeat that. You are lea' ding me 4 into something. Will you repeat that question? I'm not 5 trying -- I'm sorry. I didn't mean to make that kind of a 6 statement.
7 Q It is the same point I have been asking you about 8 with respect to the code and Appendix B so far, Mr. Goedecket i
9 nothing different. Do you think Appendix B can be satisfied 10 by use of other means besides the quality control verification 11 of these various steps in .tlue welding process, when you are ,
12 qualifying a welder or qualifying a weld procedure?
13 A Yes; I believe it could be satisfied in another way.
14 Q How else could it be satisfied, in your opinion, l
15 other than reliance on quality. control verification?
16 A simply proceduralizing every step that requires a 17 welding engineer to witness a certain hold point. That, in my 18 opinion, would more than satisfy NRC requirements. In other 19 words, you make a fit-up hold. A welding engineer -- I am not l l
20 talking about a craftsman. I am talking about a welding !
21 engineer, will go up there, take a look at the fit-up, make 1
22 sure it is in compliance with the code, then sign it off as !
4 e .
l
4 216 1 in compliance.
. 2 The next step, when it is pre-heat, each step of the 3 way could be or should be satisfied in one fashion or .
4 another., I believe that would very well satisfy Appendix B 5 requirements.
6 Q In your opinion, does a program, in order to satisfy 7 Appendix 3 requirements, require the witnessing of these
, a welding steps by someone, whether it be a welding engineer or 9 a quality control inspector?
10 A Yes; I would say that, that is the intent of 11 Appendix B, Criterion nine. >
- 12 BY MR. GUILD
( 13 Q Mr. Goedecke, after you arrived at Zimmer, and 3
(
- 14 Mr.'Puckett was succeeded in the position he held as the 15 welding engineer, did the NRC identify any items of 16 non-compliance with respect to the Zimmer welding program?
j 17 A Yes. If I understand your question, was there any 18 additional findings after my arrival at the site.
19 Q Yes.
l 20 A Was there additional findings? Yes.
21 Q How about after Mr. Puckett was replaced in the i
22 welding engineer position?
4
. =
( _
l
---r ---,---------.,--,-,--e,-e -,.a -,._,--.w ----,r,,--,---m-,,w+~-, , - - - ~ , - - - --,._w,-_.,,.-.,,.g,,w,-, ,m ,,,e,--e.w.e ,,n-w-p ,-m,--,,--m--
l i
217 l i
1 A Yes. 1
( 2 Q Were'those findings.the responsibilit'y of someone 3 other than Mr. Puckett?
4 A Yes. l 5 Q Who was responsible for welding area items of 6 non-compliance after Mr. Puckett left the position as the 7 Zimmer project welding engineer? ~l 8 A Quite obviously, it was I. I was ultimately 9 responsible for the whole project. I don't know of any 10 nuclear plant that doesn't have any items of non-compliance.
11 Q I am looking at NRC Inspection Report -- it appears ,
, 12 to be 82-06 for Zimmer. It has a November, 1982 date and I
l 13 reflects inspections performed beginning April 9th and 1
14 extending through June 4, 1982. !
15 I want to direct your attention to the Notice of
- 16 Violation that is transmitted with that report. Let me shara 17 the document with you. Your name appears under the " Details" 4
18 portion. l 19 A Yes; I see it.
1 20 Q Under " Henry J. Kaiser Company." You are identified i 21 there as the weld manager; correct? !
22 A That's correct.
l O
! ( .
I . . _. _
f
, 218 1 Q Among other violations, this Inspection Report '!
1
( 2 identifies item one, which reads " Contrary to'the above i 3 engineering assistants, who are not qualified to do the work l 4 of a welding engineer, employed by H. J. Kaiser, were 5 performing functions which were described in the contractor 6 procedures as ' welding engineer' functions."
7 Are you familiar with that item of non-compliance? '
8 A Yes.'
l
- 9 Q Does that relate to a practice that occurred after i
10 you were responsible for the Zimmer welding program?
11 A That's correct.
12 Q Why did that item of non-compliance occur?
I 13 A It occurred because all of our procedures were
(
14 written in the play script format. It establishes the
- 15 responsibilities strictly from a managerial type position.
- - 16 These procedures here are administrative procedure's that we t-17 are discussing. We went by the order of responsibility.
i 18 When we said the welding engineer is responsible, we 19 simply did that to eliminate his assistant or the other 20 person. We just went by the order of responsibility.
i 21 obviously, these responsibilities can be or are delegated 22 downward. I believe this item was eventually resolved to the i I
i i
1 J
l
219 1 satisfaction of everyone by changing the procedure at a later f
L,4 2 date, by saying the welding engineer or his -- I don't t
3 renember what we called it -- approved substitute, something. ,
4 to that.effect.
i 5 Q You explicitly provided that the welding engineer i
6 could delegate to persons holding the position of engineering
( 7 assistant?
1 .
i 8 A Right, at a later point.
, 9 Q This finding reflected the NRC's conclusion that i>
10 that practice specified by the Zimmer procedure violated the 11 requirements of Section 3 of the ASME code; correct? .
12 A Yes, that was their opinion, even though the N/A g f" 13 section is a quality assurance section and not an engineering
( '
14 section.
15 Q The procedure that they cited, was that a procedure 16 you were responsible for adopting at Zimmer?
i pr a ci.:u.2 4
17 A Was that position identified? -
- i7 '
18 Q Yes. William H. Zimmer Nuclear Power Quality 19 Assurance Manual, Section i.3.
I 3
20 A Yes. That is the Quality Assurance Manual and not l l
21 our procedure. The Quality Assurance Manual deals with the 22 quality assurance organization. That's why I said N/A. It is 1
e *
( m .
_.,_-,,,.-,...,4=v--- - - - - . , . , , , . -- wsw-v------------~--*=-y -
- 220 1 the quality assurance section of the code, specifically in 1 ,
2 section 3, which establishes the quality assurance
- 3 requirements of a nuclear power plant. -
2 -
l 4 The point of argument here was whether or not an 5 engineering function falls in the criteria of quality 6 assurance / quality control. My contention was it never was.
l 7 These documents, after we initiated anything, as I stated 8 earlier, went to the quality assurance organization for review
. 9 and approval.
10 Q They were approved?
11 A And approved, in accordance with Section N/A, and I
- . 12 the quality assurance program.
,i ..
!. / 13 Q Did the engineering assistants who were, according
(
14 to the NRC, performing welding engineer functions, did they 15 work in your organization?
- 15 A Yes; they did.
17 Q I am going to show you another Zimmer Inspection i
i 18 Report. It appears to be 82-11. It has a transmittal letter 1 l
19 of May 13, 1983. You were responsible for the Zimmer welding l
j 20 program at that time; were you not?
t j 21 A Yes, sir.
22 Q Notice of Violation appears following the i
t . :
, , , , mmn, v w w, yw w - r--g r , ,,,m- w -v- www,=e-m----,,---,.r-,._ ee,-, w.v r - ,,, p,-,.----,---,-,,,.,-,,,-----,-,m,--- --
--,,-,w-.,
221 1 transmittal letter. It is item 1.b. It begins on page one k 2 and extends over on page two. Are you familiar with that 3 item? .
4 A , [Perusing document.) No, I am not familiar with the 5 item. That does not deal with the welding engineering 6 department. It is a quality assurance problem here.
7 Q In the welding area?
8 A It may deal with the welding area; yes. It's a 9 GQP10, Revision 2 corrective action reports, which is a lo quality procedure initiated by the quality assurance 11 organization. .
12 Q This is not a violation that falls under your area
( 13 of responsibility?
, 14 A That's correct.
15 Q Item 1.d appears on page three of the Notice of 4
16 Violation. It relates to the subject of weld filler material 17 control under procedure WCP3. Are you familiar with that item 18 of non-compliance?
19 A Yes.
20 Q Did that occur in your area of responsibility?
21 A Yes.
22 Q What was the cause of that item of non-compliance?
. l I
1 I
l
.. .___.- .-- - --- - - - - - - - - - - , - - , . - -----------------c - - - - - - -
- ' ^ * ' ' ' ' - ~ ^ - " ~ ~ ~ ~ ' ~ ~ '~
' ~ '
222 1 A Generally, when you qualify a welder in a weld test
( 2 booth, we are talking about in a weld test booth, not at the 3 fabrication of any nuclear component, in the weld test booth,
- 4 generally a welder quits welding and lays his rod on the.
5 table, he cleans his weld and lays his rod on the table.
- flu & j 6 In this particular case, somebody didn't btock in r M25 .
o f- 7 his oven and laid his rod on the table. It was identified as 8 a " procedural violation" of WCP3.
9 Q I see the first item that is described as 10 uncontrolled weld rod in the test shop. The second item is 4 1 11 uncontrolled bare wire weld rod in the RHR heat exchanger A I, 12 room. Is that a separate incidence?
(f 13 A Yes; it's a separate instance. Obviously, that is a i
4 14 procedural violation. You are dealing with 2,000 welders. It 15 happens every day that somebody didn't do what he was supposed 16 to do.
I
- 17 Q You were responsible for seeing that they did what j 18 they were supposed to do; weren't you?
i
~
19 A Yes, sir.
4 20 Q August 29, 1983, transmittal, Inspection Report 21 82-12. Again, the Zimmer facility. It reflects an inspection
)
l 22 conducted beginning October 1, 1982 extending through Decenber I
/
1 1
l '
,, 223
. 1 4, 1982. Were you responsible for Zimmer welding activities
, 2 at that time?
3 A Yes, sir; I was. '
4 Q Item three, page two, states as follows: "seven 5 welding procedures contained an essential variable deficiency, 6 such that it would be impossible to produce a quality weld 1
7 using the procedures as written..." et cetera. ~
8 Are you familiar with that item of non-compliance?
9 A No. Can I look et it? '
10 Q Yes.
11 A [ Perusing document.) These procedures written here i
! 12 were written prior to my coming to the site.
l 13 Q Did you identify the deficiencies in those
(
14
. procedures prior to the NRC's identification of the matters of 15 non-compliance?
i
! - 16 A This item, I did, to the best of my recollection.
17 These items were historical items.
l What I mean is they were 18 procedures that were in the vault no longer in use. _They had 19 been revised.
4 l 20 Q They had been revised by you when you came on-site?
i I 21 A Right.
22 Q They were previously employed in performing work at i
I I
{
i l
l
\ - . - . - -- -. .- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ ~ ~ ~ ~ ~ ~
l 224 1 1 the facility?
k 2 A Prior to my coming here.
3 Q Had you identified the deficiency in those earlier -
4 procedures?
Yes.
5 A We identified the deficiencies, and that is 6 why they were revised. \
7 Q Did you take correctiv's action for the work that was '
8 performed to the previously deficient procedures?
9 A No. I couldn't. I can't take a corrective action 10 or do anything about a historical problem until the time that
,l 11 we establish our final inspection of the plant. That was our '
- 12 valk-down. Any deficiencies like these were indeed 13 dispositioned at a later date. Some of them resulted in 14 corrective actions, such as cutting out a weld.
15 Q After the NRC identified the item?
16 A I wouldn't say the NRC particularly identified any 17 item. These items could have been identified prior to the 18 NRC.
19 Q That is my question, Mr. Goedecke. With respect to 20 the seven welding procedures that the NRC identified as not 21 containing essential variables, proper specification of
- i 22 essential variables, had there been any identification prior 1 . .
l
( .
i c, .y9-----=~.w m-eMM v 19-w '"
Fe--4------n"P *W ' "
i 225 1 to the NRC's inspection of the welds that were performed to r ( 2 those deficient procedures, such as a non-conformance report, 3 a corrective action report --
,l 4 A ,0h, yes. They all would have had a non-conformance {
5 rep, ort or corrective action report.
6 Q If you had appropriately identified these 9
7 deficiencies prior to the NRC's inspection, why did they write 8 it up as an item of non-compliance?
9 A They wrote it up as an item of non-compliance 10 because at that particular time, they went into historical
- 11 records. It had nothing to do with the ongoing current .
12 wel' ding activities. That was a complete and separate issue.
These items occurred, as I said, in the historical portion, 2
13 14 prior to my arrival.
15 Q It is your testimony that you had done everything 16 correct, everything properly to have identified both the 17 procedural deficiencies in the welding procedures and the work
, 18 that had been done to those improper procedures, prior to the 19 NRC's inspection?
20 A No. We identified everything that was in the i
3 21 welding procedure noted as a deficiency, and the welding 22 procedures that were in use at that particular time, not i
I I
- i I
. 1 l
226 1 corrections or any action that affected the hardware in the l
i 2 field, that belonged to the historical side of the house.
3 We had established a program with the concurrence of
} 4 the NRC that there was a due date. There was a date set by 5 the NRC, from this day forward, we will use the new 6 procedures. Then we will address the old items. This is one 4
7 of the old items. As a matter of fact, these particular items 8 would fall under the Worley Puckett era.
9 Q It is your testimony that you had no responsibility 10 for the item of non-compliance, that is item three in NRC 1 11 Inspection Report 82-127 1,
12 A Ultimately, I would have had, and I did have.
l' 13 Whether it is historical or current, ultimately I would have 1
(
14 dealt with all these problems. What I am saying is I had no 15 responsibility for the installation and the procedures that
~
16 were initiated prior to my coming there with the exception 17 that eventually I would have taken corrective action against 18 the pre-historical type welding activities. .
19 Q Did you make tha't point to the NRC, that you 20 eventually would have corrected these matters?
21 A Yes; we did. As a matter of fact, we did make 1
22 corrections, because it was written up. Once they write it e
1 1
i i
. 227 1 up, you have to take immediate or relatively immediate
( 2 corrective action.
3 Q Notwithstanding your position, the NRC identified 4 this as an item of non-compliance? '
r' .. .
5 A That's correct.
6 Q Item four of the same Inspection Report, it states )
7 in part " corrective action to data did not assure that .
8 conditions adverse to quality, i.e., deficiencies in essential 9 variables, were corrected to prevent deficiency in welds 1
10 produced by these procedures, or to address the quality of the 11 welds produced subsequently by these deficient veld
. 12 procedures."
13 A Again, we are dealing with a date of September,
(
,14 1981, prior to my involvement.
15 Q That's the date for the identification of weld 16 procedura qualification record deficiencies.
17 A Yes.
18 Q The point of the violation is that you didn't take 19 timely and effective corrective action for those historic 20 deficiencies; is it not?
j 21 A That's correct. I felt then and I feel now that it 22 was not under my scope to take action on historical problems.
1 .
l i
n.--.--..-, - , ~ , , - , , , - - - - - , - - - - , . . - - - - - , - . , . - - , - ,,---,-----n-,,- - - , - - - -e,----- ,, .c- -- ,,,~- - ,n, - ,,n ,-,a--.,
228 1 Q You were responsible for all of the welding activity k 2 at Zimmer during your tenure at that facility; were you'not?
- 3 A Yes. All of these items, I may add, were corrected ,!
.I' 4 in one way or another.
5 Q Item five of the Notice of Violation appears to cite 6 the Licensee at Zimmer for failure to notify the Commission 7 pursuant to 10 CFR 50.55(3), of the deficiencies in welding 8 procedure specifications and welder procedure qualification 9 reports. That cites this as a Severity Level Three violation.
10 A That is the problem. The requirements to report a 3 11 deficiency by the Licensee, not by the weld engineering -
12 department. The Licensee failed to inform the NRC of g 13 deficiencies that were reported.
14 Q Were you, Mr. Goedecke, as the project welding 15 manager, responsible for in turn informing the Licensee of the
- 16 deficiencies that are identified in item five of the 17 Inspection Report?
18 -
A No. I was not responsible for doing that. That is
- 19 strictly a function of the Licensee.
20 Q Who was responsible at Kaiser, if anyone, for seeing 21 1
to it that the Licenses was aware of the deficiencies of this 22 l sort, so that the Licensee in turn could make the 50.55(e) 1 i
i I
, 229 I .
1 report to the NRC?
y 2 A Mnf ,
(A Items such as corrective action.sequestr, CAR's, .f-i 3 which are submitted to CG&E for approval, lists potential 4 violations or it lista violations. Once you identify that you t
cA
.; 5 have a potential 21.o5 50.55(e), it is your responsibility to M, I-l 6 report this to the Licensee, which then has a requirement to i 7 report these items to NRC.
j 8 Q There was a Kaiser procedure that called for 9 identifying potential Part 21 or part 50.55(e) deficiencias to t
10 CG&E?
11 A That's correct. These items right here have an are'a 12 where it says potentially reportable or reportable. We y 13 strictly dealt with 50.55(e) 's there.
( '
l 14 Q Did you identify the items that are shown as
+.
15 deficiencies under violation five in this Inspection Report as 16 potentially reportable to the Licensee?
17 MR. MILLER: I am going to object. There are three
{ 18 or four of those that pre-dated Mr. Goedecke's appearance at 19 the Zimmer site. -
i 20 MR. GUILD: I don't mean to suggest otherwise. They 21 appear, as you say, but the question is the Report was issued 22 August 29, 1983, and is based on an inspection that apparently
/
~ *
.I ,
1 i
e
230 1 occurred from October through December of 1982. The question i 2 .still remains, did Mr. Goedecke report any of'those
! 3 deficiencies as potentially reportable items to the Licensee. i 4 THE WITNESS: No. It wasn't my function. That is a i ,
5 quality assurance function. It is my function to report a 6 deficiency to my quality assurance department, which then 7 issues an NR, a CAR or the' appropriate document. From that 8 point forward, this document goes to the Licensee. The L
l 9 Licensee reviews this document. He either concurs that it is 10- potentially reportable or it is reportable, then takes notice 11 and sends a letter to the NRC, informing the NRC of a 12 potential problem.
!. 13 BY MR. GUILD: '
! (
14 Q Did you have any involvement in the disposition of l
15 this item of non-compliance, item five in that Inspection i
[ - 16 Report?
17 A I'm not positive, but I would say if the CAR came to
] 18 our department, yes, I would have had an input via disposition i
l 19 of this item.
!' 20 Q What was your involvement in the Licensee's response l 21 to the NRC on this item, if any?
22 A I simply supply information to clarify the item, f
t e
n.- ,-~,.w,,---,. .-w,.. w--,,,,wg,,,-,-,_,--,,----,-,.w,,,n,-,-v - .--.n,---v_,_,-,,--,_- ------,g,-,,, w-s,e,-
. 231 1 correct the item, or dispute the item. Then the Licensee would take wha'taver recommendations I make, include them in
,'- 2 3 their letter of response, once an itan is identified as a 4 violation, or not use it. That is the Licensee's prerogative.
5 Q Do you recall performing that function in this 6 instance, for violation five? ,
7 A I don't think so, because the Audit Report, 67, 8 internal management QA audit, was again received on the site, 9 right after I came. I had no input there. It was reported.
'- 10 Q How about the management corrective action request, 11 82-02, dated September 22, 19827 ,
! 12 A CG&E management corrective action report?
13 Q Yes.
{
,14 A I most likely had some input in this.
15 Q Do you recall what it was? The subject again is ,
< i
~
16 weld procedure specifications and weld procedura qualification
- 17 report deficiencies.
18 A That's probably the report we initiated in the 4 19 welding engineering department to begin with. "Have remained 20 uncorrected." That's because we issued a new set of welding 21 procedure specifications to be used. In this case, it could 22 have been our response.
1 j .
I i ( .
l i
i h
k i
.. .- . . ~ ,
l 232
~
1 l Q You changed the procedures? -
l 2 A Yes,' or issued new ones, or qualified new ones. We 3 qualified numerous new procedures.
4 Q .Again, your position is that as to welds that were,,
4 5 performed under the old deficient procedures, you would have i I
6 gotten to correcting them at some point in the future? .
7 A ' That's correct.
4 .
8 Q Mr. Goedecke, did you have an experience with I 9 Mr. Schapker, an NRC inspector at the Zimmer facility?
10 A Somewhat,~yes.
11 Q Did he inspect in the weld area during the time you .
12 were on site at Zimmer?
- 13 A From my recollection, he did not do any physical
(
14 inspections. Mr. Schapker's main involvenant was in review of 15 documentation, welding documentation.
- 16 Q Did you have an opportunity to form an opinion as to 17 Mr. Schapkar's knowledge of the application and interpretation 18 of the AWS welding code?
19 A My involvement with Mr. Schapkar mainly dealt with 20 the ASME codes because the involvement of the Regulatory I
21 Commission at a nuclear site usually deals with safety-related
! 22 systems, and a lot of AWS applications are not safety-related i ,
i i
233 1 items. So the thrust of the NRC usually, as it was in our 2 case, dealt with items that affect safety.
3 Q All right. So your answer is that you did not have i 4 an opportunity to form an opinion about Mr. Schapker's ;
5 familiarity with the AWS code.
6 A I believe not, not with the AWS code.
7 Q Now then, with respect to the ASME code, did you 8 have an opportunity to form an opinion as to Mr. Schapkar's 9 knowledge of the proper interpretation and application of the
. 10 ASME code?
11 A Yes. As I previously had stated in regard to .
12 Mr. Orlov, there were occasions where I -- and some of these s -
13 things that are noticed herein --
A4 Q in the inspection reports.
15 A Right, and the numerous inspection reports that we 16 went through previously, that I obviously didn't agree with 17 the interpretation of Mr. Schapkar, but Mr. Schapkar, besides 18 quoting the ASME Code at times, his main thrust dealt with the f
19 18-point criteria of Appendix B, which at a later date 20 obviously were incorporated into the ASME Code verbatim, just i
21 about.
22 I don't always agree with an interpretation of a i
I i
l
. 234 1 code with anyone, and Mr. Schapkar falls under that category.
4 2 I don't always agree with Mr. Schapkar's observations or code 3 interpretations.
4 Q
- Recognizing that, what is your opinion about his 5 knowledge of the interpretation and application of the ASME 6 code?
7 A Average.
8 Q Now, what is the scope of Nuclear Power Services 9 work at the Braidwood site?
10 A Presently we have a scope of work at the Braidwood .
11 site. I have supplied two welding engineers to assist ,
, 12 Phillips-Getschow, and I believe that number is up to four 13 now. One of them resigned from NPS and went to work directly 14 'for Phillips-Getschow. In my area, that is our scope, to 15 assist Phillips-Getschow. Th' era are other areas where we are 16 involved, and I really can't give you an accurate description 17 of our involvement in these other areas.
18 Q Can you identify any other areas where NPS is 19 involved in Braidwood?
20 A Not really.
21 Q Do you have any knowledge at all?
22 A I have knowledge that we are involved on there, but f .
e
- k
235 1 what our scope is --
(
2 Q How about the subjects of other work? When you say 3 your scope of work, you are talking about welding? -
4 A Right.
5 Q What other disciplines was WPS involved in, if at all, at Braidwood? \
6 ,
, 7 A I know we are involved but I can't specifically tell 8 you which disciplines. I don't get involved.
9 Q Do you know how ;many other, if any, persons NPS has 10 placed at Braidwood outside the welding area?
11 A Yes, I believe there are about 10 or 15 of us down *
- 12 there, of our company employees down there. It might be more 13 now. I don't know. I have been in Europe. I've been out of 14 touch.
15 Q Now, what is the area of work in the welding 16 discipline?
17 A As I stated, strictly to act as a consultant to 18 Phillips-Getschow in dispositioning of nonconforming i
. l 19 conditions, reviewing procedures, specifications, retroactive j I
20 actions, if necessary.
l 21 Q Do you know how long NPS, first in the welding area, 22 has been involved at Braidwood?
5
-- e -- _ ,, , _ , , - - - - - +-- t---- .-
. 236 1 A I would say close to a year. February or March.
( 2 Q How about NPS in any other area eside'from welding?
, 3 A Probably -- and I am guessing, I don't know --
4 probably maybe two years.
5 Q Who are the engineers that have been supplied to 6 Braidwood by NPS in the welding area?
7 A As I said earlier, one of them resigned and went to 8 work for Phillips-Getschow, but the original manpower down 9 there was John Flaherty.
10 Q The same Mr. Flaherty who had been at Zimmer?
11 A That's correct. Paul Evans.
12 Q The same Mr. Evans who'had been at Zimmer?
13 A That's correct. A gentleman by the name of Wright.
(
14 That's W-r-i-g-h-t. I don't recall his first name offhand.
15 And Joe -- I can't recall his last name right offhand. Joe 16 Emerik. E-m-a-r-i-k, I believe.
17 Q And who among them left NPS and joined 18 Phillips-Getschow?
19 A Mr. Evans.
20 Q Have you consulted yourself with respect to 21 Braidwood?
22 A No, with the exception of administratively O
e 9
237 1 supporting my people at the site.
( 2 Have'you consulted with them regarding their work at Q
3 Braidwood? ,
d 4 A .Once in a while a code question pops up, yes, via 5 telephone, yes.
6 'Q Code questions raised by one of the gentlemen that 7 you have placed there? .
8 A Yes.
9 MR. GUILD: I believe that's all I have. Thank you.
10 .
11 ,
12 13
(
14 15 16 17 18 19 20 21 l
22 e
9 .
1 l
l
. - - . . _ . ~ . . . .
238 1 EXAMINATION 2 BY MR. MILLER:
3 Q Mr. Guild asked you about the requirements of 4 Appendix B with respect to quality control involvement in 5 welder qualification test procedures. Do you recall that line 6 of examination?
7 A
~
Yes. .
8 Q And I think ultimately one of your answers was that 9 the activities would have to be witnessed by quality control ^
10 or that there would be hold points for weld engineering, but 11 in any event, there would have to be a witness to a variety of, 12 activities in the welder qualification test procedure;
/ 13 correct?
(
14 A That's correct.
15 Q Now, my question is --
16 A Not to Appendix B. I don't think I said Appendix i
17 B. Appendix B, control of special processes -- again, let me 18 identify the area of involvement at Zimmer. At Zimmer we had 19 one standard for everyone, so we could not differentiate 20 between an electrician or an iron worker or a pipefitter. So 21 our QA manual was written to establish control of special 22 processes, which involved everyone.
l .
s
, - , , - - - - _ - , - - . . - - .- ,s.,
239 1 Q Including those welding to the ASME code; correct?
' k A 2 A That s correct.
3 Q Where the requirements with respect to welder , ,
4 qualification are more stringent than they are for the AWS
, 5 code; correct?
6 A That's correct.
7 Q Now, under the AWS Code and control of special 8 processes under Appendix B, would a program have to be e
9 established, in your opinion, for qualification of welders to 10 the AWS code which required continuous witnessing of welder 11 qualification tests? -
12 A If the AWS activities were involved in
( 13 safety-related items, it would fall under the same criteria as t 14 Criterion 9, yes.
4 15 Q Yes, sir, but would it have to be continuous as 16 opposed to intermittent witnessing of the activities? In i 17 other words, would a QC inspector -- let's say that the 18 program that was established called for a QC inspector to '
19 witness the welder qualification test. In your opinion, does 20 Appendix B require that the QC inspector be there 21 continuously? i i
22 A Appendix B does not require any such thing.
e 4
n ~
240 1 Appendix B requires that you establish measures, and if your i 2 program that you established requires that, than yes. If your 3 program establishes that you do a 10 percent inspection or you 4 do a surveillance, then you do so. But Appendix B does not 5 require, neither does it dictate any form of control.
6 Q Now, I think earlier in response to a question I 7 just asked, you said at Zimmer you had one welder 8 qualification procedure for all the trades, whether they were 9 involved in AWS or ASME welding. I take it that the heat 10 number traceability that you described in response to a 11 question from Mr. Guild at Zimmer similarly spanned all 5
- 12 activities within Kaiser's scope of work: electrical,
/ 13 mechanical, civil and structural.
14 A That's correct.
15 Q Are the ASME requirements for traceability more or 16 less stringent than the AWS requirements for traceability?
17 A The ASME is much more stringent.
18 Q You were asked about whether it was more appropriate 19 to use AWS D1.3 for the welding of thin-gauge metal. I think 20 we have established that.the AWS Dl.1 code, the 1975 edition, 21 does not have any limitation on the thickness of the metal 22 that is subject to welds made in accordance with that code l ( .
241 1 correct?
2 A Thats correct. -
Let's assume that the very next year, such a 3 Q ,
4 limitation does appear in the AWS code in 1976. Is it 5 required under the code th'at ths earlier versions which do not 6 have that limitation be abandoned as a requirement in the 7 ongoing construction? ,
8 A No, sir. The contract date and the FSAR
, 9 requirements, which clearly stipulates the codes that are in 10 use at a nuclear facility, is the governing document and the
, 11 specification, not adopting a later code. -
12 Q once the AWS D1.3 code became published and ~
4 13 available and in use, was its use by its own terms made 14 mandatory for ongoing construction projects that may have been 15 partially constructed in accordance with, say, AWS D1.1, 1975?
16 A No. The code does not make anything mandatory. The 17 architect engineer is the one that makes anything mandatory.
- 18 Q I think in response to a question from Mr. Guild 19 about your conversations with Mr. Puckett when he vas at 20 Braidwood and you were at NPS, you stated that you told him i i
21 to stop work on a couple of occasions. Do you recall the 22 4
circumstances that he described to you which led you to e
S 6 1
i 242 1 recommend or concur in his statement that the work ought to be
( 2 stopped? '
3 A I do not believe I ever used the term, '
4 saying: Mr. Puckett, stop work. I did not have the authority 5 to direct him to stop work. I simply said that in a situation 6 like this, I stopped work at Zimmer.
7 Q Now, what situations did Mr. Puckett describe to you 8 where you said in situations like that, I stopped work at 9 Zimmer?
10 A The base materials that weren't prequalified and 11 were.used at Braidwood.
12 Q This is what we have ultimately come to understand
/ 13 is the welding of A36 to A446 materials; correct?
(
, 14 A And the stainless steel materials, right.
15 Q Any other situations that you can recall where you
- 16 told him, well, at Zimmer we stopped work in such 17 circumstances?
18 A Yes. The other occasion was the position problem, l
l 19 where the qualification was performed in the SG position and 20 the welding was done to all positions.
21 Q Did Mr. Puckett ever tell you in any conversation 22 that he had, in fact, recommended a stcp work with respect to G
, 243 1 the SG position and that his recommendation had been followed? ,
'l
( 2 A No, he did not. l l
3 Q You don't know of your own knowledge whether, in i 4 fact, that occurred at Braidwood?
5 A To my own knowledge, no.
6 Q Mr. Guild started off his examination, which makes
~ ' ~
7 it the end of my redirect examination, by asking you about 8 persons who hold Level III certification for simply a
, 9 managerial status at a nuclear power plant site. Do you 10 recall those questions?
11 A Yes, I do recall that. ,
12 Q Even if an individual simply held a managerial 13 status at a nuclear power plant site and he was not performing 14 inspections or resolving disputed interpretations of welds in 15 the field as a Level III, in order to obtain the Level III 16 certification in the first instance, he would have to be 17 qualified and certified in accordance with the site 18 procedures, would he not?
19 A And ANSI N45.2.6, right. I'm sorry, ANSI 45.
i 20 Q 2.6. Yes, it's getting quite late, and I apologize.
21 Are there requalification requirements, in your
! 22 experience, for individuals who hold a Level III 1
, l l
244 1 certification?
( 2 A Yes.' As a minimum, there is an eyesight 3 requirement, and yes, there is a requalification requirement ;
1 4 if you have a procedure change, for instance. Then you have 5 to retrain individuals. It doesn't have to be an examination, ,
6 a detailed examination, but any time you change a program to 7 an extent, then certainly people have to be trained to the new 8 requirements, including the Level III's, who usually write the 9 new requirements.
10 MR. MILI2R: That's all I have.
11 [Whereupon, at 6:40 p.m., the taking of the .
12 deposition was concluded, signature not having been waived.)
13 14 4
p 15 .
16 17 18 19 20 21 22 ,
e 4
3
245 1 CERTIFICATE OF DEPONENT
( 2 -
3 I, MANFRED L. GOEDECKE, do hereby certify that 'I have 4 read the foregoing transcript of my deposition testimony and, 5 with the exception of additions and corrections, if any, 6 hereto, find it to be a true and accurate transcription 7 thereof.
8 9
10 MANFRED L. GOEDECKE 11 12 f
13 DATE
,14 ***
15 CERTIFICATE OF NOTARY PUBLIC
- 16 Sworn and subscribed to before me, this tha _
1,7 day of , 19 .
18 19 -
20 21 NOTARY PUBLIC IN AND FOR 22 My commission expires:
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CERTIFICATE OF NOTARY PUBLIC -
2 >
3 I, Suzanne B. Young, the officer before whom the foregoing deposition was taken, pages 5 through 244 , ,
5 do hereby certify that the witness whose testimony appears in the foregoing deposition was duly sworn by me; that the 7
testimony of said witness was taken by me and thereafter 8
reduced to typewriting by me or under my direction; that
' 9 said deposition is a true record of the testimony given by 10 the witness; that I am neither counsel for, related te nor ur '11
, employed by any of the parties to the action in which this 12 deposition was taken; and further, that I am not a relative
~
13 or employee of any attorney or counsel employed by the u
parties hereto, nor financially or otherwise interested in
- 13 l the outcome of the action. j 14 l
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1g L t da u.s - %W
' V
' SUZANNE'B. YOUNG 19 Notary Public in and for the gg ,
District of Columbia i
21 s7.
y My Commission expires: ut u di /f /9/f
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[ , APR 1 6 $82 i
Docket No. 50-358(DPRP) , /.,,, .-~. _ m{7',
]'
s Cincinnati Gas and Electric '
^g Company . .i,.s ATIN: Mr. Earl A. Borgmann '
,...y...,.
Senior Vice President .
j
. Engineering Services and .. M/
[/k Electric Production {P.-
- 139 East 4th Street L .
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' ,41sdinnati, OH 45201 Y '
Gentlemen: -
. N.ii, refers to the routine safety inspection conducted by Messrs.
V. T. Christianson, T. P. Gwynn, K. D. Ward, and J. D. Schapker of this office on February 1-5, 8-12, 16-19, 22-26, and March 1-5, 1982, of activities at Va. H. Zimmer Nuclear Power Station authorized by FRC Construction Permit No. CPPR-88 and to the discussion of our findings .
with Messrs. J. R. Schott, D. J. Schulte, and others at the conclusion of the inspection.
( ne enclosed copy of our inspection report idc .tifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
__ No items of noncompliance with NRC require.sents were identified during the c: utse of this inspection.
- Ia.accordance with 10 CTR 2.790 of the Commission's regulations, a copy 6f this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If this report contains any infousation that you (or your contractors) believe to be exempt from disclosure under 10 CTR 9.5(a)(4), it is necessary that you (a) notify this office by tele-phone within ten (10) days from the date of this letter of your intention to file a request for withholding; and (b) submit within twenty-five (25) days from the date of this letter a written application to this office to withhold such information. If your receipt of this letter has been i
delayed such that less than seven (7) days are available for your review, I please notify this office promptly so that a new due date say be estab-lished. Consistant with Section 2.790(b)(1), any such application must
~
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- Cincinnati Gas and Electric 2 April 16, 1982 Company
, , 1 be accompanied by an affidavit executed by the owner of the information which identifies the document or part sought to be withheld, and which , l contains a full statement of the reasons which are the bases for the l claim that the,information should be withheld from public disclosure.
This section further requires the statement to address with specificity the considerations listed in 10 CTR 2.790(b)(4). The information sought ,
to be withheld shall be incorporated as far as possible into a separate l part of the affidavit. If we do not hear from you in this regard within the specified periods noted above, a copy of this letter and the enclosed inspection report will be placed in the Public Document Room.
We will gladly discuss any questions you have concerning this inspection.
Sincerely.
50rfsinal s!gned by R.L. Spassard" R. L. Spess2rd. Director T. f: . of P sjsc: :c. ,
Resiaant Programs
Enclosure:
Inspection Report No. 50-358/82-02(DPRP)
(
, cc w/ enc 1:
J. R. Schott, Plant Superintendent DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII Harold W. Kohn, Power Siting ,
Commission Citizens Against a Radioactive Environment Helen W. Evans, State of Ohio Robert M. Quillin, Ohio Department of Health RIII RI I RI W, \
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U.S. NUCLEAR REGULATORY COMMISSION k REGION III Report No. 50-358/82-02(DPRP) -
Docket No. 50-358 License No. CPPR-88 Licenses: Cincinnati Gas and Electric Company 139 East 4th Street Cincinnati, OH 45201 Facility Name: Wm. H. Zimmer Nuclear Power Station Inspection At: Wm. H. Zimmer Site, Moscow, OH
. Inspection Conducted: February 1-5, 8-12, 16-19, 22-26, and March 1-5, 1982 Inspectors:
MbM- h
W. F. Christianson X !!4/62- /
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T. P. Gwynn 4 /Ii/32 H A Yd K. D. Ward /f!M
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06t4L J. E. Sch
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Approved By: Nnter, Chief I4 5 Reactor Projects Section 2B Inspection Summary Inspection on February 1-5. 8-12, 16-19, 22-26, and March 1-5. 1982 ,
(Report No. 50-358/82-02(DPRP))
Areas Inspected: Routine resident and regional personnel inspection of previously identified items; fuel receipt and storage; observation of special process and test activities; follovup on the Quality Confirmation Program; followup of the April 8,1961 Immediate Action Letter; and plant tours. This inspection involved a total of 148 inspector-hours onsite by two NRC resident and two regional inspectors, including 16 inspector-hours onsite during offshifts.
Results: No items of noncompliance or deviations were identified.
i O
, l 3205040548 920416 PDR ADOCK 05000358
- j e PDR
i *'
SECTION I Prepared by W. T. Christianson '
T. P. Gwynn Reviewed by D. R. Hunter, Chief Reactor Projects Section 2B
- 1. Personnel Contacted Cincinnati Gas & Electric Company
- J. R. Schott, Plant Manager
- H. R. Sager, QA Manager
- D. J. Schulte, QA Engineering Director F. K. Pfeiffer, QA Engineer F. Lautenslager, Security Supervisor C. Elenstroub, QCP Task VII Coordinator Henrv J. Kaiser Ccmpany
(
A. L. Jenkins, Site Operations Manager D. L. Snyder System Engineer The inspectors also contacted and interviewed other licensee and
- contractor technical and administration personnel.
- Decotes,those attending interviews conducted during the inspection period of 7ebruary 1 through March 5, 1982.
1
- 2. Licensee Action on Previousiv Identified Itess (0 pen) Unresolved Ites (358/81-15-10): Electric (Nuclear) Production Department did not have a program for control of design changes and l modifications. The licensee had not completed developing corporate directives and lower tier administrative and implementing procedures to control design changes and modifications to plant systems and equipment. With respect to the diesel engine modification, an Engineering Change Request (ECR #634) was approved for the modifica-tion on December 2, 1981, referencing the applicable documentation.
A procedure (ME CMP 4100, Revision 0, " Diesel Engine Vibration Damper Repiscenent") for performance of diesel engine vibration damper replace-
! ment was subsequently prepared and approved on February 27, 1982, specifying quality control inspection (witness) requirements, acceptance ,
-l- criteria, and retest requirements.
- l e i 1
e l
.- - .. . w __ __ w _ __ __
l i
(Closed) Unresolved Item (358/81-22-02): Valve RH LE12F306, the shutdown cooling , suction valve, is a manually-operated gate valve located inside containment but no position indication is provided in the control room. The inspector verified that the residual heat l removal system operating procedure OP.RN.01, Revision 06, dated i January 28, 1982, requires that valve 1E12F306 be locked open prior ,j to system operation. In addition, a physical locking device (chain) ,
was available on the valve. To resolve this satter, the licensee has issued a nonconformance' report (NRC-QAD-82-1304-I) identifying the deviation from the GE design specification.
(Closed) Unresolved Item (358/81-22-09): Several deviations from the GE Design Specification and the FSAR description, involving valve
, packing leak detection, require resolution by the licensee. The li-consee has issued nonconformance reports pertaining to valves 1E51F066 (NR-QAD-82-1092E) and 1821F016 (NRC-QAD-82-1091E) for engineering .
disposition to resolve this matter. The remaining valves, including the reactor vessel head vent and vent to radweste valves 1B21F001, F002, F005, and the RCIC steamline drain valve 1E51F076 listed by the inspector are of a packless variety and require no licensee actions.
- 3. Fuel Recein: and Storaze The inspector verified the integrity of security controls in effect ,
for the new fuel storage area, verified proper environmental protec-tion for the new fuel storage area, and spot checked the implementa-tion of licensee commitments under NRC Special Nuclear Materials
- License SNH-1823.
- a. Documentation Reviewed (1) SE. SAD.03, " Interim Access Control New Fuel Storage Area",
Revision 6, dated June 25, 1980 (2) Refueling Floor Access List (2) EC. SAD.07, " Cleanliness Centrol", Revision 0, dated August 3, 1979
- (4) Station Security Contingency Plan
- b. Findings (1) Members of the guard force interviewed were alert and .know-ledgeable of procedures and requirements.
(2) The licensee was in compliance with .special nuclear asterials
' license requirements checked.
No items of noncospliance or deviations were noted.
1 i
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, _ _ , - - -. - _ - . . _ ~ _ - ~ _
- 4. Observation of Special Test Activities The inspector observed partial performance of SU.SP.23, " Initial I Recirculation Pump Operation". This inspection included verification of a sample of test prerequisites, verification that the latest revision *
'of the test procedure was available and in use, that sufficient personnel were available for conduct of the test, that all test participants were .
briefed prior to test performance, that essential plant systems were in operation .as required by procedure, and that the system operating procedure '
was checked cut to the extent practicable during test performance. ,
- s. Findinzs (1) The training records of two test participants (the test director and CG&E staff engineer) were reviewed to verify that the qualification requirements of the Final Safety Analysis Report for preoperational test personnel were .
, met. Both individuals had received the required training
- and their qualification was documented in accordance with procedure SU.ACP.07, " Qualifications of Preop Phase '
, Personnel."
(2) CG&E management maintained appropriate overview of test
.: activities. Technical support was available through rep-
'. resentatives of the station technical staff, the generation - ,
construction department, and the pump vendor representative.
(3) Communications were established between the control room and remote test locations. There was coordination between the
( other test 'ocations. The actions of the test director were appropriate, timely, and in accordance with procedural controls.
, No items of noncompliance or deviations were noted.
- 5. Followup on the Quality Confirmation Prozrae - Review of Voided
,Nonconformance Reports The inspectors reviewed an additional 51 essential H. J. Esiser. j nonconformante reports (NRs) which had been " voided" rather than l
" superseded". The review consisted of determining that the exact
. problem described on the original (voided) NR had been copied on the superseding NR. The review was performed after each voided NR and superseding document had been submitted to and approved by the-NR review comttee per procedure 15-QA-04, Revision 0, " Review and i Processing of Voided Nonconformance Reports". This review included l-8 the following nonconformance reports:
l E-1422 E-1784 E-5004 E-1448 E-1862 E-2057
- E-1485 E-1862 R1 E-5015 i E-1574 E-1966 E-5073 j E-1591 E-1973 E-5076 j -
E-1591, R1 E-1984 E-2578 1
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. E-1607 E-2010 E-2578 R1 E-1610 E-2601 E-5105
( E-1610, R1 E-2671 , E-1078 E-1637 E-2711 E-5129 E-1641 E-2787 E-5149 -
E-2790 E-1641. R1 E-6006 .
E-1641, R2 E-2875 . E-6027
- E-1641, R3 E-2880 E- 784 E-1707 E-2912 E-6080 E-1708 E-2955 E-6084 E-1769 E-2966 E-6085 The inspectors identified two discrepancies with NR E-1591 which .
addressed traceability of material for pipe attachments in ASME code-class systems, as follows:
(a) On the original NR the pipe attachment number RT-RH-99 was changed to RT-RH-98. This change was not reflected in subsequent revisions of the NR (revision 1 and 2).
(b) The final disposition wh'ich closed NR E-1591 Revision 2, did not address the applicability of the NR to systems other than the reactor water cleanup system, although the condition description stated "This condition is also evident in other systems." .
These items are considered to be open and will be followed up in a future inspection. (358/82-02-01) '
( No items of noncompliance or deviations were noted.
- 6. Plant Tours The inspectors conducted frequent plant tours throughout this inspec-tion period. During a tour on February 11, 1982, the inspector ob-served that the reactor building floor drains were overflowing onto the floor cu the 496' elevation of the reactor building. The inspector informed the control room operators who imeediately corrected the I
. probles. No essential equipment was affected.
No items of noncompliance or deviations were noted.
1
- 7. Manezement Exit Meetinz Due to the frequent interviews with licensee representatives throughout j the inspection the routine exit meeting was not conducted concerning ,
this report section. '
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- W- N *. Om M W 3, , *Wp6 P W" --
N**
SECTION II
( .
Prepared by K. D. Ward ,
Reviewed by D. H. Danielson, Chief ,
Materials Processes Section
- 1. Persons Contacted Cincinnati Gas and Electric Company (CG&E)
~ ~
- D. Schulte, QA Engineering Director ,
- J. Vannier, NDE Ievel III Kaiser Enzineers. Inc. (KEI)
- D. Novard, Director, QA
- W. Nedzik, Site QA Manager The inspector also contacted and interviewed other licensee and contractor technical and administrative employees.
t
- Denotes those attending the exit interview on February 25, 1982.
- 2. Licensee Action On Previously Inspected Findinas
( Openi Noncompliance (358/81-21-01): Dis repancies in radiographs of two welds. One weld was cut out and replaced and the other weld is to be repaired.
(Closed) Unresolved ites (358/80-2'-01): 0 No specific time for a QC inspector to be in the veld test shop. The inspector reviewed HJK procedure, Welding Performance Qualification Testing, WCP-2, Revision 0, paragraph 4.1.11. The procedure included the following note:
" Representatives of HJK Veld Engineering and Quality Assurance vill be present in the test shop at all times when weld tests are being performed."
- 3. Eicensee Action on IE Bulletins (Closed) IE Bulletin 80-21. The inspector reviewed the the following documents which indicate that none of the safety related valves furnished to Zimmer by General Electric were manufactured by the Malcola Foundry Company:
II Bulletin 80-21 " Valve Yokes Supplied by Malcolm Foundry, Inc. ,"
dated November 6, 1980. .
CGEE letter to NRC dated December 29, 1980, and July 1, 1981 interim re,sponse to IE Bulletin 80-21. ,
I 1
i 6 i
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CG&E, letter to NRC dated August 5,1981 final, response to IE Bulletin 80-21.
- 4. Examination of Tamediate Action Letter Items During the week of February 23-25, 1982, the inspector reviewed the
- following items concerning the April 8,1981, Imediate Action Letter.
- a. Radioiraphs (Pullman)
A review of Pullaan shop radiographs is being continued by NES.
The review is approximately 85% complete and radiography is to ,
start in the near future. l t .
- b. NDE Personnel Certification
^
The NDE personnel certifications of the following NES personnel reviewing the Pullaan radiographs were reviewed.
i Name RT-Level M. Mercer II I R. Zieber III
- 3. Provost II
- c. Procedures n e following procedures were reviewed.
(
CG&E, " Review and Re-Radiography of Pullaan Power Products Pipe Welds", 19-QA-01, Revision 2.
CG&E, " Indoctrination and Training of QA/QC Personnel",
_ 02-QA-01, Revision 5.
HJK, " Preparation, Approval and Distribution of QA Precedures",
A-1. .
. d. Traininz Records The following NDE training recorda were reviewed.
.l E
CG&E Name Name
- R. Murphy M. DiPuccio J. Obermeyer D. Helton D. Podlin B. Ashenfelder F. Rivera J. Craig ,
No items of noncompliance or deviations were identified.
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- 5. Review of Radiorraphs
(
Theinspectorre[ievedthefollowingGE-suppliedshopweldradiographs performed by the General Electric Company and Associated Piping and '
'* Engineering Corporation.
- a. General Electric Company. Nuclear Enerzy Division Ites Name Piece No. Weld No. Date RT !
Dry Tube 6612406 11-12 12/7/77 Dry Tube 6612407 11-12 12/7/77
. Dry Tube 6612408 11-12 12/7/77 -
. Dry 'Dube 6612409 11-12 12/7/77 Dry Tube 6612410 11-12 12/7/77 Dry Tube 6612411 11-12 12/7/77 Dry Tube 6612412 11-12 12/7/77
! Extension TOB34-002 2-3 5/24/77 Safe End TQM43-002 1-2 6/8/77 I b. Associated Pipinz and Enzineerina Corocration Recir. Loop ,
Item Piece No. Weld Date RT
, Piping 761E379P9-1 W-A 6/1/72 Piping 761E379P9-1 W-B 5/30/72 l
( Piping ELL 22 T 3/22/72 Piping ELL 22 3 3/22/72 ,
Piping 0081-4 L3 4/25/72 t
. Piping 761T379P5 W-C 4/26/72 Piping 761T379P5 W-D 4/26/72 Piping ELL 36 T 3/8/72 Piping ELL 35 B 3/8/72 Pipf.c3 ELL 28 T 3/20/82 Piping ELL 28, B 3/20/82 ,
No items of noncompliance or deviations were identified.
- 6. Exit Interviev j l
'Ibe inspector met with the licensee representatives (denoted in paragraph i
- 1 of this report section) on February 25, 1982, and summarized the scope '
and findings of the inspection activities. The licensee acknowledged the inspector's findings. )
I i .
,t 8 l - - . m e. - . ....,,n. n- .n . . . . . . -~ .-. ~ m - - - -.
l SEO~: 'II
(
Prepared by J. E. Schapker -
Reviewed by D. H. Danielson, Chief Materials and Processes Section -
1 l
l
- 1. Persons Contacted -
l Cincinnati Gas and Electric Company (CG&E) !
- D. Schulte, QA Engineering Director .
- R. Vannier, NDE Level III .
D. Kramer, Acting Director, QC Division
- D. Noward, Director, QA
- V. Hedzik, Site QA Manager *
B. Varchol, QA Administrator Manager The inspector also contacted and interviewed additional licensee and contractor technical administrative employees.
(
- Denotes those attending the exit interview.
- 2. Observations of Veldina Activities:
_ The inspector observed nondestructive examination and welding activities in progress in the ongoing construction program. Inspections were being
, performed by Nuclear Energy Services (NES) and Kaiser inspecters with
- j. overview by CG&E inspectors.
Welding in progress was observed to conform with the applicable weld
, procedure specification (WPS). Nondestructive examination (magnetic particle) was performed in accordance with the procedure (NES-MT-80A3887, i , Revision 2) by Level II magnetic particle inspectors.
The following welding and NDE activities were observed while in progress:
- a. Wald MK P-138 to MK 222A; KE1 foru Number A10197; Dvs. 5466, Revision P; Weld procedure 3.1.51 Revision 4; Wald material E7018 heat Number 412N-5381; and fit-up and magnetic particle examination (!fT) of the root and every 1/4" to final weld pass. The MT was performed by a NES Level II ffT inspector in accordance with procedure 80A3887, -
Revision 2.
. .t ,
e
- 9 .
I i _. . . . _ _ _ . ___ . _ . _ . _ _ _ _ .
b .* Weld sein Steam Line 1M5078B12 to Lug D at 489' level, 7' azimuth
(
within the containment vessel; applicable drawing was PSK IMS-23A; and weld procedure specificati ns SPPM 3.1.28, Revision 1, and SPPM 3.1.12, Revision 5. The inspector observed magnetic particle examination (MT) of the final weld. The examination was performed ;
by a NES Level II inspector assisted by a Level I inspector. The . I applicable procedure was NES-80A3887, Revision 2, MT sachine Number )
3622 sith calibration sticker indicating due date of September 8, l 1982, was utilized.
- c. The inspector performed in-process weld surveillance inspection for fit-up, tacking, weld procedure specification (WPS), welder qualification card, identification of material being welded and welding satorial withdraw card containing the appropriate infor-nation, and observation of welding in progress to conform with the referenced WPS welding variables such as: preheat and inter-pass tesperature; welding rod size and welding position; electrical characteristics; welding progression; interpass cleaning; and the welder's ability to make a visually appearing sound weld. The hanger being welded was Number 1MS4655R and was being welded to the pedestal band using procedure WPS 3.1.81, Revision 5. The hanger located in the suppression pool elevation 490' 1", azimuth 354
- f l No items of noncompliance or deviations were identified. ,
- 3. The following veld forms (KEI-1s) were reviewed for adequacy of
( information, adherance to procedure requirements, and completion of
. the required NDE in accordance with the approved procedures:
- a. KEI-1 form 25435, weld number K72, radwaste floor sump drain, ASME Code Class II (NC), 2.5 inch diameter pipe: The applicable isometric drawing was PSK-TR-1 and the weld procedures used was WPS 3.1.7, Revision 3. The weld material specified was E705-2, 1/8", and hsat number 77402.
- b. KEI-1 form A8466; weld Number MS-K-827; Main Steam 2.5 inch diameter pipe to elbow: The applicable isometric drawing was PSK-MS-14 and the procedure used was WPS 3.1.7 Revision 2.
Weld material specified was E703-2, 1/8", heat Number 77402 with insert heat Number 6059491.
- c. KEI-1 form A8013; weld Number K88 radwaste floor sump drain; Code Class II; 2.5 inch diameter pipe. The applicable isometric drawing was PSK-RE-1 and the procedure utilized was WPS 3.1.7, Revision 2.
The weld material specified was 1/8" E705-2, and heat number 77402 with insert heat Number 6059491.
- d. KEI-1 form A11265 and A11266; welds Numbers T1 and T6 and T7 and T8; l hanger Nur.ber 11H091; electrical conduit support, Class 1 essential.
The weld was a 1/4" plate to 1/2" plate; drawing E-189-10, detail 2; i ,[ . procedure WPS 3.1.51. Revision 4. The weld,natorial was E7018, j ,
3/32", and heat Number 412P5132.
b e 10
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- i. . . _ _ . . . . _ _ _ . _ . _ _ . ___ _ . _ _ . . . _. . ,
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~
The review provided by the licensee of the KEI-1 forms A11265 and
( A11266 appears to be in violation of Kaiser's procedure VIP-7, l Revision 0, Welding control, paragraphs 4.1.1 and 6.1.2. The forms were not made out nor reviewed by a construction welding engineer, but were prepared and signed by former clerical personnel with training provided by welding engineers. This ites was dis-cussed in the exit interview with cognizant contractor and licensee representatives who agreed to pursue this matter within their organizations to determine that the capabilities of the persor tel
. now issuing and signing KEI-1 forms are adequate to meet the intent of the procedural and regulatory requirements regarding necessary skills required to ensure control of special processes. This item x is considered unresolved pending review of the licensee's actions and further evaluation of personnel qualifications by the inspector (358/82-02-02).
No items of noncompliance or deviations were identified.
- 4. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of non-compliance, or deviations. One unresolved ites disclosed during this
. inspection are discussed in Paragraph 3.d of thisSection III of the -
report.
- 5. Exit Interview
~
( The inspector met with the licensee representatives (denoted in paragraph 1 of this report section) on February 25, 1982, and summarized the scope and findings of the inspector activities. The licensee
.' acknowledged the inspectors findings.
- l l
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g NIE8Esas PERFORMANCE EVALUATION ,
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! Ot*T/ pgapoemanct gup6cvtt pc aico no. omaoc posmo=mT6 oivision swe6cvttwaws ,
,,,, 4-15-E2
- l Worley O. Puckett 1-160 E7 Senior Engineer Weldint '
4-1-23 vvec op sva w avion D a==aac D ev-sa eu 9/.4 OUTIES PERFORMED NOT LISTED ON WORK PLAN N/A DUTIE5 LISTED ON WORK FLAN NOT PERFORMED
^
N/A
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AUde- i w"*a oYs- *IobInt- No"a t- sv Edl=c **""'"'S '
PERFORMANCE CATEGORIES ASLE mtNT ME=TE Mt=TE PROFESSIONAL / X I TECMNICAL SKILLS
( 2 suv0WLEOGE Or WORK X 3 AUALITY OF WORK X i Always willing to p' erf orm 6 4 GUANTITY OF WORK X accept additional duties.
_t ~ COST AWARENESS y .
4 OEPENOASILITY X ife ia S i nt 7 INITI ATIVE/FLEXISILtTY X 8 SCNEOULE AWARENES$ X PROJECT TEAM I 8 EFFECTIVENESS V tive always le COOPERATION y wffingcocerfelpo,thers.
o i
l Il CLIENT RELATIONS X i w l l
12 RESPONSE TO SUPERVISION X 13 vE,RS,AL gg g yy COMMUNICATIONS y I0 WRITTEN COMMUNICATIONS ASILITY I 15 PLANNING X
~
16
$ OELEGATING X g ,s .
17 .d 0 CONTROLLING X
- g*r '
g SUSO RDIN AT E '
( gg DEVELOPMENT X a #
gg ATTENTION TO ,
EECIA A* I l 20 OvtR ALL EVALUATION y4 I Onoca
- HK000033 i 1
EVELOPMENT PROGRESS DURING EVALUATION PERIOD: ,
( su) ring this past year Mr. Puckett has improved tremendously. He attended Seminars such as Maintenance Welding in Nuclear Construction and Repair Walding of Pressure Vessels. In cddition, he attended an inhouse course entitled Welding Inspection and Quality Control and hrs passed all examinations with excellent marks and consequently received certification '
from AWS and ASM including 5 CEU's. The knowledge obtained from the above described Semi-n:rs/ courses has helped Mr. Puckett in the following areas:
. 1. Code applications.
- 2. Procedure preparation.
- 3. Interpretation of Code. Standards and Specification requirements.
- 4. Practical application of Welding and NDE processes.
N MAJOR DEVELOPMENT NEED5:
Mr. Puckett needs to 3 assume a supervisory position in the Welding Department. Courses in Management Applications. Cost Engineering including Scheduling and Proposal Writing Tcchniques are desirable.
i DEVELOPMENT PLAN 5:
As soon as possible, Mr. Puckett will be included in an inhouse Management course taught by myself, which will include as a minimum, the above mentioned outlines.
Mr. Puck'ett will be placed in a supervisory position as scon as one becomes available, within the Henry J. Kaiser Company.
l EVALUATING SUPERVISO R: MX8 M ^ I Date: 8* d *88
. REVIEWER: II M^ Date: O I J J" 1 fr smPtovsas commaNTs: )
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/if4Esas PERFORMANCE EVALUATION EMPLovrE OtpT/ PC A F on t.a s.s:r E*.*pkovtE N AME No, GRADE PoSITeoN/ TITLE Div tSloN - PC R ICD 77Y7 ,AoM.10-5-81 W. O. Puckett 1-160 E7 Proi. EnE./Suot. Weldint ;o' 4-15 Tyrc or tvaLuAveoA @ ANNUAL 0oT-ca ev M -
i DUTIES PERFORMED NOT LISTED ON WORK PLAN -
4
- DUTIES L!5TED ON WORK PLAN NOT PERFORMED .
N*
t 1
i NoT NCros utETS EXCEEDS o gy.
PERFORMANCE CATEGORIES *** se- i'
- s m o v t. nrouime- arouinc. sTAmoiNo C **'***
ASLE MENT MENTS MENTS
- i g
PROFESSIONAL / Needs more exposure to TECHNICAL 5 KILLS X nroner ende internratiane.
KNOWLEDGE OF WORK X See (1) above.
4
( ., QUALITY OF WORK X-4 QU'ANTITY OF WORK y [ghjgj3Ohggfg W lhgIj{.
l' 5 COST AWARENESS y i .
i 6 DEPENDASILITY g 7 INITI ATIVE/FLExt BILITY g 8 SCHEDULE AWAREHESS g
- PROJECT TEAM I X
= EFFECTIVENESS several reports indicate 10 COOPERATION y that more cooperation is re-quired.
11 CLIENT RELATIONS X Needs better verbal & writte i 12 RESPONSE TO SUPERVISION X Se hfab 12; y,R% g COMMUNICATIONS y g,, (gy) ,ggy,,
WRITTEN COMMUNIC ATIONS 14 X AsiLivy See (11) above.
i 4
15 PLANNING y 16 DELEGATING X g ,J I
ia
$ y CONTROLLING X-j ,
{* SUSO RDIN ATE 3 DEVELOPMENT X -
gg ATTENTION TO EEO/A AP X 20 OVERALL EVALUATION X HM000035 D!T 003 r
, _ ~ . . -
, - . , . , - - _ _ ,. . - - _ , _ . . .~ . . _ . .. - . - _ _ _ _ _
._ . . . . . .. . . . . . . . . - - - - , . .. , , . - .- . . _ . ... .~ . . _
DEVELCPMENT PICv27.E55 DU '.lN3 EVALUATION PERIOD:
Mr'. Puckett is beginning to understand the requirements necessary in the construction of Nuclear Power Plants. Through no fault of his own, being the only Welding Engineer on this oject and consequently overworked, several major violations of codes and specifications
( .esulted. It is further understood that, if he brought major problems to the past Project Manager, these problems were never acted upon. His actual technical abilities meet all requirements. -
4'
- i j MAJOR DEVELOPMENT NEEDS:
Mr. Puckett needs to learn the proper applications of codes and standards in the construction of Nuclear Power Plants.
DEVELOPMENT PLANS:
As soon as possible. I plan to have Mr. Puckett attend Seminars dealing with the applicatio'n
~
codes and standards. In addition, a new Project Welding Engineer, who's knowledge of i
Aes, standards and technical applications is excellent and will help Mr. Puckett tremendous-ly.
EVALUATING 5UPERV150R: AP-/M.9 I M " # f Date: 4'*/ f" 8 2 MM '
~
r:EviEwtR: ~~ [
Dete: PV*TL EMPLOYEE S COMMENTS: I concur with my evaluation and it is my hope that I will have the cpportunity to attend Seminars to better my knowledge for present and future assignments with Henry J. Kaiser.
ruecover, Iib 3. ._ n . Qu L . . m svatover m'o., I-I hn o.t., k - e a - R P_
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CONRDENN surtover s wasTr= pcasemmet nut H@000'.'36
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. - ~ -
. INTER OFFICE MEMORANDUM AD ~%3,M~
Ti: Don Billcr - Mansg2r, Paracnn21 DaTE: April 20, 1982 af : Moscow. Ohio l
, , enou: Manfred L. Goedecke -
Project Welding Manager !
.omasto
( .
l at: Moscow. Ol}io l Jos no. 7070 ___
susJact : PERFORMANCE IVALUATION OF W. O. PUCKETT. l It is necessary to document and clarify numerous considerations which have l
' been germane to the Perfonnance Evaluation of Mr. Puckett. In this regard, the requirement for additional information and supporting clarification re-lative to the subject evaluation varrants the writing of this letter.
On October 5, 1981. I assumed the position of Project Welding Manager at the Wm. H. Zimmer Nuclear site. During my first week, which I dedicated to just ,
observing the welding operation, it was readily apparent that the inplace.
IL7K Welding organization (which consisted of one Welding Engineer. two en-gineering aids, and one clerk) was in dire need of additional qualified per-sonnel, primarily Welding Engineers. A proposal was developed, presented to l the Project Manager, and was subsequently approved. The proposal was for i expansion of the Weld Engineering Organization. During the reorganizational.
process Mr. Puckett continued to direct the department with very little in- ,
put from myself. I greatly appreciated this convenience, for I found it nee-essary to continue in the role as an observer in order to properly reconstruct and develop the required organization. My reorganization efforts are, at this f
time, being concluded. This reorganization is now directly involving Mr. Puckett.
\ In this regard, I would like the following pertinent facts to be placed on Mr.
, Puckett's. record.
- 1. Mr. Puckett is an exceptionally industrious worker.
- ._ 2. Mr. Puckett has developed and fosters a very good rapport with all individuals who report to him.
- 3. Mr. Puckett's attitudes and responses to guidance and super-vision from his supervisor within the Welding Department (i.e. myself) is, for all practical purposes, faultless.
- 4. Mr. Puckett's ability, knowledge, and understanding of general welding methodologies and techniques is exceptional.
CONVERSELY. HOWEVER;
- 1. Mr. Puckett has, on occasion, experienced some degree of dis-sention with supervisory personnel of other ILTK departments and the client.
- 2. Mr. Puc'kett, because of the extensive workload that he has handled since 1979, has not been able to keep up with the fy'%._l '
state-of-the-art in the field of Nuclear Power Plant con-struction requirements, especially in the field of welding. ihyy flTI!
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. PERPORMANCE IVAIUAI i 0F W. O. PUCKETT April 20, 1982 Prg, -2
- 3. Mr. Puckett, because of his lack of up-to-date education applicable
( to welding.of Nuclear Power-related systems. is on-the verge of losing credibility and the fespect of his peers in the Welding and Quality Assurance Organizations. .
In consideration of the preceeding facts and evaluations. I have deemed it necessary to laterally shift Mr. Puckett out of the position as Project Weld-ing Engineer. 'I realize Mr. Puckett may take exception to this move, as he may consider it a form of demotion.- It- is not to be considered a demotion in any sense. I expect Mr. Puckett to benefit from this reorganization in the following ways:
- 1. Mr. Puckett will have a "well-deserved breather" from the ,
extensive mental and physical pressures which he has so adequately addressed himself to, when he assumed those re-sponsibilities in 1979.
- 2. Mr. Puckett will be able to bring himself up-to-date with the current status and requirements of the Nuclear Power Plant-related codes and standards.
- 3. Mr. Puckett will be able to observe, first hand, the application of the current Nuclear-related codes and standards, and will immensely benefit from the experiences and approaches implemented by his peers in the Welding Organization. '
. In summary, it is my opinion that Mr. Puckett has discharged his duties since 1979 in a superlative manner. Mr. Puckett has demonstrated an exceptional
( administrative ability and has shown promising higher management potential.
In this regard, it is of great advantage to all concerned (especially Mr.
Puckett)~to effect the subject organizational change so that Mr. Puckett may have the opportunity to improve himself in the areas shown on the subject Performance Evaluation.
ws./.Saeo6c -
Manfred I. Goedecke Project'weldir7, Manager 4
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INTER-OFFICr MEMORANDUM To : Geri Keegan DATE: October 29, 1981 AT Moscow, Ohio FRou M. L. Goedecke
( -
COPIES TO AT : Moscow, Ohio ,
aos No. 7070 susacT : Salary Adjustment.
Dear Geri; -
Please take the appropiate action required for the adjustment of Mr. W. O. Puckett's salary.
The increase, shall be 10%, effective October 16, 1981.
Sincerely, .
nA)./.&YC Manfred L. Goedecke
( Project Welding Manager MLG/jrt HK0b0039 euKCO 189
~
EMPLOYEE h.AFORMANCE APPRAISAL AND DEVs. OPMENT PLAN !
- l Postf ooN TIT 6L oEFr. PEEFGkMANCE PEstgoo EMSL.OVEE NAME C eh;e4 s'c\d'n3 RW W'ocles h c ke +t a c,. m :r e q ,,.m '1-l-EO v. 5- I- 1I PERFORi4ANCE PROFILE: (Check the factors below and state the reason for each rating: 1 . OUTSTANDING 2 - EXCEEDS REQUIREMENTS, 3 - MEETS REQUIREMENTS. 4 - MEETS MINIMUM REQUIREMENTS, 5 - UNSATISF ACTORY.
NOTE: Before you twgin your appraisal, turn to the reverse side of this page for en explanation of the' procedures. Contin.ie to refer to these explanations as you pe, form your appraisal.)
1s 2a 3 a's 5 REASONS
. .o guc a u .,, r-
- 1. KNOWLEDGE OF WORK F 8 88 7 9 88 d. he.s la 49 at eA w e s.st 6 5 3 e o gM, as.s.e T' e v
- T + a 7 v *-
- 2. QUALITY OF WOR K m e#9e6rrs e,p K*a q v e a se ,*r e .v ras #
m as s't # ar #1 n ,, 3 Tde d'-
'/, =3's
( * *' Te88 *'e' K 78 ,F"2 at" fa'dt'd's- ef // E7s y s e e d*e"Pr d's .cd t
- 3. QUANTITY OF WORK ,
e .=r a. . . r. ,- -
se e d 's , vi e. ele ,eg,.e ysepa m ,wy n e ag,,,.g ,,,,,.,
- 4. INITI ATIVE/PLEXI58 LITY FAe r o.e d.de sa re s .u c e.o.a r.s z o .so f ~rs, e poc o s f,,ap ,s,,, p,, a .
3 esrsq .A vs2 d'. /s/ ,p m A. 4
- s. COST COnsCIOU$ NESS 3 m es e. T- r. so e l 113 aus.c=#s ,,,vs.v ?"5 -
i S. MANAGERIAL 5 KILLS 3
A. PLANNING J,.
. B. DELEGATING 2, C. SUSORDINATE DEVELOPMENT
)
OVE R Al.l. EVAL.UATION 38)
( ATTENDANCE: PUNCTUALITY: ATTITUDE:
" Satisfactory
- @ Satisfactory Satisfactory I I Needs improvement i i Needs improvement i I Needs improvement it. DEVELOPMENT PROGRESS: (Describe employee's progress since his/her last appraisal, or date of hire if new employee.)
~ Vo et f(oy a t. lo a) T* A'0'3 3 's"*
f e fw't. b as &2of Got el SU Ys A.T Ss h a free Y o e lij .
lit. MAJOR DEVELOPMENT NEEDS: (Describe performance areas which the employee should concentrate on improving during the ensuing 612 month interval.)
so c g (a y Zls e.s{r( e e .s.* 7"# =s/ */ ** "/*'# * *'""' 1 b # d N l** ST 0 'O
- u) a (t[o ns*J fot($y .JAeat k Soal{ l'?r fM t " bea C b o94/r 5 3 t$.q',, s94,/sp og/cossey,gr gjy' s ou foT*.*esm 4 4 s a y av *'s n .ns T .s .
IV. DEVELOPMENT PLAN: (Prepare jointly by the supervisor and employee during counseling session - Describe actions to be tamen to accomplish performance improvements shown in "Ill" above.)
- l (If more soace is needed to properly expand upon any af the aboye points. attac,h a "Supolement"page.)
, .ovNsEL o aY oATE APPRovEo o f g a ATE EMPLovEE SIGNATURE e oATE
. 6 * !' W > tY Ja. o -- . c [ 0 Q [ *Emeiovee meQtteen comments.
co*v tt) *ERsoNNEL oiv. copv m sveEnvison co* 13t Eupt.ovEE HK000040 ro aa 'o-55 "<v 22 m i
1
- PURpWE 1 he purpose af tas appreened is to rdiscuss with you empseyse how he/she b doing with roepect to performence in P ther p
- if strength and nstees e ere perfirmanca con se enould be improved. The emp6ovee wants u know. eral deserves t be honest erus descuss performance with him/her,. In this wey reos growth and dewetopment can tete g;tecs.
. sthemanager'sreasonesility and ob l igstent o ' -
o,formones e,ofiis - Deser.isen .f Nume,iesi Reunes and P.se.re y
portance of each perfo,,Dence fec,o,in ,e et.on to owe,e
,I iob ,soui,e,nents and in .
or the empio, be,ng ev.iust.d determ.ne the ,s.et,ve esproprete cosumn sesign a numereces reting which most accurately reflects the empoovee's performence for each performanc
- 1 IgUMERICAL RATINGS
, i Performance is ceserfy besow the saceptable lowel. Conesent supervision is needed. Work 5 UNSATISP ACTORY , l is genereely lacking in thoroughnees,sceu ecy and coassetency of job reevirements.
Performanos comes stoes to being setietectory, but need for further devoteement is rec.
4 MEETS MINIMUM REQUIREMENTS ogniashie. Considerable supervision is needed; work is best accomplished with detailed ;
instruction. Indevidual is still learning the job. .
)
Performance is entiresy entisfactory and acceptable with respect to requirements of job )
3 MEETSALL REQUIREMENTS being performed. The autes are being performed as espected. but not in any wey con.
salered onceeding the job .w-. 4;s. The employee has seined sufficient knowledge and esperience about the duties and responettilsties of the assigned cleosification to per.
form them proficiently and with a menenum amount of supervioon. This reting mes,ns good performance of the job. . .. ,
This esould include the rneior porten of the work force in most organisations.
t Performance is consistentfy above the setisfactory stenderd required of the position. '
2 EXCEEDS REQUIREMENTS Employees in this category demonstrate sustained high feweis of performance over e substantial pefied of time. demonstrates instistive in sueuming more responsibility, de- .
welops irnproved methods, producing high guelity and volume of work. Only occasion. .
sily reemros swork direction.
Performance is exceptionel in all respects: estraordinary volume of work completed. -
f ' OUTSTANDING ouelity is consistently highest levet, judgement con normally be depended upon in elf gob
- ro6sted situations. Empseyee's performence in the job duties cleerly demonstrates stand-erds that for emesed those required. Other employees recognise competence of this em-04evee and look to this employee for guidance.
'You may wish to use a "+" to indicate high performance withiN the levet or use a " " to indicate low performance wrthen the level.
{
FACTOR $
- 1. Kne=4edes of Work - Dorn to which employee knows the "venet","how", and "why'* of the position in relation to the position reovire-fDents.
- 2. Queisty of Werk - Degree of thorougnness, accuracy. completeness,n and press' tability of swork echieved in the performance of the job.
- 3. Quentity of Work - Degree to which volume of work is consistent with the needs of ion being performed.
- 4. Instietsve/Pleesbelsty - Degree to whicn individual demonstrates ability to ediust to varied or changed conditens; learning new tasks, actect.
irig new responsibilities; es well as ability to indeoendently pursue end accomplish obloctives wnech are not subsect to other then norma superwisson. Origeneisty and irulependent action displayed in completen of assignments. 1 l
- 5. Cast Coveciousness - Degree to which erfoloyee effectively utilizes the Company's essets to accomplish the roovirements of the job in une j most deller of f acient menner, l Sw Managerial Skills - Degree to which employee is able to meet the requirements of a position in which it is nessesary to menage other em.
p4oyees. e particuler function, or both through the use of eweluative. enelytical and decision making processes.
A. PLANNING - Degra to which empiovee effectreely enticostes the need for sad uses Company resources that will impact accomolish.
enent of the 3ce. Ability to entic.ete end solve prob 4 ems. Ability to set pesorttes.
- 3. DELEGATING - Degru to which empiovee is able to effectively assign / delegate authority and responsibility to subordinates. Cooecity l to motwete staff.
C. SUBORDINATE DEVELOPMENT - Deg ee to which emotoyee recognizes the potential abilities of subordinates and develops same in order to prepare subordinates f or advancement opportunities.
II. Developenent Progrees Describe empicyee's progress since his/her lost oppreisef, or date of here if new employee. ,
Meger Deve4opment Needs Describe what oddstional knowledge and skills would enable the employee to perform his/her job with greater effectiveness.
IV. Development Plan Deser what you end the employee plan in terms of specific actrvities (i.e., courses, seminers) for development of the smoloyee in his/her present position and/or possible future poortens. ,
yr HK000041 1
_ __ ,_ _ _. _ . _ , ___.___l
EMPLOYEE riRFORMANCE APPRAISAL AND D,EhLOPMENT PL Q.
. EMstOVEE Nf.ME POSITICN TITLL DEPT. k EMFoxM AN.E s EssioD
[ Prom / f To
- 1. I PERFdlLMANCE PROFILE: (Check the factors Mow and state thNeesoMor each rating: 1 buTSTANDING.2 ' EXCEEDS
( REQUIREMENTS. 3 - MEETS REQUIREMENTS. 4 - MEETS MINIMUM REQUIREMENTS. 5 - UNSATISFACTOiW NOTE: Before you begin your appraisal. turn to the reverse side of this page for an explanation of the procedures. Continue to refer to these explanations as you perform your appraisal.) ,
1a 2s 3e 4a 5 flEASONS
. W M Ee 8 WM ,e
/ 462 ed
- 1. KNOWLEDGE OF WORK f, unades Tsat ody ese ;e6 Mysec asersm .
- 2. QUALITY OF WOR K Vadf Y4888 9 k seawd 4te s/4 4 74,
- 3. QUANTITY OF WORK t/E
- f d'a d dF # T"A *W f~ f'# #*' *4 ' C
'*' [#'8###O d N **
- 4.INITIATivt/FLEXIe LiTY p 7, 7[hD.f4$i,'*M[r[#cs,% NIM ,ss-
=r% e n%a s=u e.
$. COST CONSClOUSNE SS &,Y , ,f'k'Y hoer ? ! y$e~r f 6 W h f$d4 *
- 6. MANAGE RIAL $ KILLS , , se [hh a M , ,, y[,f k[r[" ,
2% , r. nn on A A. PLANNING p g,
- 5. DELEGATING p gf E' SUBORDINATE DEVELOPMENT h i/ l OVERALL EVALUATION [
ATTENDANCE: PUNCTUALITY: ATTITUDE:
[ HSatisfactory @tisfactory Mtisfa'ctory I i Needs improvement i I Needs improvement i I Needs improvement
- 11. DEVELOPMENT PROGRESS: (Describe employee's progress since his/her last appraisal. or date of hire if new employee.) .
_ y) e e. { n ce stro d.tos s To ort n * */Y~** * 'r! A bef $ *hdo!Cf # N l*'5 7'E'I '
4l(FF* <
- se e y * ** I!' * " ' ' ' * * ' ' ' O *f *'"' ' Y Y~
Ill. MAJOR DEVELOPMENT NEEDS: (Describe performance areas wnich the employee should concentrate on improving during the
, ensuing 612 month interval.1 (o.st7"oa ou n 'To d% p-e*s( hse 7 lE'sl( 4 ** ho t' @ses.e.u Y !!b fe a 'Ttesu s
f< oEp e, h at son. l f A se. se d.e.as<r**P" d7~ w ad* Mo n rq Vs
- s o e. s T ss re c.,
orin o r e a. ort 94 va rro.*** .
IV. DEVELOPMENT PLAN: (Prepare jointly by the supervisor and employee during counseling session - Describe actions to be taken
, to accomphsh performance improvements shown in "Ill" above.)
% n e n. ss 4 s a + $ e I o Ty Th T* sd o c{n.1 Ws f( b4 9 s *'* d M '*' W # #' T' W U *1~ s i e s. c kss R LoleTen.s n.u[, s hell.a o =J
- T'N " !- 192o45 B f Blhe k e (If more space is ne6ded to property expand upon any of the abow points. stroch a " Supplement"page.I "COUN5 ELE av ) DATE APPROVE DATE EMPLOYEE SIGNATURE
- DATE
- $hW O (Z,s . ' En -w G * *2. 4 * $n"'
M [
- Employee may attaca comments.
i COPY (3) PERSONNEL DIV. COPY (2) SUPERVISOR COPY (3) E PLO EE 0000M 'o a" 'o 5 2 "<v 2 2
- PURPOSE a
he purpose tf th'3 amoreisel is theecues with your employee how he/she io doisg with respect to performance in hie /her present position, o i f strength end stees where performanc3 can of should be improved. The employee wents u know, and deserves to know, wh*t his/her p rJee manager's responseility and ooigetion to be honest and (incuss performanc) with him/her, in this wey feel growth and development can
- 8. Perforsenense Profile - Deseription of Nesmeriest Retings and Posters at tfie employee beeng evenuated determine the reietsve importance of each performance factor in reistion to overeft job reevirements and i
( .apropriate co e ven een.pn a numerical reting which most accuratety reflects the employee's performance for each performance factor.
g8UMERICAL RATINGS Performance is cleerfy below the neceptable level. Conetont weervision is needed. Work 4 S UNSATISFACTORY -
is generally lacking in thoroughness, escuracy and consistency of job requirements.
Performance esmos cloes to being entiefectory, but need for further development is rec.
4 MEETS MINIMUM REQUIREMENTS ogniasbie. Cormederable 1 .. r. Is rimodsdi work is boot escomplished with detailed lanruction. Individual is still learning the job.
Performones is entirely estisfactory and ecceptable with respect to requirements of iot 3 MEETS ALL REQUIREMENTS being performed. The duties are be no performed as esoected, but not en any way con.
essered escoeding the job W..nnts. The employee has gained sufficient knowedge and esperience shout the duties and responsibilities of the assigned classification to per.
4@g form them proficently and with a minimum amount of supervision. This reting means g . good performeamt the ia . ...
This would include the maior portion of the work force in most organizations.
h Performance is consistentty above the satisfactory etendard required of the position.
2 EXCEEDS SEQUIREMENTS Employees in this category demonstrate sustained high levels of performance over a
, substantial ' period of time; demonstrates initiative in assuming more responsibility, de.
setops improved methods, producing high euelity and volume of work. Only occasion.
elly reevices work direction.
OUTSTANDING Performance is exceptional in elf respects; entraordinary volume of evork completed,
- 1 queirty is consistently highest level, judgement can normally be depended upon in als job ,
reisted situations. Employee s performance in the job duties cleerty demonstrates stand- ,
ords that for encoed those required. Other employees recognize competence of this em.
' piovee and look to this employee for guidance.
'You may wish to use a "+" to indicate high performance within the level or ues a " " to indacete few performance within the level.
ACTORS
- 1. Know6 edge of Werk - Degree to which employee knows the "what","how", and "why" of the position in relation to the position require.
, monts.
- 2. Questry of Work - Degree of thoroughness, accuracy, completeness, and presentabilsty of work schieved in the performance of the job.
1 Quentrey of Work - Degree to whch volume of work is consistent with the needs of iot being performed.
- 4. Instaetree/ Flexibility - Degree to which individual demonstrates ability to adjust to varied or changed conditions: learning new tasks. eccept.
ing new responsibilrties: as well es ability to indeoerufently pursue end accomplish objectives which are not subsect to other than normal ,
weervis.on. Originedity and independent acten dispreved in completen of assignments. l S. Cast Connesouenssa - Degree to vehich erreloyee effectrvely utilites the Company's essets to accomplish the requirements of the job in the j most dotter effeient menner.
O. Managersel Skille - Degree to which employee is able to meet the requirements of a position in which it es neceanery to manage other om.
pioyees, e particuler function, or both, through the use of evolustrve. onelytical end decision meking processes.
A. PLANNING - Degree to which employee effectively anticipates the need for and uses Company resources that will impact accomplish.
. mont of the job. Abilety to entacipate and solve problems. Ability to set priorites. .
{ B. DELEGATING = Degree to which employee is able to effectrvely assign / delegate authority and responseility to subordinates. Ceoscity
! to metrvote statf.
l '
C. SUSOftDINATE DEVELDpMENT - Degree to wnich employee recognises the potential soisites of tuoordinates and develoos same in order to propere subordinates for anvencement oooortunaties.
l II. Devoteement Progree Describe emo4oyee s progress since his/her last sporeesel, or date of here if new employee.
Ill. Maper Developmeant Ne'ds e -
3escribe what additeonet knowledge and skills would enable the employee to perform his/her job with greater effectiveness.
[ ,
IV. L ,
.; Plen -
Descrite what you and the employee plan in terms of specific activities (i.e., courses, seminers) for development of the employee in his/her l present position and/or possible future po*%
~
si 48 ) i l
HH000043 6_
MANFRED L. GOEDECKE hf MANAGER OF WELDING AND METALLURGICAL ENGINEERING DIRECTOR OF THE NPS TECHNICAL INSTITUTE .
EDUCATION Graduate of: ,
Welding & Metallurgica! Engineering, M.E.l. (Diploma) <
~ Plumbing /Pipefitting (Journeyman), AFL/CIO UA. Washington, DC Machinist (Journeyman), AFL/CIO lAOM Washington, DC Trade School Saarbruecken (Germany) Ornamental tronworks & Welding' Successfully completed the following certified courses:
NUCLEAR TECHNOLOGY A) CRD Maintenance - For Bolling Water Reactors B) MSIV Maintenance - For Bolling Water Reactors C) Recirculation Pump Seal Rebuild - For DWR's D) ISI of Nuclear Power Plants per Section XI MANAGEMENT TRAINING A) Management Workshop B) Middle Management Development .
C) Effective Management D) KST Management Seminar
( PROFESSIONAL LICENSES AND MEMBERSHIPS PROFESSIONAL AFFILIATIONS Member of ASME, ASTM, ANS, AWS, ASM, DVS, CCEU, and the New York Academy of Sciences.
PROFESSIONAL COMMITTEE MEMBERSHIPS ASME Section IX SC. General Requirements ASME Section XI WG. Repair Welding ASTM A-1 Steel Stainless Steel and Related Alloys ASTM E-10 Nuclear Technology and Application AWS General Education Committee CCEU Council of the Continuing Education Unit AWARDS & HONORS I ASM Honorary M.E.l. Faculty Member AWS Member Proposer Certificate Award CERTIFICATIONS ANSI /ASME N45.2.6 Level til, Mechanical Inspector ,
( ANSI /ASME N45.2.6 Level 111, Pump & Valve inspection and Maintenance ANSI /ASME N45.2.6 Level lil, Welding Inspectiorr Welder, Certified in SMAW, CTAW & OAW - Per ASME Section IX and AWS '
D1.1 R-4
EXPERIENCE i
( As Manager of Welding and Metallurgical Engineering at NPS, Mr. Goedecke i i
has over 20 years of related experience in metallurgical and welding
- engineering for nuclear, fossil, and other industrial and commercial
- facilities. He has written several publications and taught on the subject of welding and, metallurgical behavior for classroom instruction. He has served as instructor in the certification of welding inspectors per AWS and
_ represented the AWS as proctor in the actual examination of welding inspectors. Mr. Goedecke also initiated and qualified Heat Sink Welding Technology utilizing the automatic GTAW process.
N As Director of th'a NPS Technical Institute, Mr. Coedecke is responsible for the initiation and/or implementation of various technical publications. -
and training manuals for the nuclear industry. His most recent accom-pilshment included the initiation of numerous -training manuals written in strict compliance with inpo Guidelines which included the required job task analysis, completion objectives, and performance demonstra?!ons. The before mentioned training manuals covered the following inspection disciplines: mechanical, electrical, civil, and structural. In addition, Mr.
1 Coedecke is responsible for seminar presentations in welding, metallurgy, l codes, {ASME Sections 11, lit, V, IX & XI AWS D1.1, and ANSI B31.1) and failure analysis. ,
I, As Welding Manager for a large engineering firm, Mr. Coedecke was re-
- sponsible for the welding management and the establishment of Special
' Process Procedure Manuals that were required to provide technical and
( administrative requirements for a multitude of projects. Since all existing i
and new projects have historically required a different mix or aggregate in their objectives, the corporate SPPM was designed to accommodate these.
i aggregates (i.e. ASME, all sections including,Section XI, ANSI, AWS, API, Mil Spec, etc.) in Special Process Procedure requirements.
For Nuclear Projects, his general position description and specific authority and responsibilities were the directing and managing of all administrative and construction activities as assigned to the Welding Department; developing and implementing Welding Discipline construction schedules and interfacing with other discipline schedules; managing of field construction activities associated with the Welding Discipline; coordination
- and implemeatation of quality affecting programs as they pertained to the Welding Department
- coordinating of support services and activities from
- other departments within the Project organization; administration of perti-nent departmental subcontracts; utilization of reports and other control techniques as may be required to monitor progress and productivity and to identify problems and take effective action to correct or control said problems; and assisting the Construction Manager / Project Manager with j welding problems and work assignment interface with other disciplines.
Promoted to the position of Manager Technical Engineering, Mr. Goedecke
- was responsible for the managing of administrative and construction activi-ties.as assigned to the Mechanical, Electrical, Civil and Welding Engineer-
)! Ing Departments; developing and implementing of Project Engineering i
schedules and for interfacing with construction discipline schedules; j managing of field construction activities associated with the Engineering R-4
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. _ . _ .-_ _ _ _. . __ __ . _ . _ _ . _ ~ . . . _ . . - - - - -
f Disciplines; coordinating of support services and activities from other I
.( departments within the Project organization; administration of pertinent departmental subcontracts; utilization of- reports and other control tech-niques as required to monitor progress and productivity and to identify problems and take effective action to correct or control said problems. In ,,
i addition he provided, recommend resolutions to the Project Manager. for '
comples engineering problems and work assignment interface with the
- construction and Quality Assurance organization; along with all previous responsibilities as Welding Manager.
As Senior Welding Engineer / Specialist, Mr. Goedecke was responsible for the Welding Engineering effort for the North East Region of the General *'
Electric Company. This position was office oriented since it incorporated the whole N.E. Region. However, when it became necessary, he set up
, new projects, managed projects and provided supervision and technical -
- directions for Site / Project Managers.
His principle functions were to establish a welding program for the N.E.
Region, including all Section XI requirements of the ASME Boller and Pressure Vessel Code; provide schedules, specifications and sequence of installations for the modifications of systems in operating Nuclear Power.
Plants: request and provide adequate staffing to support project schedules i
and related activities; and provide sufficient direction, instruction, and .
I training, as necessary, to enable Welding Department personnel to perform in an effective and efficient manner.
( He also implemented and managed compensation and personnel programs
- within the department; monitored and enforced project and departmental
! . work rules: developed subordinates in terms of a comprehensive departmental
- plan
- developed an individual employee ' for potential discipline manager
- replacement; and developed inter-departmental schedules, goals and targets which were complimentary to individual Project Schedules.
As Program Manager - Senior Engineer for the Nuclear Maintenance Division of the General Electric Company , he performed support engineering for complex fleid-related tasks which required a high degree of technical skill, knowledge, and judgment. Responsible for applying engineering capabilities to the investigation, analysis and solution of problems relating to the installation, operation and maintenance of
. equipment and components in the assigned areas of responsibility.
Appointed Project Welding Engineer for the Detroit Edison Company, he was responsible for the final approval authority for all welding documenta-i 1
tion, plus all previous responsibilities as Project Welding Engineer / Super-j intendent.
Previously as Project Welding Engineer / Superintendent, he was responsible '
for the construction engineering effort within the Welding Discipline, in-cluding interpretation of the design documents and rendering technical support to assist the General Discipline Superintendents in monitoring the cont'ractors to assure conformance to design and applicable code require-ments. He ,provided the Construction Manager with recommendations on i
(* significant engineering and construction problems responsibilities of the Engineering Manager- in both technical and '
and assumed l l
administrative responsibilities. '
R-4 j i
1
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f Disciplines; coordinating of support services and activities from other -
( departments within the Project organization: administration of pertinent departmental subcontracts; utilization of -reports and other control tech-niques as required to monitor progress and productivity and, to identify
, problems and take effective action to correct or control said problems. In
- addition he provided, recommend resolutions to the Project Manaoer for -
comptes engl.neering problems and work assignment interface with the construction and Quality Assurance organization; along with all previous I responsibilities as Welding Manager.
As Senior Welding Engineer / Specialist, Mr. Goedecke was responsible for
- the Welding Engineering effort for the North East Region of the General Electric Company. This position was office oriented since it incorporated
! the whole N.E. Region. However, when it became necessary, he set up new projects, managed projects and provided supervision and technical directions for Site / Project Managers.
His principle functions were to establish a welding program for the N.E.
Region , including all Section XI requirements of the ASME Boiler and Pressure Vessel Code: provide schedules, specifications and sequence of Installations for the modifications of systems in operating Nuclear Power l Plants: request and provide adequate staffing to support project schedules j' and related activities; and provide sufficient direction, instruction, and .
training, as necessary, to enable Welding Department personnel to perform in an effective and efficient manner.
He also implemented and managed compensation and personnel programs within the department; monitored and enforced project and departmental i
. work rules: developed subordinates in terms of a comprehensive departmental
- plan
- developed an individual employee for potential discipline manager
< replacement; and developed inter-departmental schedules, goals and targets which were complimentary to individual ~ Project Schedules.
As Program Manager -
Senior Engineer for the Nuclear Maintenance t Division of the General Electric Company , he performed support j engineering for complex field-related tasks which required a high degree of technical skill, knowledge, and judgment. Responsible for applying engineering capabilities to the investigation, analysis and solution of 1 problems relating to the installation, operation and maintenance of i equipment and components in the assigned areas of responsibility.
Appointed Project Welding Engineer for the Detroit Edison Company, he
- was responsible for the final approval authority for all welding documenta-
! tion, plus all previous responsibilities as Project Welding Engineer / Super-intendent. ,
a Previously as Project Welding Engineer / Superintend'ent, he was responsible for the construction engineering effort within the Welding Discipline, in-l cluding interpretation of the design documents and rendering technical j support to assist the General Discipline Superintendents in monitoring the
- cont'ractors to assure conformance to design and ' applicable code require-( ments. He provided the Construction Manager with recommendations on f i significant engineering and construction problems and assumed
' responsibilities of the Engineering both technical and
- Manager - in j administrative responsibilities. -
i R-4 i
{
l His principal functions were to provide primary contact between
- contractors and the Owners Field Engineering and Design Engineering on all welding matters that arose in the field during the execution of the work; review requisitions for procurement of welding services, material and equipment necessary to support the Project Schedule; provide for loput of welding information for the estimating, planning and scheduling efforts; comm.unicate and cooperate with other Discipline Engineers in the
'l l parsuit of mutual responsibilities to the Project; review contractor and l ceft methods of accomplishing the required welding activities to effect in i tihe and money savings and meet schedule requirements; and resolve ,
ppblems associated with conflicting conditions, interfaces, constructability, I et. , as related to welding documents.
i n also provided recommend &tions for the disposition of DDR's which were rlated to welding problems; reviewed Contractors' Procedures and assured a the final approval authority, their compliance to applicable codes and secifications; and prepared, reviewed and approved DDC's, FEM's, RCI's ad DCN's.
A Welding Coordinator / Foreman for Stone & Webster, he was responsible fr the installation of all piping, supports, and components in the Reactor Ipildings , Units 1 & 2. At the North Anna Nuclear Power Station his eties included the assignment of welders to insure all welding was being (rformed per Procedures, ASME and AWS Codes, to inspect all welds hfore turning them over to the Quality Control Department for NDT f spection, and to act as a liaison between Engineering, Quality Control,
{, id the craft.
hevious experience includes the responsibilities as Welder, including all
' pes of Q-1 welding per ASME, ANSI, and AWS codes, to install all Q-1 ping per job specifications, and regulations; the responsibilities as
_. eneral Foreman, including the installation of water mains, pumping sta-ans, fire protection system, sewage disposal plant, drain systems, and te resolution of all general plumbing problems; and responsibilities as echanical Engineer - Piping, including the updating of piping systems to L -built conditions, including the design of small bore pipe for laboratory est equipment along with coordination between subcontractor and small ore t
- sign group.
ther exprience has included the position of Machinist Welder, responsible
)r all machine work, the repair of all types of machinery, and the re-
- bing of ans' welding of all types of boilers per Government Specifica-ons. Mr. Gtodecke also served in a supervisory capacity, responsible
)r the installa lon of all signal and communication devices, the supervision f pool lineman and acting as liaison and translator between American and
- erman military personnel.
.PECI AL CERTIFICATIONS
'rinciple of Failure Analysis, felding Inspection S Quality Control, -
1etallurgy in Welding & Joining,
/ ~ {t Elements of Metallurgy,
( Heat Treatment of Steel -
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