ML062000216

Transcript of Individual

ML062000216
Person / Time
Site:	Salem, Hope Creek
Issue date:	05/28/2004
From:	NRC/OI
To:
References
1-2003-045, FOIA/PA-2005-0194
Download: ML062000216 (60)

Text

1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE OF INVESTIGATIONS INTERVIEW

---

x IN THE MATTER OF:

INTERVIEW OF (CLOSED)

Docket No. 1-2003-045 x

Friday, May 28, 2004 DNNS Conference Room NRC Region I Office 475 Allendale Road King of Prussia, PA The above-entitled interview was conducted at 11:31 a.m.

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BEFORE:

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e 45.Special Agent:

Jeffrey Teator Information in this I lý AA1eieted in accordance th* *e Freedom of Information' Act, exemptions_

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2 APPEARANCES:

On Behalf of the Witness, 0

Jeffrey Keenan, Esq.

Assistant General Solicitor PSEG Services Corporation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 P-R-O-C-E-E-D-I-N-G-S 11:31 a.m.

SR.

SPECIAL AGENT TEATOR:

Today's date is lvay 2 8 th.

The year is 2004.

My name is Jeffrey Teator.

The time is 11:31 in the morning, and this morning I am interviewingI This interview's taking place in the DNNS Conference Room at the U.S. Nuclear Regulatory Commission, 475 Allendale Road, King of Prussia, Pennsylvania.

.)you're being interviewed today as a fact witness.

No one's accused you of doing anything wrong or participating in any deliberate misconduct.

But what I'm investigating are potential violations of 10 CFR 50.7.

The two issues I'm looking at are whether Kim Harvin's job was eliminated because she raised safety concerns, because she engaged in protected activity, and whether her last day at the site was moved up from April 16, 2003 until March 28, 2003, because she raised such concerns.

Those are the two areas I'm looking to talk to you about.

Do you have any objection today to providing sworn testimony?

WNo, I do not.

iJ NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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SR.

SPECIAL AGENT TEATOR:

Raise your 2

right hand for me please?

3 Whereupon, 5

was called as a witness and, having been first duly 6

sworn, was examined and testified as follows:

7 EXAMINATION 8

SR. SPECIAL AGENT TEATOR:

Thanks you.

9 This is a voluntary interview.

Knowing it's 10 voluntary, do you wish to go forward?

11 Yes.

12 SR. SPECIAL AGENT TEATOR:

Okay.

You're 13 represented by counsel today.

Jeff, if you could 14 identify yourself for the record please and explain 15 your representation?

16 MR.

KEENAN:

Yes.

My name is Jeff 17 Keenan.

I'm Assistant General Solicitor with PSEG 18 Services.

Today I'm representing and 19 PSEG Nuclear in a dual capacity.

20 I've reviewed the information relative 21 to Ms. Harvin's concerns and I don't believe there's 22 a conflict of interest.

If a conflict arises, we'll 23 take a break from the record and figure out how to 24 best handle that.

25 We do appreciate the ability to review NEALRI.GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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the transcript, if that's made available in the 2

presence of the NRC.

3 SR.

SPECIAL AGENT TEATOR:

And(

is 4

that your understanding of the representation?

5Y 6

SR.

SPECIAL AGENT TEATOR:

I have a few 7

follow-up questions for you.

8 Okay.

9 SR.

SPECIAL AGENT TEATOR:

Does your 10 employer require you to have an attorney 11 representing you when you're interviewed by the 12 Office of Investigations?

13 No.

14 SR.

SPECIAL AGENT TEATOR:

Were you in 15 any way threatened with any type of adverse action 16 by your employer if you did not request counsel to 17 represent you today?

18No 19 SR.

SPECIAL AGENT TEATOR:

Do you 20 understand that you have a right to a private 21 interview by me if you wanted one?

22 Yes.

23 SR. SPECIAL AGENT TEATOR:

Knowing all 24

this, do you wish to go forward with counsel 25 present?

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Yes.

2 SR.

SPECIAL AGENT TEATOR:

Thank you.

3 a little background. Your date and place of 4

birth' please?

6 7

SR. SPECIAL AGENT TEATOR:

Okay, and 8

your Social Security number?

9 M

10 SR.

SPECIAL AGENT TEATOR:

All right, 11 and your home address please?

12S 14 15 SR. SPECIAL AGENT TEATOR:

Okay.

How 16 long does it take you to get down to this site from 17 your house?

18 About less than 50 minutes.

19 SR. SPECIAL AGENT TEATOR:

Really?

20 That's pretty good.

21 K

" It's really quick, because 22 if you think about it, I just go right down 141 23 here, 141, and I shoot right across.

It's 42 miles.

24 SR.

SPECIAL AGENT TEATOR:

That's not 25 too bad.

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Yes, it's not bad.

SR.

SPECIAL AGENT TEATOR:

Which bridge do you take?

The Memorial Bridge.

It' s real easy.

'Now going home is a little bit can be a bit more exciting.

SR. SPECIAL AGENT TEATOR:

Okay.

That much more, huh, going home?

It could be almost --

sometimes it can be up to three hours.

SR. SPECIAL AGENT TEATOR:

Oh, oka Depending on what's g on.

Your home phone number please?

y.

oing SR. SPECIAL AGENT TEATOR:

Like tonight, it would have been about two to three hours?

Yes probably, with everybody shooting down 1-95, I guess, going over the bridge.

SR.

SPECIAL AGENT TEATOR:

Yes, right.

Your home phone number please?

Area code4.

SR. SPECIAL AGENT TEATOR:

Okay.

Have you ever served in the United States Military?

SR.

SPECIAL AGENT TEATOR:

What branch?

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 did you serve in the*

SR.

SPECIAL AGENT TEATOR:-

SR. SPECIAL AGENT TEATOR: (

SR.

SPECIAL AGENT TEATOR:

What was your highest qualification?

SR.

SPECIAL AGENT TEATOR:

In what?

SR.

SPECIAL AGENT TEATOR:.

Oh.

What's that stand for?

SR.

SPECIAL AGENT TEATOR:

Okay, all right.

Thanks.

You attended college?

Yes.

SR. SPECIAL AGENT TEATOR:

Which school?

Attended three --

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 different schools..

SR. SPECIAL AGENT TEATOR:

Did you get a degree from there?

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SPECIAL Oh, ý."

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~Yes.

SR. SPECIAL AGENT TEATOR:

Did you graduate from P

esN SR.

SPECIAL AGENT TEATOR:

What' s your degree in?

-m s R. SPECIAL AGENT TEATOR:

All SR. SPECIAL AGENT TEATOR:

That's quite a spectrum there.

It's a renaissance man.

It's what happens when you go to college and don't NEAL A. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 finish.

You get enough credits to be able to do anything you want.

SR.

SPECIAL AGENT TEATOR:

that's --

they have that. W*

SSure.

SR. SPECIAL AGENT TEATOR:

At some point were you hired to work at PSEG Nuclear?

Yes.

I was hired in' SR. SPECIAL AGENT TEATOR:

As?

They all have generic titles.

SR. SPECIAL AGENT TEATOR:

Okay, and what were you responsible for?

Which area of the plants?

-At that time, I was responsible for engineering reliability.

SR. SPECIAL AGENT TEATOR:

How long did you maintain those responsibilities?

Well then I assumed the broader responsibility of engineering technical services, which incorporated that as well.

So that was through October of 2003.

SR. SPECIAL AGENT TEATOR:

Your current job title?

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My current job title is 2

my position title is still the same, but the current 3

functional title is*0 5

SR. SPECIAL AGENT TEATOR:

So you got 6

ýNdown there?

7

Yes, I work with for 8

most of the time.

Yes.

was --

as a matter of 9

fact, had the office next to mine.

10 SR. SPECIAL AGENT TEATOR:

All right.

11 So from May '01 through October '03, who would you 12 have reported to?

13 MR.

KEENAN:

Through 2002.

14 Well I guess there were 15 two.

There were two.

) from my higher 16 date until he left the company at the end of March 17 of the first of, beginning of April in 2003, and 18 then ifrom 2003 to present.

19 SR.

SPECIAL AGENT TEATOR:

Okay.

In Kim 20 Harvin's letter to, dated March 25, 21 2003, she speaks of, on the first page of the 22 letter, halfway through the first paragraph there, 23 there's a sentence that reads "I have repeatedly 24 called attention to the lack of engagement and 25 involvement by critical leaders for nuclear safety NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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responsibilities, and had discussed these matters 2

with each vice president," and you're named there.

3 Do you recall her discussing those types 4

of issues with you?

5 I heard her talk about lack 6

of engagement, but I did not hear her talk 7

specifically to nuclear safety.

8 SR. SPECIAL AGENT TEATOR:

Okay.

In the 9

beginning of that paragraph there, it begins, and 10 I'll read it, "In my position as Manager, Cultural 11 Transformation I have repeatedly expressed a formal 12 and informal meetings and discussions among 13 management at PSEG Nuclear, that leadership 14 weaknesses, failings and inadequate attention to 15 employee-raised issues at our site is a matter of 16 nuclear safety.

17 "Beginning in about the spring of 2001, 18 at a weekly staff meeting convened bA 0_

19 where I point-blank stated this concern."

20 Do you recall her stating such a concern 21 during a spring 2001 meeting?

I know you acme on 22 board May '01?

23 don't specifically 24 remember an occasion where she raised those issues.

25 SR.

SPECIAL AGENT TEATOR:

At all?

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(

2)At all.

I remember her 2

only to some --

she did talk about leadership 3

weaknesses and failings, but not to inadequate 4

attention to employee-raised issues or to nuclear 5

safety.

6 SR.

SPECIAL AGENT TEATOR:

Okay.

How 7

about during any meetings you were present for --

8 P\\

That was in the 2001 --

9 that was not in spring 2001.

It was probably later, 10 because I met her --

probably it would have been in 11 the June-July time frame of 2001 was when I first 12 met her.

So it would have been in the summer.

13 SR. SPECIAL AGENT TEATOR:

All right, 14 okay.

During any meetings you were at where Kim 15 Harvin was there, did she voice any concerns with a 16 perception that there was a Production over safety 17 emphasis at the site?

18 I'm just trying to recall.

19 I mean, I don't remember her ever engaging in a

20 production over safety conversation.

I saw her 21 engaging more into employee engagement and their 22 ability to work together and function together as a 23 team.

24 That was what mostly she raised the 25 issues in, but it was not in a safety versus NEAL R, GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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production context.

2 SR.

SPECIAL AGENT TEATOR:

Okay.

How 3

about did she ever raise a concern or voice a 4

concern in your presence that people in your plant 5

were making non-conservative decisions with the 6

operation of the units, the Salem Hope Creek units?

7 1 never heard Kim raise it.

8 She typically did not talk about operational 9

decision-making.

It was mostly about interpersonal 10 relations and reactions.

11 SR. SPECIAL AGENT TEATOR:

Okay.

So in 12 your presence, did she ever voice or raise a concern 13 that she thought, or others thought, and maybe she 14 was being their mouthpiece, that there was non-15 conservative decisionmaking occurring inside the 16 plants?

17 No.

18 SR. SPECIAL AGENT TEATOR:

How about 19 this --

I know there was this.-

20 MR*on duty.

That C

21 issue did occur.

It caused some problems in the 22 Operations Department.

23 According to what I understand, Kim 24 Harvin became involved or was made aware of the 25 problem that issue caused inside the Salem NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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Operations Department.

2 Did she discuss or raise those concerns 3

to our attention, the ones that were brought to her 4

attention about how that issue happened, and how it 5

was viewed by the operators?

6 1: never heard her talk 7

about 8

SR.

SPECIAL AGENT TEATOR:

How about 9

what]did that night?

10 I don't recall her ever 11 saying anything to me about what

• .did.

12 She was working with the Salem NEOs during that 13 time, and that was her assignment.

14 She had transitioned from Hope Creek to 15 working more with the NEOs at that time.

So she was 16 involved.

But I don't recall her ever raising an 17 issue aroundrctions.

18 SR.

SPECIAL AGENT TEATOR:

When she 19 switched over to work with the Salem NEOs, did she 20 bring to your attention any concerns that were 21 brought to her by those individuals, concerns with 22 the --

23 MOM She just talked --

her 24 concerns were that it was a tough working 25 environment; that there had been --

that the morale NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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9 10 11 12 13 14 15 16 lb was relatively low in the group; that there had been that they were working a lot of overtime; that there was, you know, we had been growing through --

we had had the tough grassing season, and that's never in favor amongst the NEOs.

I mean, you go down there and pick tubes is not a good time, and having to deal with, you know, all the stuff that goes with that.

That was in there, and the fact that there had been a transition in leadership, both at the assistant ops manager and the ops manager in that recent time frame.

Yes, she raised that, those issues.

But it was mostly about just leadership and work environment.

SR. SPECIAL AGENT TEATOR:

Okay.

Still 17 18 19 20 21 22 23 24 25

-II I

11-talking about her work with the Salem NEOs, okay.

Did she ever tell you that the Salem NEOs were frustrated at senior management because they thought senior management was ignoring or only paying lip service to their safety concerns, including nuclear safety concerns?

Never relative to nuclear safety concern.

She d

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of SAFE notification.

2 SR.

SPECIAL AGENT TEATOR:

What does 3

that stand for?

4 That's the code.

It's 5

coded in SAP; S-A-F-E.

So there are any 6

notifications that are coded SAFE, they're 7

industrial safety issues that we work off.

8 There had been a -- that backlog had 9

built up during a period of time in the latter part 10 of 2002, and there was a lot of frustration within 11 the union that some of those were not being worked 12 off in a timely fashion.

.13 That's the only thing that she raised --

14 I mean I do not -- to me.

I mean I don't ever 15 remember raising any nuclear safety concerns.

16 SR.

SPECIAL AGENT TEATOR:

Did she ever 17 I'm going to go through some of the stuff, and 18 I'll get yes or no, right?

19 In her time she's working with the Salem 20 NEOs, did she share in your presence concerns raised 21 by them that there were extensive lists of safety 22 concerns and broken promises by senior management at 23 the site, something along those lines?

Did she ever 24 share that with you, or in your presence?

25 I think in the context of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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industrial safety concerns, she talked about it, but 2

she did not talk to us in terms of nuclear safety 3

concerns.

4 SR. SPECIAL AGENT TEATOR:

Okay.

In any 5

discussions that you had wit where 6

present, did he ever make any type of 7

a complaint or statement to the effect that he 8

thought that Kim Harvin had sided with the union 9

people?

10 That's not my word.

I mean, that's in 11 some of these documents, that she sided with the 12 union.

13---

(a)

I don't 14 remember a specific conversation.

Bud 15 generally does not make pronouncements about people.

16 I mean just he will typically take input from 17 others, and then he'll make up his mind what he 18 wants to do.

But that would be out of character, to 19 have him say that she --

20 Now I will tell you that I personally 21 have said that I believe that she could not separate 22 herself from the people she was --

she had stopped 23 being a facilitator, and had become part of the 24 group in some ways, and that was problematic in that 25 she had very close relationships with people, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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personal relationships, and her effectiveness was 2

diminishing.

3 SR.

SPECIAL AGENT TEATOR:

Part of what 4

group?

When you said "She became part of the 5

group."

6 A.

Really, any group.

When 7

she was at Hope Creek, she became personally 8

attached and lost her objectivity with the people 9

she was working with.

10 So that she was always defending any 11 action that they took, right, wrong or indifferent, 12 because you know, she felt they were having a tough 13 time.

14 SR.

SPECIAL AGENT TEATOR:

It's a tough 15 site down there.

16 I's a tough site, and her 17 job was to work on cultural transformation, right?

18 So she's working on it in the personal 19 relationships, so she'd build in her own personal 20 relationships with people, which is fine.

Nothing 21 wrong with that.

22 But ultimately, that can also jade you 23 as well.

That's one of the challenges with any HRD 24 kind of consultant, you know, human relations and 25 development consultant, is that they become so NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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attached to the people that they're working with, 2

that they lose their objectivity.

3 I believe that she was --

she approached 4

that, and based on my Millstone experience, I saw 5

that some of the similar behavior with some of the 6

consultants I had there.

7 SR.

SPECIAL AGENT TEATOR:

Right.

We're 8

going to get to talking about her job performance.

9 I'm going to ask you to comment on that, but I 10 appreciate you sharing that with me.

Jeff, is there 11 something you want go over?

12 MR.

KEENAN:

No.

13 SR.

SPECIAL AGENT TEATOR:

So I've read 14 your Winston Strawn transcript.

I asked you some 15 questions.

But I mean to summarize, did Kim Harvin 16 ever raise what you consider to be nuclear safety 17 concerns in your presence?

18 Never.

19 SR. SPECIAL AGENT TEATOR:

All right.

20 All right.

21 ust one thing.

Maybe it's 22 something.

I think sometimes Kim would get 23 confused.

She has a hard time separating issues, 24 and in the conversation I had, that was one of the 25 challenges Kim would have, is she couldn't --

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would meld together and put together a bunch of 2

things, and just kind of --

she would see the pain 3

in people or the aggravation or the morale, and 4

she'd kind of look for reasons.

5 But it always ended up being around 6

industrial safety.

You know, she really was 7

concerned, because that was a battle cry of the 8

folks in the union at the time.

9 SR. SPECIAL AGENT TEATOR:

Industrial 10 safety concerns.

ii Industrial safety, yes.

12 SR.

SPECIAL AGENT TEATOR:

Right.

13 We recognized it.

We had 14 seen a fall-off in our safety performance.

So, you 15 know, and that's one of the reason we had to stand 16 down.

That's why we had a lot of the things in 17 there.

18 So in that, the last three, four months 19 of 2003, 2002, we saw a big fall-off in our 20 performance in safety, and we actually stood down 21 the maintenance organization, to try and gain 22 control of that.

Then we saw resultant improvement 23 in that.

24 So I mean, she was talking about 25 industrial safety during that time period.

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SR. SPECIAL AGENT TEATOR:

I mean, I'm 2

asking you for your knowledge of things.

The 3

Commission has come to a determination that she did 4

engage in protected activity.

5 Otherwise, I wouldn't be doing this.

6 But I'm exploring your knowledge of being in her 7

presence when she raised such concerns.

8

Yes, ine.

9 SR. SPECIAL AGENT TEATOR:

Okay.

I 10 asked you a question earlier about if at any time 11 had made a comment that he thought Kim 12 had sided with the union.

13 You said he wouldn't --

it's not like 14 him to comment like that about anybody, and you 15 don't remember him making a statement to that 16 effect.

17 Do you remember any of the other senior 18 managers, people at your level, making such a 19 statement, that they thought Kim had sided with the 20 union over --

the union meaning, I guess, the Salem 21 NEO issues.

22 I don't remember them ever 23 saying "sided with the union."

I remember them 24 saying they had sided with the NEOs.

25 SR. SPECIAL AGENT TEATOR:

They're all.L NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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union people though, right?

2 Right.

So, I mean, you can 3

draw that.

But I mean you asked specifically if I

4 heard things like "sided with the union."

I heard 5

them say that she sided with the NEOs.

6 SR. SPECIAL AGENT TEATOR:

Okay.

Who 7

did you hear that from?

Do you remember?

8

) No, I don't recall 9

specifically who it was.

10 SR.

SPECIAL AGENT TEATOR:

Right.

Did 11 you think she sided with the NEOs?

12 I would say that I think 13 she probably --

I mean) I would say yes.

I would 14 think she would side with the NEOs.

Right, yes.

I 15 mean, I side with the NEOs sometimes.

16 SR. SPECIAL AGENT TEATOR:

Right.

17 When they're right, they're 18 right.

19 SR. SPECIAL AGENT TEATOR:

Yes.

I guess 20 the way it's been portrayed, though, that that was 21 looked at negatively by management, including people 22 at your level, that she had sided with the NEOs, as 23 opposed to 24 I mean, (ph) 25 sides with the NEOs all the time.

It's just and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 he's viewed as a very positive manager and managerial influence.

So I mean the answer is, it would not be a bad thing unto itself.

SR. SPECIAL AGENT TEATOR:

It wouldn't necessarily be a negative thing though?

No.

SR.

SPECIAL AGENT TEATOR:

If people did say that or think she did that?

I mean, her job was to go in and work with them and build rapport, and repair some of --

because we recognized it was a hot spot.

We were seeing a lot of issues.

There was a lot of negative conversation in there.

There was unrest amongst the leadership within the union.

There was unrest between the NEOs themselves.

There was unrest between the assistant ops Manager and some of those people.

So her job was to go in there and help build those relationships.

So where those people weren't doing what they're supposed to do, it would be appropriate for her to side with them, and try and figure out a way of facilitating a solution.

SR. SPECIAL AGENT TEATOR:

Okay.

Do you know how she got that assignment, to go work with 7/ "1

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the Salem NEOs over those issues?

Do you know if 2

that came from 3

It would have to come from, 4

ultimately frov It may have come at a 5

request from Kim, to have --

because he was, at that 6

time, he was the 7

So, I mean, doesn't typically go 8

out.

So would have directed her, because she 9

worked directly foA 10 SR. SPECIAL AGENT TEATOR:

Okay.

I'm 11 going to ask you some questions now regarding your 12 testimony to Winston Strawn, when you were being 13 interviewed by them.

If you could read page 4 and 14 page 29.

If you need to read a couple pages 15 surrounding it, that's fine.

16 MR.

KEENAN:

Do you want to take a 17 break?

18 SR.

SPECIAL AGENT TEATOR:

It's five of 19 12:00.

I'll go off the record while you're reading 20 that.

21 (Off the record.)

22 SR. SPECIAL AGENT TEATOR:

Okay.

It's 23 almost 12:00.

We're back on the record after a very 24 short break.

'have you had a chance to 25 look at those portions of your Winston Strawn NEALR. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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transcript?

2

Yes, I reviewed the pages 3

around page four and around page 29, regarding the 4

WANO issues.

5 SR.

SPECIAL AGENT TEATOR:

Maybe you 6

could tell me a little bit about this WANO debrief, 7

and --

because it talks in your --

well, you 8

testified to Winston Strawn.

9 Mike McGarrity (ph) was one of the 10 attorneys there, about issues that WANO brought.

11 Maybe you can go in and tell me now what those 12 issues were that WANO brought up during this 13 debrief?

14 Sure.

WANO, the World 15 Association of Nuclear Operators, debriefed us after 16 a two-week visit to the station.

That debrief 17 resulted in a report, and a report out, a written 18 report, as well as an oral debrief, and then a final 19 debrief with the Chairman of the Board and other 20 members of the senior leadership team.

21 Their issues largely were around long-22 standing equipment issues that were plaguing the 23 plant, maintaining and holding standards and 24 expectations in the work place, in the field.

That 25 was a concern of theirs.

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The elements of human performance were 2

not visible to the extent that they see at other 3

stations.

4 That debrief occurred, and so in the 5

context of this, when the question was posed, was 6

there anything where we discuss leadership 7

weaknesses, they talk about the leadership 8

weaknesses in ensuring compliance in the field, to 9

standards and expectations.

10 They talked about leadership weaknesses 11 in terms of putting Human performance at the 12 forefront of a conversation.

They also touched on 13 the industrial safety issues that were raised, and 14 are in a relative sense poor performance against our 15 nuclear peers.

16 SR.

SPECIAL AGENT TEATOR:

On page 29, 17 there's a question asked, "Have you heard anybody 18 suggest that the site" line 11 there --

the 19 question is, "Have you ever heard anybody suggest 20 the site is not consistently coming from safety in 21 decisionmaking."

22 You answer on line 14 "Well, in that, I 23

mean, I think that to some extent there is a little 24 bit of that in the Weil report.

They were not 7

25 consistently enforcing standards and expectations."

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That seems to talk about safety there, 2

plant safety.

3 Right, plant safety, and 4

that's where I was I was posing that's why people 5

make certain decisions that are not consistent with 6

our standards and expectations, and go counter to --

7 and have a bias to getting the work done, regardless 8

to the potential consequences to themselves.

9 SR. SPECIAL AGENT TEATOR:

When WANO is 10 bringing this information forward, based on their 11 review of the plant, how is it received by you and 12 people at your level?

13

Well, I mean it's not 14 inconsistent with what they told us the previous 15 time, in that we'd seen it before.

I mean, in some 16 ways you're embarrassed, in some ways you're upset, 17 because that's still there.

18 You know, you're working on closing the 19 gap but you're not closing the gap fast enough.

So 20 I would say that there's some level of frustration.

21 There's some level of a sense of failure that you 22 haven't closed the gap as effectively as you should 23 have, and some level of deciding yourself that 24 you're going to have to turn up the gain, and have 25 to do more to ensure that those standards and NEALR. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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3 4

5 6

7 8

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 29 expectations, and obviously do something different, or else, you know, you're going to continue to have a problem.

SR.

SPECIAL AGENT TEATOR:

Right.

Did anyone from senior management disagree with WANO's conclusions?

On enforcing standards and expectations?

It would be hard to disagree, because there was a laundry list of examples.

So it's one of those --

you can sit in there and get, you know.

But standing up and telling somebody that's got ten examples that they saw, that you're consistently enforcing it is a pretty specious argument.

SR. SPECIAL AGENT TEATOR:

Now based on the WANO report, the findings, did the company move forward and take actions to try to address the issues identified in the report?

Sure.

Well, a number of different things.

We developed the Human Performance Team and brought to help put together Human Performance Work.

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techniques in the field, and we refocused ourselves 2

on the safety issues and, you know, began working on 3

reinforcement of safety behaviors in the field.

4 We had the job safety observation 5

program. We did some other things like that, and 6

brought different programs to bear in a more 7

programmatic response, with mixed levels of success.

8 SR. SPECIAL AGENT TEATOR:

Right.

Now 9

you mentioned safety there, are you talking --

10 I'm talking industrial 11 safety.

12 SR. SPECIAL AGENT TEATOR:

Okay, all 13 right.

Question.

Now let's drop back to Kim 14 Harvin.

Is she raising some of the same issues 15 identified by WANO?

I mean stuff she was raising, 16 and we've talked about your --

what she raised and 17 you testified to that.

18 Was she raising some of the same things 19 that WANO raised in their debrief, and if so, which 20 ones would be similar or closer to the same?

21 Yes.

I think you could 22 argue that her --

the lack of consistency, in terms 23 of enforcing the standards and expectations.

She 24 talked about that, and the inconsistency between 25 groups.

She saw that as one of the things that

/

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impacted morale.

2 I think that the issues around 3

industrial safety and around human performance, I

4 think she talked about that, you know, the people 5

taking the time to do the job.

I think she raised 6

those issues.

Yes.

I think in those cases, but not 7

in--

8 The WANO issues weren't couched in as 9

much nuclear safety issues as they were in work 10 practices and industrial safety and human 11 performance.

I believe that she was probably even 12 more into work practices and industrial safety.

13 SR.

SPECIAL AGENT TEATOR:

Okay.

We can 14 put this report aside for a couple of minutes.

Not 15 the report; the transcript.

16 All right.

Let's go back and talk a 17 little bit about the decision to eliminate Kim's 18 position.

When did you first become aware that her 19 position was going to be eliminated?

20

1. believe it was in the 21 latter part of January, early February time period.

22 I mean, it would have been January-February time 23 period.

24 SR. SPECIAL AGENT TEATOR:

Of '03?

25 Of '03, that's correct.

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SR.

SPECIAL AGENT TEATOR:

Okay, and do 2

you remember how you learned that?

3 I think it was just a 4

hallway conversation.

But I don't know.

5 SR.

SPECIAL AGENT TEATOR:

Do you 6

remember?

All right.

7 Then Kim several days 8

later, I mean several days after I heard that, I was 9

talking to Kim, and she said "You know I'm leaving."

10 And then I said "Oh, I had not heard it."

Then she 11 told me she was leaving, that her job had been 12 eliminated.

13 SR. SPECIAL AGENT TEATOR:

Her last day 14 on the payroll was April 14 '03.

She was given 15 knowledge of her 45-day letter on February 2 6 th.

So 16 she had 45 days from that --

17 I don't remember the 18 specifics.

19 SR. SPECIAL AGENT TEATOR:

She was 20 formally notified on February 26 that her job was 21 going to be eliminated, and she signed this 22 agreement here.

So knowing that now, when do you 23 think you had that conversation with Kim?

24 It would have been after 25 she was informed.

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SR. SPECIAL AGENT TEATOR:

Okay.

2 So it would have been in 3

the latter part of February, early March.

4 SR. SPECIAL AGENT TEATOR:

Do you recall 5

participating in any discussions prior to that, 6

where it was discussed that her job may be 7

eliminated, or the need for her function may be 8

eliminated?

9 W

Only in the context --

I 10 think one of the questions, not in the elimination 11 of the job, but in the effectiveness, the 12 effectiveness of that role, of an in-house 13 consultant, was raised with me.

14 SR.

SPECIAL AGENT TEATOR:

Okay, let's 15 talk about that.

Let's go to talking about her job 16 performance and her effectiveness.

17 Now let me go back to the 18 other one, but I think you asked the question.

We 19 began a process in the fall of '02 to look at all 20 the staff and support positions, and to say "is that 21 really worth what we're investing in it."

22 We looked at our consultants, and we 23 looked at our in-house talent, and said "Are we 24 really letting what it is that we need from those 25 people?"

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SR.

SPECIAL AGENT TEATOR:

Right.

2 We looked at our IT 3

functions, our HR functions, our supply chain 4

functions.

All of those things came into review, 5

and we were going through all our business support 6

and business services functions, and allied 7

functions.

So that was underway.

8 Was Kim captured in that umbrella?

9 Probably.

I mean she should have been if she 10 wasn't.

11 SR. SPECIAL AGENT TEATOR:

Right.

12 So we had a discussion, 13 then, about _2 I don't want to say it was in the 14 January time frame, about, you know, her 15 effectiveness, that January-February time frame.

16

Again, I don't think -- can't remember the specific 17 dates, about her effectiveness.

18 I was asked about her effectiveness in 19 that role, and I said that I didn't believe that she 20 was necessarily as effective as she should, that she 21 was impacted by her very close relationships with a 22 lot of the people, and that she didn't have the 23 requisite level of separation from the people that 24 she was facilitating, to maintain the appropriate 25 level of objectivity to facilitate discussions.

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You know, it's hard to be a facilitator 2

if you're on the side of one group.

3 SR.

SPECIAL AGENT TEATOR:

Did you 4

provide that input during a Saturday morning meeting 5

at

.house in early '03, talking about 6

everybody's job performance for the prior year?

If 7

not--

8....

I don't remember.

I don't 9

remember providing it at that meeting, but I 10 remember --

it may have been at that meeting, or it 11 may have been at a subsequent meeting.

But I recall 12 a staff meeting subsequent to that, giving that 13 feedback, a staff meeting in.-office 14 SR.

SPECIAL AGENT TEATOR:

Okay.

Would 15 the other VPs have been there also?

16 Right.

17 SR.

SPECIAL AGENT TEATOR:

Is that where 18 a staff meeting would be at the site?

19 Right.

It would have been 20 in conference room, the executive conference 21 room adjacent to office.

22 SR.

SPECIAL AGENT TEATOR:

Did you 23 provide specifics as to your basis for what you told 24 people during that meeting, she lost her objectivity 25 I think is one thing you said?

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Yes, I did.

I talked to 2

them about, you know,

-..#'and the fact that 3

• she would defend --

4 SR.

SPECIAL AGENT TEATOR:

Who's that?

5 s a 6

on, for example, on Hope Creek.

And she would 7

defend-, -truggled at certain points 8

with starting the unit, something going through it, 9

and basically making sure that the schedule matched 10 the work, and that we were moving through, and that 11 the pre-planning, a lot of the pre-planning wasn't 12 done that was necessary, and some of the prereqs.

13 It was just kind of --

he was falling 14 short.

He did well in the production portion of 15 theo outage, but during the start-up phase, a lot of 16 that wasn't laid out as well as it should, and he 17 had a leadership role.

18 I remember her just irrationally "Well, 19 you know, he's a great guy."

It's not a great guy 20 issue.

It's does the schedule reflect what you need 21 to do to start the plant up, and he's accountable 22 for the schedule, and it doesn't.

23 It's not a great guy issue; you have a 24 performance standard, which means that the things 25 you need to do to start the plant up ought to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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37 1

accounted for in the schedule, and they're not.

2 So that's really where --

so I would 3

have used as an example.

I probably would 4

have used as an example, 'A il

\\"

5 I probably would have used, where she 6

would defend the Hope Creek managers, who she had 7

felt she had developed a very good working 8

relationship, kind of almost irrationally.

9 SR.

SPECIAL AGENT TEATOR:.

10 (ph),

was he one of them?

11 No,'

was --

I never 12 heard her say a word about

-one way or 13 another.

14 SR. SPECIAL AGENT TEATOR:

(ph)?

15 yes.

16 SR.

SPECIAL AGENT TEATOR:

He was at 17 Hope Creek, right?

18 He was at Hope Creek.

He 19 was the t Hope Creek.

'was 20 there;.

21 was a who was, had been put into the 22 position.

23 She had developed a rapport with them, 24 and she would oftentimes defend them without benefit 25 of facts.

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SR. SPECIAL AGENT TEATOR:

This staff 2

meeting that you're talking about, where you gave 3

this input.

Did others provide input regarding Kim 4

Harvin at that meeting?

5 I'm sure they did, because 6

1a would have gone around the table and asked for 7

it.

8 SR. SPECIAL AGENT TEATOR:

Okay.

Do you 9

recal2) asking for input from his staff about 10 other people besides Kim, or is it just Kim?

11 7

Well, in different venues, 12 qould ask for opinions about everybody.

13 SR. SPECIAL AGENT TEATOR:

Right.

Let's 14 talk about this staff meeting, though.

15 In this staff meeting, I 16 don't recall him asking about anybody else.

17 SR. SPECIAL AGENT TEATOR:

Do you know 18 why the questions were asked regarding 19 That was one of the --

I 20 mean, I'm putting two and two together.

21 If we had earmarked that position as one 22 of the business services positions, and he was 23 trying to make a decision on how effective that job 24 was, he would have asked for feedback.

But I'm just 25 I'm just supposing what I believe "IMwould NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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have done.

2 SR.

SPECIAL AGENT TEATOR:

All right.

3 Did you provide any written input to Mz 4

regarding your view of Kim's job performance or her 5

value?

6 Written?

Not that I 7

recall.

8 SR.

SPECIAL AGENT TEATOR:

All right.

9 At any point did ask you or others, 10 while you were in his presence, whether he should 11 keep Kim in her function, in her job?

12 I'm sure that's the context 13 that he asked the question in, you know, when he 14 went around the table that time at the staff 15 meeting.

I would feel pretty comfortable about 16 that.

17 SR.

SPECIAL AGENT TEATOR:

Okay.

Take a 18 very short break.

It's 12:15.

19 (Off the record.)

20 SR. SPECIAL AGENT TEATOR:

We're back 21 on.

It's about 12:20.

I'm going to go back and 22 talk about --

from what I understand, there was a 23 meeting a f

house, a Saturday morning 24 meeting?

25 Yes, there was.

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SR.

SPECIAL AGENT TEATOR:

In early 2

2003?

3 i Yes, there was.

4 SR.

SPECIAL AGENT TEATOR:

Where the 5

performance of a good number of people was discussed 6

at that meeting, the VPs are giving their input to 7

4o From my understanding, you were present at 8

that meeting?

9 I was.

10 SR.

SPECIAL AGENT TEATOR:

You remember 11 the meeting now?

12 M M i

Sure.

13 SR.

SPECIAL AGENT TEATOR:

Do you recall 14 Kim Harvin's performance being discussed during the 15 meeting?

16 I don't remember specifics 17 on Kim at that meeting, but we talked about 18 virtually everybody at that meeting, so it could 19 have been Kim.

But I mean, as you said earlier, all 20 the directors were reviewed.

21 All of the managers, and so it was a 22 rather large cross-section.

It was probably, I'm 23 guessing, about 35 to 50 people were discussed.

So 24 could she have been one of them or should she have 25 been one of them?

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specifics on Kim Harvin.

2 SR.

SPECIAL AGENT TEATOR:

During the 3

discussion which you described earlier, at a staff 4

meeting where you gave input tA

,on your view 7

5 of Kim's job performance, were you asked to give a 6

summary rating on where you felt her performance 7

was?

8 Needs Improvement, Meets Expectations, 9

Exceeds?

Were you asked to give such a summary 10 conclusion as to your view, overall view of her 11 performance?

12 I'm just trying to think.

13 I don't remember giving a summary, I mean being 14 asked to do a summary.

Really just I don't 15 remember.

16 SR.

SPECIAL AGENT TEATOR:

Do you know 17 if at the end of that discussion on Kim, there was a 18 consensus reached by the group, as to how the group 19 viewed her performance?

20 In there, I think it was 21 universally felt that she was --

her performance was 22 less than effective, at changing, affecting the 23 culture amongst the Salem NEOs.

24 SR.

SPECIAL AGENT TEATOR:

Okay, and the I{

25 reasons for that were, as you already described NEALR. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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earlier in your interview today?

2

Well, I think one of the 3

challenges she had was she came over --

she had a 4

good relationship in Hope Creek.

She had a better 5

relationship with some people in there, and she had 6

been in there.

7 To some extent, she became, I think she 8

was impacted with two things.

There were the people 9

in Salem who liked her, and there were the people in 10 Salem who thought she was a Hope Creek interloper.

11 SR. SPECIAL AGENT TEATOR:

Okay.

12 I

I think that impacted her.

13 So she had trouble just with her own role, coming 14 over there as a --

being known as a Hope Creek 15 person, coming over Salem.

16 SR.

SPECIAL AGENT TEATOR:

That's my 17 phone.

We have to take a short break.

18 (Off the record.)

19 SR. SPECIAL AGENT TEATOR:

We're back on 20 the record after an interruption.

It's 12:25.

I 21 guess we were talking about that meeting still, the 22 staff meeting.

23 Right.

24 SR.

SPECIAL AGENT TEATOR:

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43 1

interloper.

But go ahead and finish.

2 Yes.

Just, you know, there 3

are some people that are viewed as Hope Creek people 4

at the station, and there are some people that are 5

viewed as Salem people.

We used to have a fence 6

between them.

7 Amongst the operators, there's less 8

mixing even amongst the NEOs, at the operator level, 9

and in some of the shops, because like in RP, they 10 don't typically commingle too much.

They tend to 11 work in their respective units.

12 So she came over, having worked with the 13 Hope Creek operations people and outage people 14 extensively.

So she was viewed by many of them as a 15 Hope Creek person.

She came in; she didn't have a 16 lot of relationships established at Salem, because 17 she'd been so focused on Hope Creek.

18 It was a challenge.

I mean, she was not 19 as readily received at Hope Creek as she had been at 20 Salem --

excuse me, at Salem as she had been at Hope 21 Creek.

22 SR. SPECIAL AGENT TEATOR:

Was that 23 issue discussed when this staff discussion occurs 24 about her performance?

Did that come up, that --

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factored in there.

It just was a question of how 2

effective had she been.

She'd been over there for, 3

at that point, for probably about six months or so.

4 So she should have worked through that, 5

but had not been --

had been unsuccessful, and she 6

even voiced her concerns and her frustrations with 7

not being able to kind of break into the --

to 8

establish a rapport with the operators at Salem, in 9

personal conversations with me.

10 SR. SPECIAL AGENT TEATOR:

Do you know -

11

- well, did she document any of those?

I mean, I 12 see a lot of e-mails from her in the documents I've 13 gotten.

14 Did she ever put anything like that in 15 writing that you're aware of, through an e-mail, a 16 note, a message, anything like that?

If so --

17 I get hundreds of them a 18 day, and I won't remember.

I mean, and I certainly 19 you know, Kim is one of those people who, you 20 know, comes in, sits down, and you know, kind of 21 bares her soul.

So I wouldn't normally --

22 SR. SPECIAL AGENT TEATOR:

If you have 23 any document like that, could you give it to Jeff?

24 am a very, very diligent 25 purger.

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old in my office.

2 SR.

SPECIAL AGENT TEATOR:

Okay, okay.

3 purge everything.

4 SR.

SPECIAL AGENT TEATOR:

Let's switch 5

to just a separate area for just a minute.

Same 6

issue though, talking about Kim's performance and 7

her work down there.

8 Did you ever get any concerns or 9

complaints voiced to you from union people regarding 10 Kim?

11 The union, the business agents, the 12 stewards?

Did they, something to the effect that 13 they didn't trust her, Couldn't trust her, anything?

14 (Tape change) 15 1

There's something --

I 16 don't remember specifically.

I remember a 17 conversation with.

about her.

He's the 18 land it just is a --

it has a negative 19 connotation to it.

20 SR. SPECIAL AGENT TEATOR:

Okay.

21 IBut I don't remember, if

• I 22 you're asking me specifically what it

was, it just 23 it's catiloading (ph) under a negative

/

24 interaction.

25 SR. SPECIAL AGENT TEATOR:

All right.

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Do you think that conversation with

)

2 occurred in

'03,

'02?

3 Probably would have 4

occurred in

'02.

5 SR.

SPECIAL AGENT TEATOR:

Okay.

Jeff, 6

are you going to continue, or you've got to answer 7

that?

8 MR.

KEENAN:

No, I'm good.

9 SR.

SPECIAL AGENT TEATOR:

Okay.

All 10 right, okay.

11 1 talk t all the 12 time.

I mean, you know, I probably have a 13 conversation with;Iat least every ten days.

14 SR.

SPECIAL AGENT TEATOR:

Even today?

15 Yes, about all kinds of 16 things, you know.

I'm involved with him in safety 17 areas, you know, industrial safety, because I head 18 up the line of business for the support 19 organizations, the safety, and he's the chairman or 20 the co-chair of the Site Safety Council.

21 He's also the chairman of the --

the co-22 chair from the bargaining unit perspective and the 23 support council.

So I'm talking to'V all the

/ZL' 24 time about issues.

25 SR.

SPECIAL AGENT TEATOR:

Okay.

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decision to actually eliminate Kim's position there 2

at the site, that decision was made.

Were you part 3

of the decisionmaking process for that to occur, or 4

was it jus d**s Sion?

5

• jNo.

That wa at 6

least to me, it was him.

I mean I didn't he 7

didn't ask me, other than just my opinion.

8 SR.

SPECIAL AGENT TEATOR:

Okay.

When 9

did you come to learn that a decision had been made, 10 and Kim was going to be leaving 45 days after That?

11 It was subsequent to the 12 decision to tell her, because I heard a rumor, and 13 then a couple of days later Kim validated the rumor 14 in a personal conversation when --

15 SR. SPECIAL AGENT TEATOR:

When she saw 16 you in the hallway?

17

Yes, saw me --

we actually, 18 I think she came into my office, and said something 19 to me about it.

20 SR.

SPECIAL AGENT TEATOR:

All right.

21 During that discussion that she had with you, did 22 she tell you she felt that that action had been 23 taken because she had engaged in protected activity?

24 No, because if she had, I 25 would have done something with it.

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 48 SR.

SPECIAL AGENT TEATOR:

Right.

Did she tell you that she thought that action had been taken because she raised any concerns to senior management at the plant?

No.

I think her conversation was that it was a business decision, and that's all it was.

It was a business decision at that time.

That's how it had been related to her.

SR. SPECIAL AGENT TEATOR:

Right, right.

But she didn't give me her perspective that it was anything other than that.

SR.

SPECIAL AGENT TEATOR:

Right, okay.

Now Kim's told on February 26, 2003 --

The reason I can be sure of that, by the way, is because after Millstone, if somebody comes up to me and says "I'm doing something that's protected," I'm doing something with it.

SR. SPECIAL AGENT TEATOR:

Okay.

Okay, and my track record, I can show you a track record.

Every time somebody brings something like that forward, I mean I'll be the first person to come to your doorstep.

SR.

SPECIAL AGENT TEATOR:

Okay, I was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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going to say if you had gotten a whiff of that at 2

all--

3 I would have immediately 4

gone to see Jeff, and I would have gone to see 5

(ph), and say "Hey, we've got a problem.

We 6

need to figure out how we're going to do the 7

investigation."

8 SR.

SPECIAL AGENT TEATOR:

Okay.

At 9

some point, a decision was made to --

her last pay 10 date, her last day on the payroll was going to be 11 April 16, 2003.

12

.)

That's what I understood.

13 SR.

SPECIAL AGENT TEATOR:

Right, and --

14 all right.

When Kim comes and tells you her job's 15 been eliminated, does she say during that 16 conversation that she's going to work up to her last 17 day, meaning April 16th?

Did that come up at all?

18

) No, it didn't come up.

19 SR.

SPECIAL AGENT TEATOR:

Okay.

At 20 some point a decision was made, where she was not 21 going to be working at the site, up to April 1 6th.

22 Her date was going to be moved up to late March.

At 23 some point, did you become aware that that decision 24 was made?

25 No.

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she came in on the 2 8th and said it was her last 2

day.

3 SR.

SPECIAL AGENT TEATOR:

Okay.

Is 4

that the meeting that's described in your Winston 5

Strawn --

6 NON Right, when she came in and 7

read that soliloquy.

8 SR.

SPECIAL AGENT TEATOR:

Some people 9

gave her a hug at the end --

10 Right.

I mean, I gave her 11 a hug at the end.

I mean, hook her hand.

I 12 think a couple of other people gave her a hug, who 13 knew her pretty well.

14 SR.

SPECIAL AGENT TEATOR:

Did you have 15 any other discussions with her that day about her 16 leaving, other than this?

17 I did not see her after she 18 left that room.

19 SR.

SPECIAL AGENT TEATOR:

Okay.

20 So the last time I saw Kim 21 was the moment she left that room.

22 SR.

SPECIAL AGENT TEATOR:

Okay, when 23 she gives her speech to the people in the room.

Did 24 she make any claim at that point that she thought 25 what had happened to her, meaning either her NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 position was eliminated or her date moved up, she think that that happened to her because she had raised concerns at the plant, raised issues that management didn't want to hear about?

Did she make any claim like that at all?

No.

As a matter of fact, she alluded to that "Hey, it's kind of like the life cycle, business life cycle.

She came with(A She leaves with 7

I mean that's what she said in the --

mainly she just talked about the things that had

worked, th6 things that didn't work and, you know, where she saw the win and where she could have seen a win.

SR. SPECIAL AGENT TEATOR:

Okay.

Are you aware of any information which leads you to believe that Kim's position was eliminated because she raised concerns?

I'm being general about concerns, because --

but are you aware of any information which leads you to believe that because she raised concerns, that caused her position to be eliminated?

SI know of nothing.

SPECIAL AGENT TEATOR:

Okay.

Same/"'/

question for the decision to move up her last day at qc-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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work.

Are you aware of any information which leads 2

you to believe that her last day was moved up 3

because she raised concerns at the plant?

4 No, no.

5 SR.

SPECIAL AGENT TEATOR:

All right.

6 It's 12:36.

We're going to take a short break.

I 7

believe I'm almost finished up, but we'll look over 8

it and then we'll jump back on the record.

9 (Off the record.)

10 SR. SPECIAL AGENT TEATOR:

Okay, we're 11 back on.

It's about twenty of 1:00, and I want go 12 over a couple of questions for you.

Yes or no, if 13 you want, and please expand on the answering if you 14 can.

15 Sure.

16 SR. SPECIAL AGENT TEATOR:

Did you ever 17 hear any --

first of all, did you observe this 18 yourself, that --

did you ever see Kim acting as a 19 line manager, overstepping her bounds, and confusing 20 people as to her role?

21 Yes.

22 SR.

SPECIAL AGENT TEATOR:

Had others 23 ever told you that they had seen Kim act in such a 24 fashion?

U 25 Yes.

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SR. SPECIAL AGENT TEATOR:

And when you 2

observed her acting in that fashion, did you ever 3

counsel her or talk to her about that?

4 The answer is yes.

I think 5

she used to come in every once in a while and would 6

chat with me about her role and role clarity, and 7

about how do you align better with the organization.

8 Then we often had discussions about, you 9

know, what I used to refer to as "don't go native."

10 You can't allow yourself to become part of the 11 people you're trying to facilitate and interact 12 with, and we would have that discussion.

13 Most of her issues were about where she 14 would side with people, without benefit of fact, 15 just because of her personal relationships with 16 them.

17 SR. SPECIAL AGENT TEATOR:

How about her 18 acting as a line manager, and that really wasn't her 19 function?

People have described that to me.

Can 20 you comment on that?

21 I've never seen her act as 22 a line manager.

I've seen her overstep her bounds, 23 and I've seen her -- what was the other one in there 24 about --

25 SR.

SPECIAL AGENT TEATOR:

Confuse NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 people as to her role?

Confuse people as to her role.

But I've never seen her act as a line manager.

I've seen her go in there and act as kind of --

trying to act as a puppeteer for a line manager.

SR.

SPECIAL AGENT TEATOR:

Who?

Anybody in particular?

WWI.The folks over at Hope Creek, you know, the1

'and different people, and try and speak for them.

SR. SPECIAL AGENT TEATOR:

Okay.

AU So if that's "act as a line manager," then that might be what people are alluding to.

I saw that.

SR. SPECIAL AGENT TEATOR:

Let's talk about

__for a minute.

Had he ever asked you if you, individually or in a group with your contemporaries, the other VPs, if you felt that the facilitator was worth the money your were spending on it and making forward progress at the plant?

That was --

he would ask that question regularly, about whether it be Gap or Kim or anybody else, yes.

We always look-at the --

'I are we getting the value that we expect out of any C

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support organization.

That would be a common 2

question.

3 SR.

SPECIAL AGENT TEATOR:

Do you ever 4

remember him asking a specific question as to Kim?

5 Or was it more of a general question froi D

6

It may have been part of 7

that last discussion, whether we really thought she 8

was --

remember that effectiveness question that we 9

talked about before in that meeting?

10 It was probably --

it may have been 11 embedded in that.

But I don't recall it 12 specifically being asked.

13 SR. SPECIAL AGENT TEATOR:

Did you ever 14 recal lsaying that certain jobs at the 15 plant would be reviewed every year, to see if 16 they're still needed?

17 Yes.

We reviewed a lot of 18 jobs, with respect to that.

19 SR. SPECIAL AGENT TEATOR:

Do you recall 20 Kim's position in particular being discussed in that 21 fashion, other than the one time that we're --

22 Oh, he'd ask --

23 occasionally, he'd ask about Kim.

He'd ask about 24 everybody.

He'd ask about, you know, howlAM 25 A..

(ph) is doing and how, you know, how Kim NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 56 (ph) doing, how anybody who would work for him was doing and performing.

So all the people that reported to him, either directly or kind of on a staff function, he would ask about their performance.

That was kind of

-- almost a routine conversation.

SR. SPECIAL AGENT TEATOR:

Right.

And if you think about it, that's kind of the role of management, to ask about how people are performing, and whether what they're doing is really serving the need.

SR.

SPECIAL AGENT TEATOR:

Had you ever heard-qsay that Kim's -- we're going to break for just a minute.

(Off the record.)

SR.

SPECIAL AGENT TEATOR:

Had you ever heardýstate that he viewed Kim's job on a year-by-year basis, what would be a yearly review of her job, or he would decide on a year-by-year basis on whether her job was needed for the next year?

I never heard say that.

SR.

SPECIAL AGENT TEATOR:

Was it clear in your mind that her job was temporary down there, C-1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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and that it was not a permanent position, a 2

permanent job?

3 I assumed that her job was 4

like everybody else's, that it was a permanent job, 5

when she rolled from the Service Company to Nuclear, 6

that it was a permanent position, in the sense of 7

any other at-will employee's position.

8 That as long as there was a need and the 9

company needed it and she wanted it, there was room 10 at the end, and she was performing at the requisite 11 level.

12 SR. SPECIAL AGENT TEATOR:

How about the 13 fact that she was working fow a

s was-14 leaving?

15 I worked for j

16 as leaving.

17 SR. SPECIAL AGENT TEATOR:

Okay.

I take 18 your point.

All right.

19.

But I'm not a contracted 20 employee.

21 SR. SPECIAL AGENT TEATOR:

So to close 22 out here, why do you think Kim's position was 23 eliminated?

24

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9 10 11 12 13 58 and Gap, and we got to the point where if you took a look at it, we weren't getting, I mean we kind of plateaued as an organization with both of those groups, with both Kim and Gap.

And, you know, it was probably the time to change horses.

If you kind of look a approach, 10had a different approach than and you know, I think bringing in a new style and a new approach has been healthy for the site.

So I thin1i3.

recognized that there was a change needed at a lot of different levels, both with his leadership and then as well as the consultants that he had supporting him.

SR. SPECIAL AGENT TEATOR:

Was the GAP contract also terminated?

.*R. KEENAN:

GAP, they'd be contractors.

)C-14 15 16 17 18 19 20 21 22 23 24 25 Right.

They were contractors, and their contract was terminated.

Frankly, we didn't bring in, you know, a HRD consultant until just early this year.

So we went ten, basically ten months or so until it was the January time frame.

So roughly what is that?

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 specific job functions, and then their contract is terminated, ends on June 1 5 th.

SR.

SPECIAL AGENT TEATOR:

Of this year?

Yes.

SR.

SPECIAL AGENT TEATOR:

Okay.

So they were just brought in that's the' SR.

SPECIAL AGENT TEATOR:

Okay.

I saw their name on tall box down there.

Yes, the big tall people.

SR.

SPECIAL AGENT TEATOR:

On the jar.

I'll look for them.

They were at Millstone.

You'd probably remember.

He's like 6'8" and she's like 6'2", and I mean they are really tall people.

They were at Millstone, and they worked for me inlo They're in here for a defined scope of work.

They do it and they're gone.

Tot a big one for an in-house kind of consultancy.

He likes to use those kinds of people, bring them in, do short-term and then turn around and bring somebody else in, or else bring those people back in after a break, because he sees more value in that, getting the boost, and using them as like a catalyst.

SR.

SPECIAL AGENT TEATOR:

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 anything more you want to add todayqmU-

• No.

SR.

SPECIAL AGENT TEATOR:

Jeff, is there something you want to go over with your client?

MR.

KEENAN:

Yes.

We can take a quick break and see if there's anything further.

I think we're done now.

SR. SPECIAL AGENT TEATOR:

All right.

We'll take one more break and then we'll be --

we'll finish up.

(Off the record.)

SR. SPECIAL AGENT TEATOR:

It's about five of 1:00.

I don't have any other questions.

Is there.something you want to add?

No,-.there's nothing else I would like to add.

SR. SPECIAL AGENT TEATOR:

Okay, Jeff?

MR.

KEENAN:

Nothing further.

SR. SPECIAL AGENT TEATOR:

Okay.

This interview is concluded.

Thank you very much.

Thank you.

(Whereupon, at 12:55 p.m., the interview was concluded.)

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