ML20078L773
| ML20078L773 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/13/1983 |
| From: | Morgan R DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20078L617 | List: |
| References | |
| FOIA-83-434 NUDOCS 8310240062 | |
| Download: ML20078L773 (120) | |
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U NIT ED STATES OF A MERIC A NUCLEAR REGULATORY C O M MISSIO N i
BEFORE THE A T O MIC SAFETY AND LI C E N SIN G BOARD In the Matter of: )
.)
DUKE P O W E'R C O M P A N Y ,- et al.) Docket Nos. 50-413 '
) 50-414 (Catawba Nu cle a r Station, )
Units 1 and 2) )
k e
JULY 13, 1983 l
1:17 P . M.
l D E P O SITIO N O_F :
ROBERT A. MORGAN l
s f ll l
Ogo2jjo62830810 Evelyn Berger Associates AHLERS83-434 PDR STENOTYPE REPORTING SERVICE P. O. SOX 19444 I cuan t. OTTI. MomTW can cLIM A AA11A
2 1 A PPE ARANCES:
2 ROBERT GUILD, ESQ.
Columbia, S. C.
3 C ouns el on Behalf of Int e rve no r, Palmetto 4 A llian c e C o rp o r ation 5 RON A LD L. GIBSON, ESQ.
. C h a rl o t t e , N. C.
6 C ouns el on Behalf of A pplica nt, Duke Powe:r 7 Company 8 Also Pr e s en t:
9 Roger Ou elle t t e Duke Power Company 10 Glenn H. B e ll 11 Duke Power Company 12 W illia m O. Henry Duke Power Company 13 Phil Jos 14 Palmetto A llia nc e 15 Betsy L evita s C a r olina En vir o n m en ta l 16 S tu d y Group 17 18 19 I N D E X 20 WIT N E S S DIR E C T CROSS 21 R ob e r t A. Morgan 3 117 22 23 24 e 25 kVELY% GERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROLINA
2A 1
EX H I B I T S NUM BER DESCRIPTION PAGE 2
Morgan Exhibit Graph 31 3
One 4
M or gan Exhibit N ote s of Mr. Zwis sle r's Two inte rview 32 5
6 7
8 9
10 11 12 13 14 15 16 l
17 i
18
(
i 19 20 21 22 23 24 l
25 EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
Morgan - Direct 3 1
The D e po s ition of Robert A. Morgan is 2 taken at the corporate o f fic e s of Duke Power Company ,
3 C ha rlo tt e, N o r th C a r olina, on this th e 13th day of 4 July, 1983, in the presence of Robe rt G uild , Attorney i
5 for th e Intervenor; and Ronald L. Cibson, Attorney 6 fo r the A p plic a n t.
7 All f o r malitie s as to c a p tio n , c e r tifi c a t e 8 and tr a n s mi s sio n are waived. It is agreed that Lynn 9 B. G illi a m , Notary Public in and for the State of 10 North C a r olina , may take said D e po sition in ma chin e 11 s ho rthand and tr an s c ribe the same to typewriting.
12 Said D e po sition is taken subj ec t alone to 13 te s timony for competency, relevancy and ma t e ri alit y; 14 and a ll obj e c tio n s , save as to the form of qu e s tio n s 15 asked, are reserved until the H e a rin g.
16 17 ROBERT A. MORGAN, 18 having been first duly sworn to tell the truth, was 19 examined and te s tifie d as f ollows :
20 21 DIRECT E X A MIN A TI ON 22 BY MR. GUILD:
23 Q State your full name and business address 24 for the Record, please, sir.
3 A Robert A. M o r g an.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH C AROLmA
Morgan - Diroct 4 1 Q And your business address, sir?
2 A Duke Power C om pany, Box 223, Clover, 3 South C a r oli na , 29710, 4 Q And that is at the C atawba Nuclear Station ?
5 A T ha t's correct.
6 O In what c a pa city are you employed by Duke ?
7 A My job is Senior Quality A s suranc e E n gi-8 neer, Projects.
9 MR. GIBSON: Mr. G uil d, I wanted to 10 do this before you got s ta r te d; I as sume 11 we are proceeding under the same s ti pula -
12 tion s that we have ope ra ted under with 13 respect to the other D e po sitio n s ?
14 MR. GUILD: Yes.
15 MR. GIBSON: Pursuant to your 16 Notice of D e po si tio n and e a rlie r te s timony ,
17 we are m a ki n g available a copy of a three 18 page draf t that was prepared and main-19 tained by Mr. M o r ga n.
20 He will answer s pe cific que stion s, 21 but for general identity there was a quest ion 22 of whether anyone took a look at the numb e r 23 of NCIs before, af te r and during the 24 Welding Inspector concerns.
25 D a vi s o n and perhaps I b elie v e Mr.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Morgen - Diroct 5 1 s o m e o ri e else in dic a t e d it was done and 2 done by Mr. Morgan.
'l 3 This is s o m e thin g that was in M r.
4 Mo r g a n's file s , and as I say, pursuant to 5 the N o ti c e of D e po sition, we had him b rin g 6 a copy.
7 I show you the original and will make :
8 a copy available to you (in di c a tin g ) . As 9 you can see, the numb e r s are in red, and to s om e of the copies may not be as legible; 11 but I think it comes th ro u gh le gible.
12 Also with respect to the copy of the 13 Zwi s s le r notes r e s p e c tin g Mr. M o r gan, 14 our copy is about as bad as your copy.
15 MR. GUILD: Did Mr. Z wi s sle r give 16 you his original notes? Did he present 17 original not es ?
18 MR. B E L L: I would have to check 19 to see what I do have.
20 MR. GUILD: L e t 's see if we can go 21 f o rw a rd, and we may need to come back tci 22 this.
23 24 BY MR. GUILD:
25 O Mr. Morgan, my name is Robert Guild, _
EVELYN SERGER ASSOC 8ATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Mor gan - Diroct 6 1 and T. am C o u n s e l. - f o r P alm e t t o A lli a n c e . Are you 2 aware that my C li e n t s are Intervenors in the o p e r a tir g ,
3 license p r o c e e din g for the Catawba Station ?
4 A Yes.
5 O And we have fil e d for litigation a contenti on 6 referred to as C on t e ntion Six that qu e s tion s the 7 adequacy of Q u a li t y A s su ra nc e at the Catawba S t a tio n .
8 A Yes.
9 Q I will show you a copy of that contention to and let you f a milia riz e your s elf with it (in dic a tin g) .
11 M r. Mo r g an, I want to direct your a t t e n tio n to Pages 12 Three and Four of the December 31st, 1982, A n s w er s 13 of Duke-Power Company to que s tion s po s ed by Palmet to 14 on Co nt en tio n Six; and they are there, the text is 15 quoted if you will take a moment and read the indent < -
16 e d, single apaced quotation.
17 It begins at Page Three and extends over 18 to Page Four.
19 A A ll right, sir; are you talking about this 20 s e c tio n here (indic atin g) ?
21 Down to the Sottom there.
Q 22 A Okay.
23 A ll right, sir; have you seen the text of O
24 C o n t e ntion Six before?
25 A No, I don't think so.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROLINA
Mor ga n - Diroct 7 1 Q A ll ri g h t , sir; that is fin e if you will 2 hand that back to me, Mr. M o r ga n. I will a s k you 3 a series o f que s tion s , and the purpose of my 4 que s tion s is to gather in f o r m a tio n and evidence for 5 use in the o p e r a tin g li c e n s in g proceeding on the 6 subject of C ont e ntion Six.
7 If I ask a que s tion and you do not under-8 s tand the que s tion or I am not being clear, please 9 ask me to rephrase or t e ll me you don't understand.
10 W ha t will be done with this D e po sitio n is 11 your te s timony will be transcribed, and unless you 12 ask for clarification, we will see my que s tio n and 13 your answer, and I will presume that your answer is 14 responsive, and that you did understand.
15 Give me a g e n e r al d e s c riptio n, if you 16 w o u l d. , of your dutie s as a S e nio r QA at the project.
17 A I am responsible for QA technical e n gin e e r-18 ing and te chnic al f unctions as it relates to the QA 19 D e pa r tm en t at the proj e c t.
20 I am responsible for the c olle c tion and 21 documentation of how the plant was b uil t, the l
l 22 c oll e c tion of all the QA Program documents.
l l
23 Q Mr. Mo r gan, would you relate, please, 24 your work history with Duke Power, when you came 25 to work for the company and a pp roxima tely the dates i
i EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAROUNA
Morgan - Direct 8 1 at which you have held the various po sition s you hav e 2 held, sir ?
3 A I came to work June 22nd, 1970. I work-4 ed at Oconee Nuclea r Station as an A s sis tant Con-5 s t ru c tion En gin e e r.
6 I worked p rima rily as a Tech Support for 7 the C raf t ac ti vitie s and inte rf a c ed with D e's i g n 8 E n gin e e rin g D e pa r tm en t.
9 I m ov ed f ro m a po sition at Oconee where I 10 worked in the field to A s sociate Field E n gin e e r 11 O f fi c e , and the approximate date would be probably 12 1973.
13 At that time I was responsible, and I 14 worked for the Senior Of fic e E n gine e r. His title is- -
15 I can't r e c a ll his exact title back th en--and I was 16 r e s ponsible f o r processing the a d mini s t r a tiv e duti e s 17 of the o f fi c e .
18 I handled Fire P r o t e c tion, Se cu rity, and 19 Home Purchase Plans. We transferred a lot of 20 p eo ple from Oconee to M c G ui r o at that time.
21 O Where were you located at that tim e ?
22 A Still at the same lo c a tio n, Oconee Nuclear 23 S ta tio n. I was at O co ne e until about September, 24 1974, and then I was assigned to the D e s ign En gin e e r-25 ing De pa rtm ent of Duke Power Company here in EVELYN B ERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAROUNA
Morgan - Direct 9 1
C ha rlott e; and I was there, I worked there for one 2 year in the Structural S e c tio n of D e sign Engineering 3 r e s pon sible for designing s t ruc tu ral steel for 4 McGuire and some ac tivitie s for C a t a wb a.
5 Also I wrote s p e cifica tio n s for procure-6 ment of design equipment such as hoists and cranes.
7 In S e pte mbe r of '75, I came into the QA De pa rtme nt E and was t e m p o r a r il y - - s o m e wh e r e along the li n e I' v e 9 lost my ti tl e s , is that impor tant ?
10 Q It w o u l d' b e helpful if you could--the last 11 one you gave me war A s sis tant A s s ociat e Field 12 E n gin ee r Of fic e, and then you moved to Design 13 E n gin e e r in C ha rlott e.
14 A I maintain ed the same title, A s s ociate 15 E n gin e e r in Design; and when I came over to QA, 16 I came over as QA E n gin e e r, C ivil.
17 That was in September of '75. I worked 18 at M c Gu ir e Nu clea r Station for a p p r o x i m a t el y six to 19 nine rn o n t h s with the QA Program at hi c G uir e.
20 I came to Catawba in M. a y of '76, and I 21 was pro mo te d to --wh e n I came to Catawba, I was th e 22 only QA E n gin e e r there.
23 The only a c tivit y we had going on was 1
1 24 b a s ic ally f ounda tio n work.
25 Q % hat was your p o s ition at C a tawb a ?
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROLINA
Morgan - Dirnet 10 1 A GA En gin e e r.
2 C C ivil ?
J A Civil, E l e c t r i c a l, .M e c h a nic al.
4 Q Everything ?
5 A Yeah, everything at that ti me. At that 6 tim e there were only two people, I was there and 7 one othe r pe rs on was there.
8 C A ll right, sir.
9 A And we started adding our work f o rce, had 10 an inc r e a s e in our work fo rce, and I think it was '78 11 that I was promoted to what was known as Project 12 Senior Q ua li< y -saurance E n gin e e r.
13 That was the title of that p a r ticula r job.
14 C At C ata wb a ?
15 A at C a t a wb a; and that was when our staff, 16 we started adding our other QA E n gin e e r s at that 17 time.
18 And on 2/1/81, I mo ved to the ti tl e of 19 Project GA En gine e r, and on I think !i e p t e m b e r - -
20 these dates are kind of dif fic ult to r e mem b er o .t a c t l y ,
21 but I tried to study thes e before I came in-- ,
22 September of '82, I was moved to Senior CA E n gin e e r ,
23 Frojects; and that is my present po sitio n to date.
24 C A ll right, sir; nt the time of your promo-25 tion to Senior QA Engineer, Pr oj ec ts, there were more EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAPOUNA
Morgan - Diroct 11 1 than one project under construction.
2 A N o, not at that tim e ; that was ba sic ally, 3 w e ll, I guess you are right. Cherokee was still 4 f u n c tio n in g.
5 It was s till staffed at that time.
6 Q Where were you located in Septembe r of '8 2?
7 A Catawba, I had been at C at awb a since May 8 of '76.
9 O What were your du ti e s before that in th e 10 p o s ition you had in February of '81?
11 A Project QA En gine e r. On 2/1/81, I was 12 responsible for th e QA Engin e e r s and the QC T e c hni-13 cal Supervisors and the QC E ngin e e r s .
14 C A ll right, sir; and how did your po sitio n 15 change in September ?
16 A In September I was only r e s pon sible for 17 the QA En gine e r s.
18 O Did s omeone else take the po sition Project 19 QA Engine e r ?
N A N o, that p a r ti c ula r job was, I guess you 21 w ou ld aay done away with, or they did not f i ll that 22 job.
23 C W he n you were Project GA E n gin e e r, h. r .
24 M o r ga n, were you responsible for supervising the 25 T ec hnical Su pe rvis o r s in the Quality Control?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVtCE. CMARLOTTE NORTM CAROUNA
Morgan - Direct 12 1
A Yes.
2 O And that would inc lu d e the T echnic al Su pe r -
3 visors who were in ch a r g e of V, e l d i n g Inspectors?
4 A Yes.
5 Q And did you h av e any r e spon sibility, h' r .
6 M o r ga n, for r e viewin g the processing of nonc on f o rm-7 ing it em reports ?
8 A Only on the basis that someone else wa s n't 9 there. T ho s e are n o r m all y handled by the QA 10 E n gin e e r s th a t work for me, and for some r e a s on 11 they were all on va c atio n or at a m e e tin g , and it 12 was not as a general p r ac tic e.
GIBSON: Excuse me, s'. r . C uild ;
13 bi R .
14 1 thin k thi s may be more legible than the 15 original copy.
16 I a s sume you will do the same thing 17 with M r. Shropshire. Do you want me to 18 give one of tho s e to Mr. Morgan?
l 19 MR. GUILD: Yes, please, if you 20 would make one available to him.
l 21 22 BY M R. G UILD :
23 O Vi h a t was your r e s pon sibility at that time 24 when you were Project QA Engineer for r e viewin g 25 the r e s olu tion of n on c onf or min g items ?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Morgan - Diroct 13 1 A The same as I s ta te d e a rlie r, that was the 2 p rim a r y r e s po n s ibilit y of the QA E n gin e e r s , and they 3 would no r mally p ro c e s s those.
4 It is r eally the same.
5 Q How about your r e spon sibility for review-6 ing the r e s olu tio n s , of r e vi e wi n g nonconforming items 7 or the r e s olution s of no n c o nf o r min g ite ms for pur-8 poses of id entif yin g the root cause of d efici e n ci e s ,
9 identifying trends in d e fici en c ie s and r eviewin g the 10 appropriateness of c o r re c tive a c tio n ?
11 A That is r e ally the same as processing 12 NCIs; that is part of the NCI P ro g r a m, and that would 13 only be on an as needed basis.
14 A gain, not in the normal flow of ac tivitie s 15 for th at .
I 16 Q How about in the course of s u p e r vi sin g l
17 th o s e who did th at func tion ? % hat was your responsi -
18 bility in that su pe rvision, Mr. Morgan?
19 Did you get support, did you r evie w the 20 raw documents; describe for me, if you will, what 21 you did ?
22 A V/ e l l, the OA En gin e e r s reported to me.
23 The people, as I e x plain e d e a r li e r , that process, the 24 non c o nf o r min g items, if they d etec ted s o m e thin g that 25 looked p e c uli a r they would brin g it to my a tt e ntio n.
l EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROUNA l
hio r g a n - Direct 14 1 That was part of their r e s po n s ibili ty , to 2 keep me advised of any problems or p o t e nti al p r o ble m s.
3 O How did they do that?
4 A They would co me a round and t ell m e.
5 Q Did they report to you in a written f o r m?
6 A No, just bring the report, itself, and say, 7 talk to me about it if they needed to.
8 Q Right, did they bring any other r e p o r tin g 9 on a regular basis that you would r e vie w to d e t e r min e 10 trends or r e vi e w appropriateness of c o r r e c tiv e a c tio n s?
11 A N o, sir.
12 Q Let me take you one step back before that.
13 In your duties as P r oj ec t Senior QA En gine e r , did 14 you have r e s p o n sibility for r e vie win g non c o n fo r min g 15 it e m s or their r e s olution s ?
16 A Project Senior QA E n gine e r is the same 17 job. I had QA E n gin e e r s that worked for me that 18 did that par ticula r work, and they do that.
19 Q Did you ever do this particular work, 20 your s elf ?
21 A Only in the early stages during the time i
l 22 period '76 to--
23 Q '79?
24 A Yeah, whe n I was a QA E n gin e e r, probably .
l 25 C And during the period '76 to '7d, you, as EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAROUNA
Morgan - Direct 15 1 a QA E n gin e e r , did the actual r e vie w that later was 2 done by pe r s on s under your s up e r vi sion ?
3 A Ask me th at q ue s tio n again.
4 O Sure; in '76 through '78, when you were a 5 QA En gine e r, you performed the r e vi e w of nonconforrn-6 ing items and their r e s olutio n s ?
7 A Yes.
8 O Mr. M o r g an, tell me fir st, give me a brie f 9
summary of your professional background and training-10 prior to j oinin g Duke Power.
11 A Let me see, I graduated from Virginia 12 P olyt e chni c In s titu t e in 1970, and I took you th ro u gh 13 my work history.
14 Q Sure, what was your degree in ?
15 A B.S. in C i vil En gin e e rin g, and I have 16 attend ed lots of s e min a r s a nd I'm a Re gis tered Pro-17 f e s sional En gine e r, North and South C a r olin a.
18 At one tim e I was a R e gis ter ed Waste 19 Water T reatment Plant Ope rato r and Wate r Treatment 20 O p e ra to r.
21 Q And what kind of work did you do af ter you 22 got your Civil Engineering degree?
23 A I came to work f or Duke Power. It was 24 two weeks later.
D Q You don't have any training or experience EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
Mor gan - Direct 16 1 in welding ?
2 A Only s e min a r s that I' v e attended and any 3 background I may have picked up in De sign Engineer-4 ing.
5 Q So you a re not a welde r ?
6 A No, sir.
7 Q Now C oun s el made available a co py of a 8 document that he d e s c rib ed as a gr aph showin g numbe rs 9 of NCIs.
10 Did you prepare this or was this prepared 11 by someone under your s up e r vi sio n ?
12 A It was prepared by someone under my 13 supervision.
14 Q W hen was this prepared?
15 A W ell, it was prepared s omewhe re around 16 the end of J anua ry or February, and then it was pre-17 pared on a daily basis.
18 I* vas kept up to date on a daily or I thin k 19 it was "i % h); basis that we updated this p a r tic ula r 20 chart.
21 Q J anua ry and February of what year, sir ?
U A That would be 1982.
23 C January, 1982; ts that right?
24 A A round January, February, end of January.
25 W ould it have been about the tim e of the C
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROLINA
Morgan - Direct 17 1 W elding Inspector concerns and the Task Force work '
2 A Yes.
3 O So it would be January and February, '82; 4 right?
5 A Yeah.
6 Q. A nd you began it then and kept it up to 7 date through what pe riod ?
8 A It looks like July 15.
9 Q Of what year?
I 10 A 1982.
11 Q A nd why did you do this gr aph or have this 12 graph done?
13 A Okay, the QA, I guess the CA En gine e r s 14 brought to my attention during the ti m e period they 15 could see an increase in th e number of N C1 s being 16 writte n by the W e ldin g Ins pe cto r s , and that would be 17 indicated, as you can see here on the graph on Page 18 One, around the end of January through the fi r s t par n 19 of February, at that t i m e. .
20 I us ed this as a human r ela tion s s kill 21 in dic a to r that I wanted to see ho w it used to be.
22 T his little hump here (in dic a tin g) represents a time 23 pe rio d when the final d e cis io n was made on pay.
28 By" hump," around where it says February C
3 on Page One?
EVELYN SERGER ASSOctATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Morgan - Direct 18 1 A Yeah.
2 O I can see what you are referring to, but 3 the Record, unf o rtunately, is just in words; so you 4 will have to v e r b all y tell me what you are poin tin g 5 to.
6 A Okay, so what I was tr yin g to do is measu re 7 here how the p eo ple had reacted, so I said go back 8 to the fir s t of the year, whi c h as you can see on thi s 9 p a r ti c ul a r graph, January 1st, and a pply to the 10 number of NCIs that were n o r m ally writte n by the 11 % elding In s p e c to r s , and monitor it to see what kind 12 of eff ect the situation has.
13 I' m s a yin g we carried it on out u n til it 14 s eeme d to -taper back off. In my analysis, my graph, 15 we had a little peak and it went away af ter that 16 pe riod of time, so I just s to ppe d.
17 I con sid er ed the graph r eally inf ormal.
18 Any graph I present to my s u p e r vi s io n would have 19 title blo c k s and the exact date.
l l
M T hi s is a rough, personal graph is what it 21 1.,
22 Q Did you present this graph to your manage < -
23 ment ?
24 A I've shown this graph to Mr. D a vis on, yes, 25 Q W he n did you do th at ?
l EVELYN SENGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Morgan - Diroct 19 1 A I would say it was the time, I' m saying 2 hey, I can see we have an indicato r he r e that it was 3 going up '81/'82.
4 Q So he saw this graph and was aware of its 5 existence?
6 A Yes.
7 Q Did you report on it as you went along ?
8 A Yes, he would come down once or twice a 9 week and I would s how it to him.
10 Q On the fir s t of January the graph, you 11 were probably c ele b r a tin g New Y ea r's Day, and you 12 do not have any NCIs that day at all?
13 A T hat 's correct.
14 Q What is the extreme range; what are the 15 extr em e s of the range of numbers per day of NCIs ?
16 A "0" It could be from to "11".
17 O Eleven is the most that occurred any day 18 during this pe riod ?
19 A T ha t 's correct.
20 Q Are all those NCIs in W eldin g ?
21 A T ha t's correct.
22 Q How did you e s t abli s h the universe that 23 you are measuring here ?
24 A I don't understand your que s tion.
25 Q How did you d e t e r mine w hi c h N CI s you wer e EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE NORTH CAROU:4A
Morgan - Direct 20 1 going to count on your plot?
2 A The CA En gine e r s were broken up into 3 various dis ciplin e s , and the GA E n gin e e r, W eldin g, 4 indicated ther e wa s a trend in this pa r tic ula r a r e a ;:
5 and I said w ell, we can watch that.
6 Q W ho was the QA E n gin e e r W eld e r at the 7 tim e ?
8 A Joe Shropshire.
9 Q Where did you get your data f rom ?
10 A T he s e were out of the lo g f or the proce-11 dure log. I think it is QlB or C 1.C ; that is the form 12 num be r out of the no nc o n f o r min g procedure.
13 C Okay, that is--
14 A Part of the CA P ro g ram.
15 Q It is the log of nonc onf o r min g items ? That 16 same log is used to log all the nonco nf o r ming items; 17 is that correct?
18 A T hat's correct.
4 19 Q How do you d e cid e whic h ones you are N going to count and which you wer en't ?
21 A You have to count the person initiating the 22 f o r m, so the name was given on the log. .
23 Q whose name was given ?
24 A The individuals who were writing the N CIs ,
M Q W ho s e did you count and whose didn't you EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Morgan - Direct 21 1 count?
2 A When the trend started developing we 3 counted the work in this p a r tic ula r area,. which was 4 W elding In s p e c ti on.
5 Q These were th e ones initiated by W elding 6 In s p ec to r s ?
7 A T ha t's correct.
8 Q A ll W e ?. d i n g Ins p ec to r s ?
9 A les.
11 A No. i 12 O Not all th e W eldin g Inspectors?
NDE Inspectors are not W eldin g Inspectors
~
13 A .
14 O When you say Welding Inspectors you mean 15 persons p e rf o r min g vi s ual in s p e c cio n s of weld s ?
16 A Yes.
17 Q Who have the job title V. e l d i n g Inspector?
18 A T ha t's correct.
19 Q But that is not all the people i n s pe c ting 20 welds; is it?
21 A T ha t 's correct, no.
I 22 Q P eo ple doing NDE and RT are in s pe ctin g 23 welds ?
24 a That's right.
25 Q And you didn't graph that?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Morgan - Direct 22 1 A No.
2 Q Do you maintain or have pre pa red und er 3 your su pe rvision, Mr. M o r gan, any other trend 4 analysis of NCIs at C atawb a ?
5 A No.
6 Q Who does the other trend analysis ?
7 A QA Manager, T e c hnic al Services.
8 O Who is th at ?
9 A W. O. Henry.
10 Q Mr. Henry does that analysis; did Mr. Hen ry 11 do that trend analysis du ri n g this pe riod ?
12 A Yes, I b eli e v e so. It is his r e s pon sibility 13 to perform trend analyses, so I as sume that he did.
14 Q Who does trend analyses of R 2 A s ?
15 A It is the r e s pon s ibilit y of the C o n s tr uc tio n 16 D e p a r tm en t.
17 Q W ho in pa rticular ?
18 A I' m t r yin g to think of the title, it is the 19 O ffi c e E n gin e e r who reports to the Engineering Manag er 20 who reports to the Project Manager.
21 Who is the O f fi c e En gine e r ?
Q U A Larry Vincent.
23 Q And M r. Vincent, has he been there for 24 awhile ?
25 He has been there a couple of years.
A EVELYN SERGER ASSOCIATES, STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAROUNA
, __ _ _,_.- -- _ ~ _ , , . . , , _ . .. ,. , _ _ _ _ . - , . . . . _ , _ _ , - . _ _ - _
M or gan - Direct 23 1 Q Since '81?
2 A I' m not ex a c tly sure, maybe '82, '81 or '8 2.
3 Q Do you know who held that po sition before 4 he did ?
5 A That is a new position.
6 Q Do you know who is responsible for trend 7 analyses of R2 A 's before Mr. Vincent?
8 A No.
9 Q Was anyone responsible? Did they trend 10 R 2 A 's before Mr. Vi nc ent's time ?
11 A I don't r e c all.
12 MR. GIBSON: Excuse me, ar e you 13 referring to R Z A 's in welding or R 2 A 's 14 g e n e r ally wherever they were used?
15 MR. G UI L D : Whatever the a p p r o p ria t e 16 answer is, I didn't know what his answer 17 would be to that.
18 MR. GIBSON: I am asking you in you r 19 que s tio nin g.
20 MR. G U IL D : I' m not kno wle d g e a bic 21 on the subject. .I want to know f ro m the 22 Witne a s.
M Do you know what the answer was?
24 THE WITNESS: What is the que s tion M a gain ?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE. CHARLOTTE. NORTH CAROUNA
Mor gan - Direct 24 1 BY MR. G UILD :
2 Q Are trending of R2 A's in weldin g, and who 3 is responsible for trending R 2 A 's in w e ldin g ?
4 A The Office E n gin e e r.
5 Q Larry Viacent, and before M r. Vincent?
6 A B ef o r e Mr. Vincent, the % elding In s p ec to r s 7 did not use R2A's. It was not their p r ac tic e to use 8 R Z A 's .
9 O Who trended R 2 A 's other than in areas of 10 welding before Mr. Vincent?
11 A I can't r e c a ll, it may be the QA M an a g e r, 12 T e c hnic al Services, a g ai n.
13 Q Mr. Henry?
14 A Yeah.
15 Q Okay, when did they begin t r endin g R 2 A 's 16 in welding ?
17 A I' m trying to r e c all wh e n the new revision 18 procedure came out. That would be I would say may- -
19 be 12 mon th s ago or 9 months ago.
20 Q Did they begin trending R 2 A 's when the 21 procedure was changed to provide for use of R 2 A's 22 in welding a s opposed to N CIs ?
23 A It became part of that procedure, yes, to 24 start trending R 2 A 's assigned to the C o n s truc tio n 25 D e pa r tm ent.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROLINA
Morgan - Direct 25 1 Q But they trenied all areas, not just W eld-2 ing, like Electrical,' M e c h a ni c al, C i vil , R e c eivin g; 3 R 2 A 's in all those areas?
4 A Yes.
5 Q Always have been?
6 A Someone did a trend analysis on R2. I 7 c an't r e call w ho , but the use of R 2 A 's was fairly 8 minimal u n t il the last revision procedure.
9 Q Minimal g e n e r ally ?
10 A P eo ple would n o rm ally use another form 11 rather than an R2A.
12 O In M e chanical and Civil as well as W eldin g ?
13 A Yeah, plu s those procedures provided their 14 own means of co r r ec tive action.
15 Q On the procesa control f orms ?
16 A Yeah, process control.
17 O So use of R 2 A 's to note deficiencie s is 18 r ela ti ve ly recent in all areas?
19 A I would say yeah.
20 Q A nd trending, therefore, f ollowed the s am e 21 p r a c ti c e to the best you can r emembe r ?
22 A I can't r e c a ll, b ut s omeone wa s responsi-23 ble for t r endin g R Z A 's.
24 MR. GUILD: C oun s el, has d e t e r min a.
25 tion be en m ad e about the a v a ilabili ty of th e t
EvELYN eERoER Associates. sTENOTYPE REPORTINO sERvlCE. CHARLOTTE. NORTH CAROUNA l
26 1
N CI trend analysis ?
2 MR. GIBSON: It wa s n't my r e call If 3 that v. a s s om e thin g you had requested.
4 you did, I' v e overlooked it in terms of my 5 memory.
It is s o m e thin g I haven't taken up wit s 6
7 management or dis cu s s ed with othe r Counse l.
8 It is not my r e c olle c tion, we may have 9 discussed it and I've f or go tten it.
10 MR. G UILD : Yes, but the trend 11 analysis is d e finit ely s ome thing we would 12 like access to and like produced.
13 MR. GIBSON: I will let you know, 14 b ut I can state to you ge n e r ally unless some 15 item in our view clearly relates to welding 16 and W eldin g In s p e c tio n, it is clearly be-17 yond the scope of Discovery and up to the 18 Board; but I will get back with you af ter I 19 talk to the other Counsel.
20 MR. GUILD: A gain, Mr. Gibson, 21 under s tandin g your position and disagreein g 22 with it so we. can move forward, we would 23 ask that you do make available those doco. -
24 ments in the W ,s i d i n g area; and we b eli e v e 25 that it is relevant in Dis co ve ry to seek EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING T ERVICE. CHARLOTTE, NORTM CAROUNA
-- , . - - - . , . . . ~ . - .- -
27 1 p r o du c tio n of tr end analyses beyond that 2 area.
3 But so we can move forward we would 4 appreciate your making that available on 5 the W eldin g area.
6 On the same point, the outstanding 7 relating area on the documentation from 8 Mr. B r adley' c t e s timo ny, the NCI e v alu -
9 ation.
10 MR. GIBSON: Our inclination is to 11 make those items r elatin g to w eldin g avail able 12 Our folks in QA have been oc cupied in 13 D e p o s itio n s or Mr. Henry or Mr. G rie r 14 is out of town.
15 Who could possibly do that in a d di ti o n i
16 af te r their r e v'i e w would be done, C ouns el 17 will hav e to take s om e time to look at 18 that so that review is simply not c o m pl e t e d.
1 19 As I say, I am not repr t e n tin g 'o 20 you that we firmly will or will not; but 21 our in clin a tio n is to make the weldin g 22 documente available.
l 23 We will need guidance f rom the Board ,
24 at the conference c all which Mr.
I expe c t, 25 McGerry is t r ying to c all for early next EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLO7E. NORTM CAROUNA
28 1 week.
2 I think that would be a good ti m e to 3 bring this up. Where something relates 4 to W elding , and we are a tt em p tin g to make 5 th o s e thin g s available, I just cannot tell 6 you when th at other s tuff will b e available 7 or that that decision is fi r m .
8 MR. G UILD: Okay, I guess for pur-9 poses of planning, I am t r yi n g to under-10 s tand the limitations that w o ul d, th e r ef o r e ,
11 be on the scope of the que stion to be asked 12 Mr. Morgan and th e r e m ainin g Witne s s e s; 13 and the trends and N CIs and th e r e s 'u l t s 14 of that work of that E valua tion Team are 15 areas that I b eli e v e f all within these 16 g e n tle m e n 's likely area of kn owle d g e and i
l 17 exp e rtis e; and so I would desire to ask 18 them qu e s tio n s on that area, and I want 19 the R3 cord to r e fl e c t that I will proceed l
20 now in the absence of that inf o rmatio n.
21 MR. GIBSON: You haven't obs erved 22 many limitations on the scope thus far, Mr .
23 G uild.
l l
24 Go ahead.
l 25
.....oc,.r... m ~orr.... -,~ ..-,c..c~..m m.~ .r~c ~ u~.
l . m r~..
Morgen - Direct 29 l
1 BY MR. GUILD:
2 O What is the more current experience in th e 3 number of NCIs in the Welding area, Mr. Morgan?
I 4 A I have no record of that. J 5 O Based on your kno wl e d g e and inf o rma tion ?
6 A The pro gram has changed where the use of 7 R 2 A 's can be used, so I have not c olle c t e d any data 8 past July of '82.
9 Q A ll right, sir; are you informed on how to many NCIs there are in the w eldin g area cu r r e n tly ?
11 A No.
12 O W ould you know gene rally if there is an 13 N CI in the W eldin g area? W o uld that come to your 14 a tt ention ?
15 A The only way I would know is if it would 16 be an it em that GA E n gin e e r s w ould be ad vi s e d of, 17 and they would bring that to my att e n tio n.
18 Q, Have they advised you of NCIs in the 19 W elding area?
20 a yes, 21 Q How ra a n y ; give me an i d e. a of what kind of 22 N CI s you r e vi e w e d in W e ldin g ?
23 A W ell, they may dis co ve r s o m ethin g that 24 would be reportable under the guid eline s of 10 C TR 5 0. 55E 25 or it could
- r. h a t they need to bring to my attention, EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CMARLOTTE. NORTH CAROUNA
Mo r gan - Direct 30 1 be s om e thin g that 5 ould re sult in a dd iti o n al work or 2 have an impact on the schedule.
3 Q Have they brought to your attention NCIs 4 in W e ldin g that were so r e po rtable ?
5 A Yes.
6 O R e c en tly~?
7 A No, none this week.
8 Q W ha t is the mo s t recent one you have beer.
9 involved in?
10 A As it relates to W eldin g ?
11 Q Yes.
12 A The mo s t recent one I can r e c all would be 13 an item id e n ti fi e d during NRC In s p e c tio n of a low 14 spot in a weld that was not acceptable, which I think 15 was later, I think we got an NRC violation out of 16 th a t .
17 It was a support restraint.
18 Q What kin d of sys tem?
19 A pipe hanger.
20 Q And how was the item detected?
21 A NRC Inspector, during his in s p e c tio n, foun d
" the spot which was low, which had already been 23 accepted by Vi e l di n g Inspectors.
24 Q What ti m e f rame was this; when had this ,
25 happened?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Morgan - Direct 31 1 A Probably two or three years ago.
2 Q '81?
3 A Yeah, 881.
4 Q T hi s was before the change in procedure?
5 A W hi c h one?
6 O The change to use R 2 A 's instead of N CIs 7 in the weldin g ? .
8 A Yes, it was before th at.
9 O Any NCIs in weldin g that come to your 10 attention since the procedure changed?
11 A Not that I can r e c all.
12 O Do you have a copy of the notes there, the 13 more le gible copy of notes?
-- 14 A Y enh.
15 Q L et 's do this; let's ide ntify this as the 16 fi r s t E xhi bi t to your D e p o s ition, call l' Exhibit One.
17 (Wh er eupon, the document referre d 18 to as graph was marked and received 19 by the Court Reporter as Morgan l
N Exhibit One and enter ed into the 21 R eco rd. )
22 23 BY MR. GUILD:
24 O M r. M or gan, if you ta ke a moment and 25 review the notes, you were in ter viewed by Mr.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERylCE, CHARLOTTE. NORTM CAROUNA
Morgan - Direct 32 1 Z wi s s le r, the consultant to the Welding Inspector Tas k 2 Force?
3 A Yes. l l
4 Q On or about the 3rd of February, 1982?
5 A Yes.
6 Q A ll right, sir; and I have no te s here that 7 were produced in Discovery that I b e li e v e r e fle c t 8 that i n t e r vi e w.
9 Why don't you take a look at them and I 10 will look through them as w e ll .
11 MR. G UI L D : L e t 's mark these notes 12 as Exhibit Two, please.
13 ( W h er eu po n, the document referred 14 to as notes of Mr. Zwis sle r 's inter-15 vi e w were marked and received by th e 16 Court Reporter as Morgan Exhibit T w's 17 and enter ed into the R e c ord. )
l 18 l
19 BY MR. G UI L D :
20 Q A ll ri gh t, sir; now you and Mr. Zwia ale r l
21 had this me e ti ng, and I gather he acked you some l
l 5 que stion s and took notes on your answars?
l 23 A He asked me some que s tion s. I don't re-l 24 c all him taking any notes.
l t
25 L e t 's see if these notes r e fle ct your con-C l
l avetvu manoen associares. stumorna nerontina sanvice. cuantoria. Nonrw camouna l
\ -- . _ _ . _. . -.
Morgan - Direct 33 1 v e r s a tion. Af te t notin g your background and a good 2 bit of what you've al r e ad y told me under the heading 3 " P r oble m, " on Page One it says here:
4 "P r eviou sly Da vis on handled one on one 5 with inspectors. Now Mo r ga n, through Shropshire, 6 s upe r vis e s inspectors."
7 Does ' hat r e fl e c t what you told him ?
8 A Yes.
9 Q Mr. D a vi s on used to do the fi r s t li n e 10 r eview of the W eldin g Inspectors. He r e vie w e d the 11 non c o nf o rmin g it e m s that were o riginat e d ?
12 A Yes.
13 Q Is that the nature of the one on one r elatio n-14 s hip ?
15 A What that says is that when his three 16 s up e r vis o r s came to work for me on 2/1/81, I had 17 five p e o pl e reporting to me instead of two, in s t ead 18 of previously.
19 That ,v a s when QC and QA came together.
20 I did not r e vi ew N CIs. T h at was the r e s po n s ibili ty 21 of the QA Technical Supervisors an d th e QA Engineer s.
22 T ha t was s o me thin g that I did diff e r ently 23 than Larry did. Larry wo uld think dif f e r e n t than I 24 d o.
25 C You just lost me a little bit. P r e vio u s ly EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Morgan -
Direct 34 1 D avi s o n handled one on one before the change. He 2 was r e s po ns ible f o r r e vi e win g the N CIs ?
3 A He could have d ele g a t e d that down to his 4 T echnic al Supervisors, but that was s ome thing he 5 wanted to do so he did.
6 Q A f te rwa r d s you had the r e s p o ns ibility and 7 you dele gated that ?
8 A T hr ou gh the QA Engine' re s and QA T e c hnic a l 9 Sup e r vis or s.
10 Q Wha t po s itio n does Mr. Shropshire hold?
11 A QA En gine e r, V eldin g.
12 Q How was it structured after the change?
13 A Okay, my title was Project E n gin e e r, QA 14 E n gin e e r, and I had five people r e po r ting to me af ter 15 the change.
16 Q Who are the fiv e people that reported to 17 you?
18 A H. D. M a s o n.
19 Vihat po sition did he hold ?
Q 8 A QA E n gin e e r , Civil and Electrical.
21 Q A ll right, sir.
U A Joe Shropshire, QA E n gi n e e r , NDE, 23 Mechanical and W eldin g.
24 Has that been hi c po sitio n all along since Q
25 that change?
EVELYN SERGER ASSOCIATES, STENOTYPE REPORTING SERVICE. CHARLOTTE, NORTH CAROUNA
Mor gan - Diro t 35 1 A Yes.
2 O T hird ?
3 A C ha rl e s Saldwin, C. R. Baldwin; he had 4 r e s po n s ibility for % eldin g--N D E.
5 Q QA En gine er ?
6 A OA T e c hnic al Supervisor.
7 O All ri ght, Welding and NDE7 8 A T ha t 's correct. T. A. 3arron.
9 Q How do you s p ell hi.s 1-st name ?
10 A 3-A-R-R-O-N; he was the QC E n gin e e r, 11 Mechanical.
12 Q Okay.
13 A And J. N. W a rr en. ,
14 Q Warren?
15 A W ar r e n; he was th e QC E n g in e e r , Civil 16 and Electrical and R e c ei vi n g.
17 MR. GIBSON: I didn't get that last 18 thing.
l I
j 19 THE WIT N E S S : And R e c eiving.
l 1 -20 1
21 BY MR. G UILD:
r l 22 And where were these people before the Q
l 23 2/1/81, l change?
l 94 A The last three, Saldwin, V/ a r r e n , and l
l 25 Earron, reported to Mr. D a vi s on.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHART.OTTE, NORTH CAROLINA
Mor gan - Direct 36 s
, 1 Q Before?
2 A B e f' o r e ; and Shropshire and Mason reported 3 to me.
4 Q A ll right, sir; af ter the change when you 5 took over those two additional people, you did not 6 do the direct r e vi e w of the NCIs. You delegated 7 that?
8 A T ha t's correct.
9 Q To the T echnical Supe rviso r s ?
10 A Yes, at this ti me there were s till two 11 r e views in the course of the program, the three 12 people that repo rted to Larry reviewed it fir s t and 13 it came to the QA Department where it was known as 14 the QA R e vi ew.
1 15 I' m saying there were two r e vi e w s .
16 Q B ef or e ?
17 A Yeah, so we kind of double checked our-i 18 selves.
19 Q And now and af te r the change?
M A How was the r e vie w process alter ed af te r 21 the c h a n g e --i t r em ain e d the same. The only 22 diff e r enc e was Larry was no longer there, and NCIs M were reviewed by those th r e e people rather than by i 24 Larry.
U Q I see, a ll right, sir; let's look at Page EVELYN SERGER ASSOCIATES. STENOTYPE REPORT 1NG SERVICE. CHARLOTTE. NORTM CAROUNA
Morgan - Direct 37 1 Two of your notes then. What is "use QC i n qui r y 2 f o rm to obtain answers to qu e s tio n s . " W ha t does 3 that r ef e r to ?
4 A On 2/1/81, when we did have our reorgani-5 zation and those three p e o ple and the p eo ple r epo rt-6 in g to t h e m, which was a new one hundr ed o r one 7 hundred fif ty people th at came to the QA D e pa r tme nt, 8 I, my s elf, felt, to make sure that we were communi--
9 c ating with those people or make sure they wanted to to c o mmunic at e with us, came up with an informai 11 QA/QC inquiry was the name of the f orm wher e if an 12 inspector had a qu e s tio n about a procedure or any 13 te chnical ~ rela ted subject, he could address that 14 qu e s tion.
15 He put his que s tion down in w riting, and 16 that way we could address it in writing so we had
! 17 that inf o rmal process set up for that.
18 We had new mana gem ent, and we wa nt ed to l
19 make sure that they had the o p po rtunity to talk to us. ,
l 20 Q Was that f orm used?
21 A Yes.
22 O F r e qu ently ?
23 A No.
24 Q Inf r eque ntly ?
25 A In f r equ e ntly, yes.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAmouNA
Morgan - Diroct 38 1 Q Did you ever get Weiding Inspectors using 2
th a t f or m to raise que s tio n s about a p plic a ti on s of 3 Procedure?
4 A Yes.
5 O F r e qu ently ?
6 A No.
7 O How many time s did that procedure get a used, form get used, if you know?
9 A Maybe five, I don't know, th a t 's a guess.
10 Q Fine, and you provided written responses 11 when the form was used?
12 A Yes.
13 O And did you m ain tain those documents ?
14 A Yes.
15 O Y ou 'v e got the m in your file s ?
16 A Yes.
17 O Were any of the concerns expressed by 18 W eidin g In s p ec to r s expressed thr ou gh the use of this 19 inquiry form?
% A No.
21 Q Any of the same subjects raised on the 22 inquiry form?
23 A No.
24 O What inquiries by W eidin g Inspectors were 25 received on those forms ?
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Morgan - Direct 39 1 A I really can't r e c all; see it was an inform al 2 process, just a s k qu e s tio n s . They might say why do 3 we have to do this, well, because the code--and we 4 quote them a paragraph in the code or make them a 5 copy, show them why.
6 It is an informal process of trying to 7 develop s om e r elation s hi p with them. Their super-8 visor may not know the answer to the que s tio n and 9 say let's go in and we will get us an answer on this 10 que s tion.
11 Q Did the W eldin g Ins p e cto r T a s k Force i
12 r e view your inquiry forms ?
13 A Not that I r e c all .
14 Q Did Mr. Z wis sle r express any inte re s t in 15 looking at your inquiry forms ?
16 A Iknow we talked about the process of what 17 an inq ui r y was; but I don't think he looked at any, 18 no.
19 G Were any s i gnifi c a nt concerns or que s tion s 20 raised through those anquiry forms ?
21 A No. N o r m ally if they asked us a qu e s tion 22 we wo uld an s w e r. If it was si g nific a nt we would say 23 you need to write an N CI or put it on another docu-24 m ent, d e p endin g on what their qu e s ti o n led us to.
3 Ican't r e c a ll that.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Mor gan - Direct 40 1 Q What if it were a qu e s tion that said Larry 2 D avis on or Cha r le s B a ld wi n is imprope rly voiding 3 many NCIs ?
4 A W ell, it was set u p, we wo uld n o t--le t 's 5 see--I didn't get into qu e s tio n s lik e that. It was set 6 up for answers, technical qu e s tion s f rom the T e chni-7 cal Group on technical subjects.
i 8 If a qu e s tion like that were to arise, it 9 would not come up on that document.
10 Q How about technical qu e s tion s on procedur e s?
11 A N o r ma lly it would be handled through the 12 supervisor, and I would say yes, on occasion we had 13 a que s tion about a procedure.
14 O L e t 's go back to these notes now. % hile 15 in C o n s tru c tio n, Beau Ross had two % elding Ins p e cto r s 16 r e p o r tin g to him, and that was before the '81 change.
17 Is that what you are referring to?
18 A That was in the real early stages of 19 c on s t ru c tion when they were adding to the work force .
20 Right, Mr. Ross had 26 r e po r tin g to him ?
Q 21 3 1,m not ex a c tly --I would say a good many 92 p e o ple.
23 Q That number is not exact, but a large 94 number r e po rtin g to hi m ?
D A Yeah.
EVELYN SERGER ASSOCIATES, STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CARCUNA
Mor gon - Direct 41 1 Q Were there o th e r s holding Mr. Ross' 2 po sitio n at that time ?
3 A N o, he was the only supervisor.
4 C He was the only supervising person or 5 technician that held that po sition ?
6 A Yeah.
7 Q A nd it says here, "Que s tio n ability to 8 supervise this m a n y. " Vi a s that your que stion ?
9 A N o, he didn't report to me at this ti m e .
10 Q I' m saying this is your int e r vi ew with Mr.
11 Z wi s sle r when it says, " Que s tion ed his a bili t y, "
I 12 who were you reb,rring to?
13 A 1 guasc i was probably s ayin g that was a (
I4 lot of p e o pl e for one person to keep t r ack of, saying 15 it would be dif ficult to keep up with tw e n ty - s ix peopl e 16 or twe nty- fiv e.
17 Q As a re sult V. e l d i n g Inspectors were operat ing 18 ind e pe nd ently ?
19 g 7,,,
o 20 Q Tha t was your o pinio n, given that relation .
21 ship that was a large number of people to s uper vis e ?
22 A They wo rk ind epende ntly of their super-23 vi o o r because he probably did not get around to seei ag
.n them eve ry ins tant of the day. Most of my people 25 that report to me are within the same room or 50 EVELYN BERGER ASSOCIATES STENOTYPE REPORTING SERVICE. CHARLOTTE NORTM CAROUNA
Direct 42 MorBan -
1 feet or a 100 feet of my of fi c e , whereas in the field 2 you are spread out a little bit mo r e.
3 O Okay, "P r e s ently three supervisors and 4 W elding Inspectors resent di r e c tio n as a change from 5 p r e viou s autonomy. "
6 Do you see that?
7 A At that tim e there were th r e e V. e l d i n g 8 Inspector Supervisors. I don't under s tand the notes.
9 Q What don't you und er stan d?
10 A The last part, " resent di r e c tio ns as a 11 change from p r e viou s autonomy. "
12 O You did not express that opinion?
13 A In substance or those words; I don't use 14 " au ton om y. " I' m saying I di d n ' t say that, that is not 15 in my vocabulary.
16 Q Do you get the drif t of what he is saying, 17 that is what these c on s ult a nt s are hired f or ?
18 v; R . C 13 S O N : That is reserved for 19 Lawyers, we will have to speak to hi m .
20 THE V/ I T N E S S : I can't r e c all what 21 that means.
22 23 BY MR. GUILD:
24 Q Did you express that opinion, that the 25 change of having more direct supervision caused EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Morgan - Direct 43 1 r e s entment on the part of W eldin g In s pec tor s ?
2 A I do n' t r e c all m a kin g that s tat em ent, no; 3 but I would probably say they used to wo rk inde pe n-4 d e n tly, and bein g independent and v er y knowledg ea ble 5 of the procedure, they probably felt that they did 6 not need supervision, but now we have provided that 7 s up e r vis io n for them w hi c h they needed.
8 Q 1s that inconsistent with your opinion, 9 whether you said it to them or not; they might have 10 resented that new dir ec tion ?
11 A I don't think they re s ented it, no.
12 O "No longer can talk to the man in charge, 13 meaning they now had a supervisor between them and 14 who, Larry D a vi s o n ?
15 A No, I think that was related to the situatio n 16 that d ev elo p e d between the First Line Supervisor, 17 Mr. B aldwin , and they were h a vin g a communication 18 p ro ble m, and they were having trouble c o mmunic a tin g 19 with e ach othe r.
20 Q I' m sorry.
21 A The man in charge would have been Baldwi:2 22 in this case.
23 Q So that was r e fl e c tin g the communications 24 problem that existed at that time with Mr. B aldwin ?
U A As best I can r e c all.
EVELYN SERGER ASSOCIATES. "ENOTYPE REPORTING SERVICE. CHARLOTTE, NORTH CAROUNA
Morgan - Diroct 44 I Q " supervisor now handles W eldin g In s p ec to r s 2 and spends 65 percent of t im e in field. " W ho would 3 that be referring to ?
4 A One of the things I did on 2/1/81, I set 5 up what was known as key r e s ult areas, responsible 6 for diff e r ent jobs; and my philo sophy was th at the 7 W elding Inspectors' supervision needed to be in the 8 fi e ld to work on a day to day basis with their people ,
9 and th e y tried to find ways so they did not have to 10 handle so many admini st r a tiv e things, so I set a goal 11 for th e m to spend more tim e in the field handling the 12 day to day a ctivitie s.
13 I also set goals for QA Engine er s and 14 everyone else.
15 Q A nd the goal for the supervisor was 65 16 p e r c e nt ?
17 A Yes, I thought that was reasonable. I had o 18 p e o ple outside, they should be out a minimum of 65 19 percent of the time.
20 Q How did th ey me asur e the amount of time 21 th e y spent in th e field, if they did ?
22 A I had them r eport into their clerk how muc h 23 tim e they we re s p endin g in the field, and today how 24 did your percentage of ti m e break up: that way you 25 could analyze their job and see if maybe they needed EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAmouMA
Mor gan - Diroct 45 1 help in this particular area or this p a r ti c ula r area.
2 Maybe they were spending too much time 3 in P e r s onnel getting insurance, or maybe they needed 4 a runne r o r clerk, and you c olle c t the data of how 5 you s pend their time during the day, and you analyze 6 that and sit with them and s a y he y, where are you 7 spending your time ?
8 It is just r e ally a m an a g e m e n t tool I used 9 to analyze t h ei r availability.
10 Q Wha t else did you have them r e p o r t'?
11 A On this pa rticula r goal as far as time ?
12 Q At this time what kind of r e p o r ti n g did you 13 in stitute beyond, in addition to the time t h e y sp e n t 14 in the field and doing other jobs?
15 A I think th a t was th e major p o r tio n of their l
16 j o b, and I can't r ecall. I know we wanted to make i
17 sure they were r eall y g e t tin g out in the field.
18 Q Oka y now, you are talking about Mr. Baldwin, 19 the level above? .
20 A N o, this wo uld have been the Fir st Line 21 S up e r vi s o r.
I i
22 Q Mr. R os s and the people at his level of 23 l
s up e r vi sio n ?
24 A Yes.
25 The Sup e rvi sin g T echnicians ?
Q EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Morgan - Diroct 46 1 A T ha t's correct.
2 O " F e els issue is 100 percent pay pr o blem. "
3 Did you express that to Mr. Z wis sle r ?
4 A As I r e c a ll, the issue was why did the 5 technical concerns come up.
6 Q Y es ?
7 A Yes, that is what I feel.
8 O Wha t did you say to hi m, you thought it 9 was 100 percent a pay problem?
10 A y,,,
11 Q And what did that m e a n, what was your 12 understanding then of the technical concerns? What 13 was your belief about the technical concerns?
14 A I believed that the inspectors felt that 15 the work that they had accepted was acceptable, and 16 that when they were told that their pay would be 17 reduced they f elt they had s ome one--they want e d to 18 b la m e it on someone; and they wanted to hold s om eo n e 19 r e s po n s ibl e for g e ttin g their pay grade reduced.
20 W ho was that?
Q 21 In my o pinio n they held La rr y Davis on A
22 responsible for that reduction in their pay rate.
91
~ W ha t was the r e la tio n s hi p between that Q
o4
~
and the t e c hni c a l concerns in your o pinio n ?
A R elation ship between those two?
EVELYN BERGER ASSOCIATES, STENOTYPE REPORTING SERVICE. C*eARLOTTE. NORTH CAROUNA
.'.t o r g a n - Diroct 47 1
Q Yes.
2 A They c all e d it lack of support, they said 3 we have had lack of su ppo rt in the past and we have 4 a lack of support no w; and as I recall they said we 5 have lack of suppo rt in the pay issue; it is all tied 6 together, 7 If you don't support us on pay, you won't 8 s up po rt us on anything. T ha t is just my opinion.
9 O What was your o pinio n about the technical 10 concerns?
11 A My o pinio n, I don't understand your 12 que s tion.
13 O I' ve f ollowe d you so far, but I want to 14 understand your opinion on the technical co nc erns.
15 A My opinion on the technical concerns, ther e 16 were qu e s tio n s that needed to be addressed and 17 answered, and it was our r e s p on sibility to address i
- 18 and answer those, and that is what we did.
1 19 Q But it is 100 percent a pay p r oblem ?
20 A My s peculation would be if they hadn't 21 reduced it then the y may not have had a ny con ce rn s.
t I
- O Okay, had them or expressed them ?
23 A Had them.
l 24 Q What does that say about the technical 25 concerns?
I
.m,~ . . . . ...oci. . .. . . ~or... .. 1,~. .m.c. . c omom. ~om c. u .
Morgan - Direct 48 1 A As I s aid e a rlie r, if p e o pl e have concerns 2 I think it is our r e s po n s ib ility in ma na g eme nt to 3 evaluate those technical concerns, to in ve s tigat e then ;
4 and that wa s what was done.
5 M aybe I didn't understand your qu e s tio n.
6 O I guess I'm trying to see if I am clear on 7 your opinion. I want you to state your opinion and 8 understand it and have it clearly stated.
9 You think it was a pay issue; you said tha t to in the note to Mr. Z wi s sle r, and you have c o nfir m e d 11 that, and you did not think the concerns would exist 12 except for the pay issue?
13 A T ha t 's correct.
14 Q They would not be stated, but you als o 15 thought they wou ldn' t exist except for the pay?
16 A That's corract.
17 O Concerns were expressed, concerns were 18 held and the W eldin g Inspectors b e lie v e d there was a j 19 p r oble m.
l 20 What was your o pinion about the problems 21 that they ul tim a t ely did express?
l 22 A I would s ay that those were thin g s th at 23 may have been bothe rin g them or bothered the m at l
24 one time.
l l
25 They did not like the an sw er they got, and EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CARouMA
hi o r g a n -
Direct 49 1 they did not c om munic a t e well enough with their 2 s up e r visio n to get it straightened out.
3 At the time supervision was s a ti s fi e d and 4 management was s a ti s fie d, but the inspectors did not 5 f e el comfortable with the answer, but he accepted it 6 at that ti me , and when given the o p p o r tunit y to come 7 up with some real r ea sons of lack of support, they 8 said w ell, what can I think of where I may have had 9 lack of suppor t, and that is what a lot of the m came to up with.
11 Q They came up with a pretty good, long 12 list; didn't the y ?
13 A Yeah.
14 Q Are you trying to tell me, am I reading 15 you c o r r e c tly you did not think they were valid ?
16 A On 2/1/81, when I became Proj ec t QA 17 hianager, if they had concerns, their m ana g e ment th an 18 they had problems with was no longer there; and they 19 would c o me .to me and I was a diff e re nt manager in 20 charge, and they did not come to m e.
21 I guess it io loss of time now; I was 22 a vaila bl e and I made my field runs through the field 23 and no one felt lik e they wanted to tell me any of 24 th ei r concerns, and that is why I feel that way.
25 the m s elve s, Q Do you think the concerns, EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Morgan - Direct 50 1 were not valid ?
2 A I think if the in dividua l had a concern or 3 had a f e elin g in his mind it was v a lid , and each was 4 evaluated and each concern would be v a li d , yes; but 5 in his own mind, that is why we inv e s tig at e t he m, 6 to d e t e r min e if the r e is--
7 Q Let me see if I can approach it another 8 way: Is it your o pinio n, Mr. Morgan, because of 9 the way those concerns arose, in other words, did 10 th e y all come as a result of what you saw as 100 11 percent pay proble m, that that s ug g e s tion that the 12 concerns, the sub s tanc e of the concerns is not valid t 13 They may have felt they were valid, they 14 may have felt they were concerns; but because they 15 arose out of a pay p r o bl e m, in your judgment the 16 substance was in va lid ?
17 A N o, I think that the inspectors had some 18 le gitima t e problems that they had trouble with; but 19 I f e el they were all c o m mu ni c a tion problems.
20 O ka y, le t's go back to the notes hero, Q
21
" Hold Larry D avis on responsible for pay, lack of 22 support. F e el if Larry did not support them on pay 23 he would not s uppo rt them on anything."
24 Whose o pinio n is that that the notes O r e fl e c t, yours or the inspectors or both ?
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTt' CAROUNA
Morgan - Direct 51 1 A I would say f rom the gist of the notes that 2 I was involved with, that that came up in conve r s atio n 3 several time s.
4 Dif f e r ent W eldin g Inspectors, and Larry 5 used to be our boss and he let us down. When he 6 went to C ha rlo tt e he had their p a y re-e v a lu a t e d and 7 they told me they did not hold me responsible becaus e 8 I had only been there a short pe riod of Li m e , and 9 Larry knew ho w busy they were and how much work to they had to do.
11 So they ju st felt that he was the guy that 12 was responsible for their pay b eing re-evaluated.
13 O Was he?
14 A Was h e, it is part of our program to
!5 evaluate the jobs that we have such as W eldin g 16 Inspectors, Mechanical Inspectors, W eldin g Inspectorn ,
17 and it is part of mana g ement 's job to do that.
18 I mean I unde rs tand it was approved in th e Q
19 l highest circles of Duke Power; but was Mr. D avi s on, 20 who was cicsely inf o rm e d on the work of W e ldin g of was he r e s ponsible l
Inspectors and s up e r vi s ed the m, 22 for that evaluation as it had to do with the M elding 23 In s pe c to r s ?
24 A No, the e v alua tio n s are done by an inde-l 25 and they come 6
pendent party in Corporate P er so nn el, EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA t.
Morgon - Direct 52 1 down and look at the p ro blem and weigh the values an d 2 present that to management.
3 They do the analysis, I guess you would 4 say. They are " experts" in doing that pa rtic ula r typ e 5 of work.
6 O Do th ey know anything about %elding 7 In s pe c tion ?
8 A They w e r e tra in e d in th e skill of analyzin g 9 p o sitio n s . I don't know what their qu alific a ti on s are, 10 okay?
11 O W ha t role, if a ny, did Mr. D avis on have 12 in providing input,or expertise o r decision making 13 or anything on the re-evaluation of the pending 14 ins pecto r s ?
15 A At the time they were r e - e v a l u a t i. n g all 16 the W eldin g Inspectors. O t h e rs h a d reductions in grad es 17 also, not just W eldin g In s p e c to r s .
18 He was in the approval process for the i
l 19 po s iti o n A naly s i s , +th at is the name of the documents.
20 Q So he approved the P o sitio n Analysis in 21 part?
22 A He had a step for approval, yes.
23 Q And he did approve it as far as you know ?
24 3 yag, 25 Q You are not aware of Mr. Davison arguing EVELYN StRGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROLINA
~,. , -- ,_
Morgan - Direct 53 1 a gain s t th e r e - e v a lu a ti o n of the W elding Ins pe cto r 2 po s ition or analysis ? ,
3 A I don't und e r s tand your qu e s tio n.
4 Q You are not aware of Mr. D a vi s o n saying 5 no, this is wrong, % elding Inspectors work much 6 harder than this; they need mor e ?
7 A Larry did not work for me, and I wouldn't 8 know that.
9 Q You are not aware of him doing that?
10 A N o.
11 O There is a quote here, it says, " Super-12 vis o r s helped a few W eldin g Inspectors."
13 A Yes.
14 Q And who were the few that you had in mind ?
15 A At this time there were only two people I 16 can r e c all who would fit into this cla s sification in 17 my opinion.
18 Q Who were they ?
19 A John i3ryant and John R o c k holt.
20 Okay, and who is the supervisor who helpe d?
Q 21 A A nd Beau Ro s s.
22 Q And Mr. Bryant and Rockholt were on Ai r .
23 Ross' c rew ?
24 A T ha t 's correct.
25 What Q "Too many NCIs were being writt en. "
i EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
Mor gan - Direct 54 1 is that reference to ?
2 A Okay, I think around 2 /1, what we were 3 having is having the s ys tem flooded with que s tions 4 and not r e ally through NCIs, and we were l o o kin g for 5 ways to handle some of the questions, eithe r an R2A 6 or re turning to th e process control a.c ti vi t y plan.
7 Q O ka y, by this time you mean 2/1/82, 8 around then?
9 A N o, it would ' hav e been 2/1/81.
10 Q So you are referring to a period--
11 A E arlie r, yes. It is not relat ed to this 12 period here.
13 Q You are talkin g about a much e a r li e r period?
14 A Yeah.
15 Q W ha t period, the year before?
16 A P robably 19 8 0 a n d 19 81.
17 Q A ll right.
18 A That was a period of increased work also.
19 Q W hy was that?
20 A I am s a yin g there was more work force 21 on the job than had previously been, more c o n s t ru ction 22 e mplo y e e s .
23 O A nd du rin g that period, too many NCIs 24 were being written, ac you said, to raise que stions ?
M A V< ell, these were a lot of NCIs written, EVELYN BERGER ASSoctATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAROUNA
Mor gan - Direct 55 1 not too many, I' m saying you v rite as many as you 2 have to w rit e.
3 A lot of things that were being written 4 were minor and could have been handled in another 5 way more e c o n o mi c a lly on the company, but our pro-e cedure required us to do that so that is the way we 7 did it; and then we looked for ways to document 8 discrepancies in o the r ways such as the R2 Program 9 which d e v elo~p e d later.
10 G W hat was the response to writing too many 11 NCIs or inappropriate NCIs at th at point in the 1980- 81, 12 tim e p e riod ?
13 A You didn't have the R2A--how do you get 14 p e o ple to write N C Is --it. w a s a que s tion, a qu e s tion 15 would not go on a no nc o nf o r min g item report.
16 Our process in the past has been to allow 17 the m to come in that way.
18 Q In '80 '81, when it was the practice to us e 19 N CIs for questions, ho w did you get them to write M less for that purpose?
21 A We had m e e tin g s with Mr. Henry and M r.
22 D avis on and discussed procedures and looked for 23 other ways.
24 One way would be to use R 2 A 's . We did 25 have an R2A procedure at that tim e , we just did not EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROLINA
h1 o r g a n - Diroct 56 1 use that procedure.
2 Q Did you start usin g it then?
3 A in weldin g there were some, that was when 4 the first R 2 A 's were written, yes, I think during tha u 5 time.
6 O In welding ?
7 A Yes.
8 Q If not an R2A, what other ways of handling 9 things were approved?
10 A The ins pe c to r has cont rol over the work 11 with his signature, and if it was s o m e thin g minor tha t 12 the individual corrected, maybe he turned the paper-13 work in and s aid I'm ready, but he did not put his 14 date in.
15 If he did not date it, the inspector could 16 say rather than writing that as an NCI he could 17 r e tu rn that to him and say you ne ed to fix this so 18 Process C ont r ol can in s p e c t it.
l 19 Q And did it work, the me e tin g s and counsel ,n g l
l M instruc tions ?
l 21 A Yes, but there was some c o m munic a tion M gap on what our real purpo s e was, what we were 23 trying to do.
24 1 do n' t think the word ever got to all the l
i 25 in s p ec to r s . I d on ' t thina they said the purpose is to EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA L
Morgan - Direct 57 1 turn the paperwork back, and we are not losing any 2 q ua lit y because the minor problems can be handled 3 in a dif f e r ent manner.
4 Somehow maybe the inspectors did n ot get 5 th e word, and it broke down th rough the c o m.m u ni c a t i ans 6 in the Task Force.
7 That was one of the big thing s.
8 C Who was responsible for the c o m mu ni c a tio r s 9 to the W eldin g In s p e c to r s in this ti m e frame, Mr.
10 D a vis on, '80/'81 now?
11 ,
A Mr. Davison would have been, yes.
12 Q Now help me understand--
13 THE % IT N E SS: I need to speak to 14 Ron a minut e .
15 (w he r eupon, the % i t ta e s s and his 16 Counsel conf er red out of the hearing 17 of the Court Repo rter. )
18 i
l 19 MR. G13 S O N : Mr. G uild, Mr. Morga n l
l 20 has indicated that he t hi n k s he misspoke i
21 a date.
l 22 l
23 BY MR. GUILD:
24 Q If anything occurs that you want to change 5 your answer--
l EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROLINA
Mo r gan - Direct 58 i
MR. GIBSON: That is the purpose of 2 the conference.
THE W IT N E S S : Instead of 1980, it 3
4 was af ter 2/1/81. % hen you asked me the qu e s ti o n about Mr. D a vi s on , I realized no, 5
6 the time periods were wrong.
7 8 BY MR. GUILD:
9 Q B ef or e 2/1/81, it would have been Mr.
10 Davis on ?
11 A Right.
12 Q B ut af ter that he no longer was in that 13 po sition ?
14 A T h at's correct.
15 O But af ter that he would have been the 16 supervisor to co mmuni ca te this in s t ru c tio n back to 17 the W eldin g . In s p e c to r ?
18 A Yes.
19 Q fielp me under s tand in what way is an 20 N CI less e f fi c ie n t or more a d mini s t ra tiv ely time 21 c on s umin g than handlin g it s' o m e other way?
M A D u rin g the e a r li e r s ta g e s of the job, we 23 allo w e d people to ask qu e s tio n s on NCIs b a s ic ally 24 because we had a staff there thr.t could ans we r i
25 que s tion s that way.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
M or gan - Direct 59 1 It was obvious that was not what the pro-2 cedure required. It r equir e d us to document non-3 c onf o r ming items.
4 %e had to get out of the p r a c ti c e of asking 5 qu e s tion s, so that is what we did. As the work 6 increased, the number of po s sibilitie s for qu e s tio n s 7 can increase also.
8 Q Did you h ave more staff ea rly on to respor.d 9 to that in that way r elative--
10 A When you have more staff, it is a dif f er en t 11 type work. At the e a rli e r stages it was less proces s 12 control in the early part of the project.
13 Q A nd a s the work increased, less staff was 14 a v a ila bl e to respond to NCIs ?
I 15 A We have always had adequate staff, it was 16 just tha t--a s k me the que s tion again.
17 Q W hat change; why was it less efficient to 18 do it that way in later days as compared to e a r li e r l.
l l
19 days of the project?
20 A I don't guess it was less e f fic ie n t, it was 21 th e same.
l 22 Whe r e was it an important change then, l O 23 in your opinion if it was?
24 A I can r e c a ll that we had an NRC in s p ec tio n l
25 that came in that said we had too many N CIs on item s EVELYN BERGER AbSOCIATES. STENOTypE REPORTING SERVICE. CHARLOTTE. NORTH CAROLINA
Mor gan - Direct 60 1 which were not significant which could have been 2 handled in another manner.
3 I'm s a yin g that is only my r ec olle c tion.
4 O Your r e c olle c tio n is did you respond to 5 c riticis m by the NRC, too many NCIs being used for 6 less s ig nific an t ite ms ?
7 A They were saying we somehow had so many 8 on our system that we, in a phrase, could not see 9 the forest for the trees because we had the little 10 trees and the big trees.
11 MR. GIBSON: Okay, if this is a con-12 venient time for us to make a pit stop, 13 break.
14 MR. GUILD: Let me finish this littl e 15 bit.
16 17 BY MR. GUILD:
18 O Who coined that phrase, if you car, rememb e r, 19 who was that poet?
20 A If it was in the woods, it was probably 21 T ho re au.
22 W ould that have been the R e sident, Mr.
C l
U VanDoorn?
24 A Idon't think Mr. VanDoorn was the R e s i-25 dent at that ti me.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Morgan - Direct 61 1 C Mr. M a xw ell ?
2 A No, this was a Team Ins pe ction that came 3 in.
4 Q Mr. Bryant, he was a rather colorful 5 individual, as I r e c a ll.
6 A I don't r e c a ll who was on the team. I 7 know two people that were on the team at that t im e.
8 Q A ll right, let me fini s h this li t tl e bit and l I
9 you have gone back to writing NCIs so that the l l
10 in st ru c tion and training and guidance r e s ult ed in I 1
11 r e d u c tio n of use of NCIs for that purpose; and now l i
l l
12 you have gone back to writing NCIs. T hi s is the
)
13 little peak that you show on your graph there?
14 A No, this is a diff e rent time p e ri od; this 15 is 1982 on that one. T his is 1981 (indi c a tin g) . I 16 think what I was saying there was--
17 Q W ai t a second, this is the notes of your 18 c o n ve r s a tion with Mr. Zwi s sle r in February, '82, 19 and your graph is February, '82.
20 A Yes, but the statement that he has back 21 to me now, we have gone back to writing N CI s.
22 A gain, a hu m a n relations scale indicator, we felt 23 that at this time period that the in s p ec to r s were 24 saying they were not being supported.
25 They had lack of support, and so we said EVELYN BERGER ASSOCIATES, STENOWPE REPORTING SERyiCE, CHARLOTTE NORTM CAROLIN4
Morgan - Direct 62 1 we made the decision that we w o'u l d process any 2 que s tio n o n NCIs , so we went back to the old wa y we 3 were doing it and said if it makes you feel more 4 c. o m f o r t a b l e to do that, do it.; and we processed them 5 a ll that way durin g that time period.
6 We went back to the old way we were doing 7 it.
8 Q Okay, how was that change m ade ?
9 A G oin g back?
10 Q To the old way of doing it.
11 A We told them if you have an NCI bring it 12 to us, you know, if you have a que s tio n.
13 O Who did that, M r. D a vi s o n ?
14 A I don't r e c all, I think that was s o m e thi n g 15 that I did. I told them hey, if they didn't think I l
16 was s up po r tin g t h e m, t o tell me why I wa s n't support < -
17 ing th e m.
18 Q And to do it through an NCI?
19 A If they felt more comf o rtable. I had the 20 Manager of the Human R ela tion s s a yin g they were 21 very tense because of the pay si tu a tio n.
l 22 I said if it makes you f e el mor e co mf o rta ble, I
23 do that.
l 24 A ll right, so you gave them this guld. .e Q
25 in February, 1982, is that the time f rame for which EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAROLINA
Morgan - Diroct 63 1 you are talking about?
2 A It would be early, probably N o ve mb er o f 3 '81, s ome thin g in the end of 1981.
4 O The pay grade change was announced in 5 July of '81.
6 A Yes, it was more long that tim e.
7 O See if you can remember now July of '81, 8 was the pay grade change, the fi r s t level recourses 9 were be ginning to come in in the August, September 10 ti m e frame.
11 Would it have been a round in there?
12 A A round the time of their fir s t recourses.
13 (Whereupon, the D ep o s ition was 14 recessed at 2:59 p.m., and reconvene d 15 at 3:20 p.m.)
16 i
17 BY MR. GUILD:
18 Q Mr. M o r g a n, this is sort of an unrest i 19 among s t the Vi e l di n g In s p e c to r s as a r e sult of the 20 r ecla s sification and as a Human R ela tio n s device 21 you had, if you had problems related to the work 5 que s tion s, you suggested to use the NCI process, in 23 short?
24 A What we were saying was they f elt com-25 fortable before we changed our p r a c tic e, so I told EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
Morgan - Direct 64 1 them we would go back to the same p r a c tic e that we 2 had before until we could get our procedures in place .
3 O Because you knew they would feel com-4 fortable under that procedure?
5 A
~
As far as I knew they would feel co mf o rt-6 able, yes.
7 .Q Had they rais ed at that point, concerns to 8 you that were about t h e .w a y they were doing their 9 job, lack of support?
10 A No.
11 O What was the basis then for your judgment 12 that they needed any other device to raise qu e s tion s 7 13 A Are you r ef e r ring to the inquiry proc es s ?
14 O No, about the time when you told them to 15 use N CIs to go back to the old process of N CIs ; why 16 did you do that?
17 A Because I did not want to do anything to 18 upset people any more than what they were. S a yi n g l 19 hey, if it makes you feel c omf o rtable, it m ak e s me 20 feel c omf o r t able, so let's go back to the old way we 21 were doing it.
22 O They were unhappy about this pay, you 23 were t e lli n g me; how did the discussion of NCIs ente:r 24 into it at all?
l
' 25 A They were unhappy, I' m trying to get my i
EVELYN BERGER ASSOCIATES, STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Morgan - Direct 65 1 time frames straight here, this was af te r the pay 2 had been r e -e valua t e d, and it was when, it was af te r 3 th e NRC had come in and addressed the fact that they 4 were do c ume ntin g things that were not proper on NCI s, 5 and all I can r e c all is that they had changed, you 6 know, that they we re not g e t tin g support; and I, my-7 s elf, did not want them to feel li k e I wa s n' t givin g 8 them support, so since they had an em pty f e elin g in 9 this area, I said let's go back to where you feel 10 c o mf o rtable.
11 Q A side from the s p e cific s of the precise 12 t i ce, e , it wac efter J uly that they changed the W eldin g 13 In s Jec to r s ?
14 A Yes.
15 Q Did W elding In s p e c to r s come to you and 16 say w e. 'w a n t to go back to the old system of u s in g 17 N CIs ?
18 A yes, 19 Q Okay, give me an idea how that happened, 20 how that came to your at t e ntion.
21 A As I r e call it was a situation of lack of T- support, and they were saying we haven't had the 23 support on the pay situ ation, and you won't support 24 us on N CIs .
25 T ha t is where we had the c o mmunic ation EVELYN SERGER ASSOCIATES, STENOT*PE REPORTING SERVICE. CHARLOTTE. PeORTM CAROUNA
tL..
Morgan - Diroct 66 1 breakdown before; and they didn't understand what we 2 were trying to do with NCIs.
3 So rather than my s elf trying to bridge that 4 communication gap, we said, they suggested and I 5 agreed, that we go back to the way they were doing 6 them before for awhile u n t il we can get other 7 m e c ha ni s m s in place to handle this type of deficiency ,
8 Q So you can write new procedures?
9 A Yes.
10 Q Who brought this to your a tt e ntion ?
11 A As I r e call from memory it was Mr. V. C.
12 Godf rey, I think is his initials.
13 Q He was a W eldin g In s pec to r ?
I4 A Yes, he was.
15 Q An y others ?
16 A No, but in his c onve r s a tion he was trying I 17 to speak for a group of people s a yi n g h e y, we a ll l
I I8 feel this way.
l I8 l Q He was trying to speak for a number of 90
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other in s pec to rs ?
21 A And in mo st c on ve r s ation s th ey all i m pli e d oo
~~
this is how everyone feels, but you never r e ally know 23 l because this is only his opinion of what other p e o ple I
o4 feel.
25 Q Did you understand he was speaking for a EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERylCE. CHARLOTTE, NORTM CAROUNA
Morgan -
Diroct 67 1 numb e r of other V. e l d i n g In s pec to r s ?
2 A Yeah, and I agreed with him.
3 Q Did he make a s u g g e stion in writin g ?
4 A do.
5 Q It was all oral, a ll in c onve r s ations ?
6 A Yeah.
7 Q Did you reapond in writing ?
8 A N o, it was a very informal conve r s a tio n.
9 He said, "May I have an id ea ? "
10 Q Okay, did you discuss this wit h anyone 11 else in mana gement ?
12 A I'm sure that I discussed it with Larry.
13 Q With La rr y Da vi son ?
14 A Yes, 15 Q W ha t did he say?
16 A I can't r e ca ll exactly what he said, but 17 he concurred with th e decision that we wo ul d do that.
18 O A ll right, anybody else; did you dis cu s s it 19 with anybody beyond Mr. Da vi s on ?
20 A W ell, I discussed it with Mr. B a l d wi n and 21 M r. A llu m, but not up the o r g aniz a tion.
22 O Not up beyond M r. Davis on ?
23 A No.
24 Q Did you discuss it with Mr. Ross?
B A No.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERveCE. CMARLOTTE. NORTH CAROUNA
Mor gon - Direct 68 1 Q The other te chnician s ?
2 A I would have discussed it with the QA 3 E n gin e e r s .
4 Q And what po si tio n did they have, how did 5 they feel about it?
6 A As far an I re membe r, we were all in agre e-7 ment that it was a good human r ela tion s move to do 8 that at that time.
9 Q Okay, it was good businese, another busine as 10 decision had been made. .W a s t h e r e any increased 11 administrative burden as a result of that decision?
12 A No. To q u a lif y, there might have been for 13 a day or two, maybe, but the answer is no.
14 Q Okay, and was there an increase in the 15 number of N CI s writt e n ?
16 A I would say only t e m po r a rily. A g ain, it is 17 the same an s w e r ,- no. It might have been that way 18 for a couple of days.
19 Q All right, the longer term tr end wa s un-20 alt e r e d, the number of NCIs c o min g from W elding ?
21 A The trend, what I am s a yi n g, for a day or 22 two we might have had a f i t. r r y c omin g in, and after 23 that it would level back off, as best I can r ec all.
24 O B ack to the level it was before, as best 3 you can r e c all ?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Morgan - DAroct 69 1
A Yes.
2 O So no significant eff ect on the numb e r of 3 N CI s except for this little peak for a day or two?
4 A As best I can r e c all .
5 Q A nd how long did that p r ac tic e continue ?
6 A That p r ac tic e would have c on tinu e d until 7 the new revisions to our QA P r og ram, as it r elat e d 8 to n o n c o nf o r min g items and c o r r e c tiv e a c tio n.
9 O Which would have been when; af ter th e 10 Task Force?
11 A Yes, it was af te r the Task Force.
12 Q Okay, that helps.
13 A Okay, it is hard to remembe r when a pro-14 cedure come s to the site.
15 Q A ll right, well, at least it did not change, 16 that p ra ctic e continued through the end of the year, 17 381 into '82?
18 A I was going to say as a r e s ult of the 19 W el din g Inspector T a s,k Force, a lot of things t h at 20 were on NCIs were c o m munic a tio n s , que s tion s about 21 concerns; and we started a new process after the 22 W eldin g Inspector concerns.
M Q But the p ra c tic e of going back to the old 24 system of u sing , NCIs c on tinu ed up until tho s e new 25 procedures came into p l a c e .?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERytCE. CMARLOTTE. NORTM CAROUNA
Morgan - Direct 70 1 A Yes.
2 O A ll right, sir; I am looking at Page Three 3 of your no te s. At the top is the name " B r yant, 4 R oc kholt; Beau Ross, Su pe r vi s o r. "
5 What is the si g nifi c a nc e of the n am e s 6 indicated there?
7 A I have no idea. It might have been mention ed 8 in the s am e c ontext. we talked about just now. I note 9 that Zwis sle r wr ote them down here again, but I have 10 no idea what that connotation means.
11 Q Did you discuss this p ra c tic e that you just 12 told me about with Mr. Zwis sier ?
13 A I probably did.
14 Q O ka y; on Page Three it says, " Solution, 15 people on team were part of re s olution to p r e vio us 16 W eldin g Inspectors filed recourse on concerns.
17 Larry af ter his vi s it. "
18 l
What is the r ef e renc e fir s t there to the 19 "p eo ple on team " ?
20 A P e o pl e on team are part of the r e s olu tio n s 01 to previous concerns.
22 C W ould that be the fi r s t Task Force?
23 '81; I can't recall what it mean s.
A D ec embe r, o4 G C an you give me any more clarification
" of what that reference is ?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROUNA
Mo r gan - Direct 71 1 A No, I don't r e c a ll .
2 Q Do you r eme mbe r the Task Force that was 3 organized in early December to review the Vi e l d i n g 4 Inspector concerns, December of '81; a t h r e e- m a n 5 Task Force?
6 A Yes.
7 Q Did it have Mr. V. illi a m s on it, Royce 8 V. illia m s ?
9 A I don't think he was on the fir s t t e am.
10 Q Was he on the second team ?
11 A Yes, I do b e li e v e he was on the second.
12 Q Second T ask Force?
13 A Yeah.
14 Q The firs t Task Force, a th r e e-man Task 15 Force, who was on that; do you r e c all ?
16 A Yeah, I will stab at th o s e-- M c M e e kin, 17 H elm s , H-E-L-M-S, L. E.; W. J. --I can see the 18 guy's face, but I can't r e c all his name.
19 His name is Wholeman.
20 MR. GIESON: I:ve got those name s, 21 Earl H o ellen, H-O-E-L-L-E-N; and Mr.
22 M e hf e ekin, hi - C - M - E - E - K - I - N ; and Al 23 H-E-M-E-S-L-E-Y, H e me sley.
24 25 BY MR. G UILD :
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
Mor gan - Direct 72 1 Q All ri ght, sir; were those three g e ntle m e n 2 a part of the r e s olutio n procesa of resolving non-3 c onf o rmin g items ? -
4 A Mr. M c M e ekin is in the D e sign E n gin e e rin g 5 D ep a r tm en t. There is a po s sibility th at --l e t me 6 clarify th at--M r. M c M e e kin is in Ele c t ric al D e s ign, 7 so the answer would be no.
8 Q How- about the other two?
9 A One was f rom Steam P r o du c tio n Department 10 Nuclear P r oduc tio n D e pa rtme n t; and I think the or 11 other guy was f r om Mill House Supply C o mp any.
12 Q So you were not referring to the membe r-13 ship of the fir s t Task Force?
I4 A I can't remember what that note says, i
15 And it is your t e s timo ny that the m e mb e r s i Q 16 of the fir s t Task Force did not have anything to do U with resolving NCIs ?
I8 Not as it relates to W eldin g.
A I9 How about N CIs g e n e r ally ?
Q l
20 Mr. M c M e ekin works in the D e sign l A 21 E n gin e e rin g D epa r tm ent, and it is possible he could 22 have resolved JCIs as they related to Electrical, his 23 area of r e s pon sibility.
94 Q Did you ever hear a qu e s tio n raised as to 95
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the in cid e nt of the fir s t Task Force, because of thei: -
EVELYN BERGER ASSOCIATES. STENOTYPE RkPO9 TING SERVICE. CHARLOTTE. NORTH CAROUNA
Morgan - Direct 73 1 prior involvement in N CI r e s olution ?
2 A No, I don't think anybody knew those--the 3 o nly people I knew was Ted M c M e ekin, and the other 4 two p e o ple I had never seen before in my life.
5 Q Okay, " W eldin g Inspectors filed recourses 6 on Larry after his vi s it. " What is that ref e renc e ?
7 A I guess when Larry came down and r e que s t- .
8 ed that th ey p ro vid e all the documentation, that was 9 a m e e tin g sometime in January, '82.
10 It was af ter that m e e t in g that they had the 11 concerns. That is what I meant by that one, he aske d 12 for them and they gave them to him.
13 Q They gave them to him ?
14 A They gave them to me, and I gave them to 15 Bradley.
16 Q By filin g a recourse on Larry, they com-17 p la i ne d about Mr. D a vis on ?
18 A It was a collection of the concerns, as best 19 I can r e c all.
20 Q Okay, down at the bottom o f tha t, " Day to 91 day most difficult job is to get procedures changed, 90 takes a whil e , QC can be changed quic kly. "
93 A At that tin: e what that meant was the QA 94 procedures that we had that we w e r e too', if we wanted.
25 a r evision it was dif fic ult to do that.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Morgan - Direct 74 1
I mean it wa s n 't difficult, it took time to 2 get all the comments because we have a corporate 3 Program and we make sure that all of ou r plant, at 4 the time they received comments f rom all the diff e r e nt 5 Projects and it took time to c o lle c t and resolve all 6 tho s e comments; whereas, yo u know, I would have ha d 7 a set of procedures for Catawba and a set for McGuir e 8 and a set for Cherokee, but we had a corporate pro-9 gram so it too k time to get all the comments in and 10 resolve tho s e procedures.
11 Q What is " local QC, can be changed 12 q uic kly" ?
13 A If we had our own site procedure we would 14 not have to go to other projects to get pr:cedures.
15 We could do the m, ourselves.
16 Q Is that a C o n c t ru c tio n procedure?
j l
17 A Yes.
i 18 Q Last page, "C h arle s and A rt were changed.
19 That reference is to the transfer of Mr. Baldwin as 20 replaced by Mr. Allum ?
21 /. Yes, that is what that says. I am trying 22 to figu r e out what that m e an s.
l 23 Q And then af terwa rd s it is sort of a c ritiqu e, 24 he wanted to do thisi 25 A I don't understand, he has lost me with hir EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE, NORTM CAROUNA
Morgan - Direct 75 1 notes.
2 Q "You," was he referring to you?
3 A Yes, I recommended alon g with Larry, we 4 both worked pretty clo s e together, that I thought 5 that was one of the things that we could do to help 6 improve c om munic ation s .
7 y, e would need to switch some people 8 around to help imp rove c ommunic a tion s . That was, 9 in my o pinio n, one of the big problems.
10 That is what that mean s, that is me.
11 Q What is the s a ying that says, " C o m pl e t e, "
12 up there; that means it has been done alr ea dy ?
13 A Yes, it has been done.
14 A bout that time ?
Q 15 A It had already been completed, yes.
16 Q "Ross has a lot of k no wl e d g e , move him 17 to work on procedures; people would look upon this 18 as being right."
l I9 A I guess he asked me the qu e s tion as I can 90
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r e c all there were two blocks in the c o m munic a tion s ;
91
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people were not c o m munic a tin g so Larry and I recommended that we move people.
23 V. e had a job for it, and it' was easy to 94
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s witc h Art and C ha rle s because they were both 25 k no wl e d g e a ble in their r e s p e c tive areas, so that was EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE CHARLOTTE. NORTH CAROLINA
Mor gan . Direct 76 1 easy to do.
2 We did not have another supervis or y job 3 o P e n, as I r e c a ll; but rather than have a lot of--
4 Beau had a lot of technical knowled g e, in my o pinio n ,
5 and my recommendation was I thought he wo ul d be 6 good working with pr oc ed ur e s .
7 Q Okay, what, s pe cific ally, did you have in 8 mind?
9 A I recommended him more for Mr. Henry 10 in the technical sense in C ha rlott e.
11 Q And did you communicate that to your 12 s up e r vi sio n ?
13 A Yes, I did.
14 Q Who did you tell; who did you suggest that 15 to ?
16 A M r. D avi s on.
17 Q What did Larry D a vi s o n say to that?
18 A I guess in my communication with Lar ry 19 would be he would take my r e c o m m e n d a tio n g e n e r ally, 20 He would not say hey, you are crazy; he would say, 21 "I'll take that and e va lu a t e it."
?2 That is the way our r ela tion s hip is. I 23 don't know what his r e ac tio n was the day I told him.
24 Q What did you get for feedback, if anythin g, 25 f rom Mr. D avi s o n about that?
EVELYN SERGER ASSOCIATES 978NOTYPE REPORTING SERVICE. CMARLOTTE, NORTM CAROLINA
Morgan - Direct 77 1 A I can't r e c a ll. %e talked on a day to day 2 basis, and you lose track.
3 Q Did you say that to him in writin g ?
4 A No.
5 Q Did you do that; did you transfer Mr. Rosn ?
6 A No.
7 O Why not ?
8 A W ell, I' m t r yi n g to put the pieces togethe r, 9 for one thing, I don't think there were any additional 10 s u p e r vi s o r s available to r e plac e him, so that was 11 one c on sid e r atio n; plus it c o n tinu ally would have bee n 12 a job that may have been dif f e r ent--wha t I want to 13 s ay- it may have been a job that may not have paid 14 as much money as what he was making based on 15 p o s iti on.
16 Q Did anybody make that d e te r mina tio n, to 17 the best you r e c all ?
18 A If it had been done, Larry would have don e 19 it, yes.
20 Q Did you talk to Mr. Ross abo ut this ?
l 21 A No.
l 22 O Do you know whether he unde r s to od this i
23 r ec o m m enda tion ?
24 A I don't think he knew anything about it.
25 Q And why has the comment, "Their p e o ple i
! EvELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE CHARLOTTE. NORTM CAROLINA
Morgan - Diroct 78 I would look upo n this as being right," that proposal 2 about M r. Ross--
3 A W ell, people in his crew were s a yi n g Beau 4 was very kn owle d g e a ble of proc edur e s, and we needed 5 to harness or use that energy.
6 He does on procedures much better, and 7 they kind of thought he r e a lly should have C ha rle s '
8 job; but as far as technical knowle d g e, the best 9 place for the technical kno wle d g e would be in the QA 10 T e c hnic al Se rvic e s Group.
11 Q Why wa sn't Mr. Ross given Charles Baldwi:2's 12 po s ition ?
13 A It was a lateral transfer between Charles 14 and Art, so it was not a p o s ition open there. It was 15 just a lateral tr an sf er; it is not a po sition.
16 Q Was he considered for that po sition ?
17 A No, because it w as a lateral transfer of 18 p eo ple and not a promotion for either one of the 19 peopte, 20 Q. There was no need to consider anybody?
21 A M r. Allum was not involved in supervising l
l 22 W elding In s p e c to r s at all. The problem was perceived 23 Baldwin in terms of as a pr oble m with k r.
24 c om munic a tion.
25 Baldwin some You are going to move Mr.
EVELYN BERGER ASSOCIATES. $TENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA
. . ---~ _ _ . _ _ _ _ - __
l Morgon - Direct 79 1 place out, and Allum wa s no' in the picture. I 2 O Why not move Mr. Baldwin some pl a c e else 3 and promote Mr. Ross?
4 A I pe rc eived it was mor e than one person 5 communicating; it was not only Charle s. It included 6 also Beau c o m munic a tin g , it was two ways.
7 Q So you did not think it appropriate to 8 promote Mr. Ross for that reason?
9 A There was no po sitio n open so it wasn't a 10 p ro mo tion.
11 O If M r. A ll u m was not in the picture you 12 c ould ha ve put him in the po sitio n to clo s e th at ?
13 A If there was no one else there we would 14 have made up a list of q u a lifi e d c andidate s for the 15 p o s iti o n open, but in this case there was never a 16 po s ition open.
17 Q You never considered a promotion for Mr.
18 Ross?
19 A No.
20 Q If the r e had been a po s itio n open, would 21 Mr. Ross have been reco mmended ?
22 A He would have been considered, yes.
23 Q Would you have reco mmend ed p et i n g him in 24 the po sitio n ?
5 A I woul ' ha ve to consider all the candidates EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTH CAROUNA
Mor gan - Direc'; 80 1 since I did not get to do that analysis, I can't, in 2 my mind, put to ge the r all th e candidates.
3 He would have been one of the candidates.
4 There would be several candidates for this project 5 and other pr oj ec t s.
6 Since I didn't go through that process, I 7 can't say he would be the one.
8 O Let me put it in sim ple r terms: Beau Ros s 9 was the fi r s t to occupy the po sition. He superv.ised to as many as 26 inspectors at one point, he had the 11 experience and he had the knowle d g e.
12 A Yes, but when we consider someone for a 13 p r o mo tio n we don't look only at the project, we look 14 ' at the entire de pa rtm ent, and there are other p e o pl e 15 who had equal a mo un t s of ex p e rie nc e or ma yb e more.
16 O Who?
17 A I think he worked for Mr. Siff o r d, and l 18 there was Mr. Bulgin, the people at M c Guir e and 19 some people at Cherokee who could be considered 20 for the job, as w e ll as people in E n gin e e ring.
21 Q You are saying who had as much expe rienc e 22 as he had?
23 A Experience is only one of the f acto rs for 24 considering a p r omotio n.
25 Q You say Mr. Siff o rd had as much expe rienc e EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE CMARLOTTE. NORTM CAROUNA
Morgan - D i r c e '. 81 1 and Mr. B ul gin had a s much experience. What do y on 2 consider experience, the number of years he has 3 worked in this particular field ?
4 I am a s kin g you.
5 A That is what I c all experience, and I don't 6 have access to their file s so I can't say how long 7 each one has been e mplo ye d.
8 I would say there are people who have 9 e qu al ex pe rien c e as Mr. Ross.
10 Q And they are Mr. Siff o r d and Mr. Bulgin?
11 A Yeah, and D e a to n and Ledford and Harris; 12 th os e are the other W eldin g Inspectors.
13 Q "Three inspectors were r e a lly stirring the 14 pot. One has gone to C o ns truc tion, don't know what 15 to do with th e m. "
16 Okay, the three in s p e c to r s you talked 17 about there, is that Mr. 3ryant and Mr. R ockholt ?
18 A Yes.
19 Q Mr. G odf rey ?
(
N A Yes.
21 Q Mr. Godfrey is the one who had gone back U to C o n s tru ction ?
23 A Yes.
24 O "Have some people qu alifi e d in W eldin g 25 In s p e c tio n looking for a way to move into Technical avium u oan ...ociates. sva~orm womma suavice. cuantona. ~ oar ~ camou==
Mor ga n - Dire-* 82 1 Support."
2 Vi h a t dses that mean ?
3 A The welding, as best I can recall, the 4 W eldin g Inspectors felt th at th e y would like to be 5 censidered for positions that we have in T e ch nic al 6 Suppo rt.
7 O What general kinds of po sitions are you 8 ta lkin g about, what job title s ?
9 A QA T-c hnician s , C on s t ru ction T e chnicia n s , ,,
10 all they were saying is we want to be c on side re d for 11 tho s e jobs, and I guess they were f e eling lik e they 12 weren't considered, and they were being considered 13 for those j o b s ,when we had jobs open; you just don't 14 have jobs open everyday.
15 O Have any M eldin g In s pector s moved into 16 a T e c hnic al Support job?
17 A I would say yes.
18 Q Who ?
19 A We have Melding In s pe c to r s that worked at 20 M cGuire that have moved. When they came to C at awb a, 21 th e y moved into dif f e r ent type jobe.
22 Ray V' 1111 a m s used to be a % elding 23 Inspector.
24 Q. What is he doing now?
25 A He works in QA S c h e dulin g , and then we EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CARQUNA
Mor gen - Direct 83 1 have a guy that us ed to be a W eldin g In s pe c to r that 2 moved into A u dit, his name is Don Owens.
3 I think he used to be a L'elding Inspector.
4 O How about Tech Support?
5 A None in T e ch Suppo r t, no. We r e ally filled 6 mo s t of our Tech Support needs with the excess work 7 force available at M c G uir e .
8 We haven't had any openings, per se, 9 because those jobs were fill e d with the excess work 10 force at M c Guir e.
11 Q Okay, so where else have W eldin g Ins pe cto r s 12 had to move to if they were looking to progress?
13 A T he y co uld move to Senior W e ldin g 14 In s pe c to r, they could move to Technician. If we had 15 o pe nin g s available, they could move to S u r v eillan c e 16 or A u dit, if we had po sition s a v a il a bl e.
17 Q Have you?
18 A Have we had p o sition s available ?
19 Q In Audit ?
20 A Yes, we had a position open, but we had 21 excess work force from McGuire so all the jobs got 22 filled from those people.
23 Q Where else could a % eldin g Inspector go?
24 A I don't know. He could put in a transfer 25 request and go anywhere he wants to.
EVELYN BERGTR ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
Morgan - Direct 84 1 Q Right, with the qu ali fi c a ti o n s of a W eldin g 2 Inspector thou gh ?
3 A That is about it, T e c hnicia n or S u r v e ill a n c e.
4 Q How about back to C raf t Vi eldin g ?
5 A He could put in a transfer request and go 6 b a c i- if th e C o n s t r u c tio n Department would honor his 7 request and they had a need fo r that po sitio n.
8 Q Have they done that, has that happened?
9 A One i..d i vi d u a l , as I r e c all in Mr. Lee's 10 letter, said that anyone who want ed to go back to 11 C on s t ru c tio n, to go back to Construction; so three 12 people chose to go back to C on s truction and be 13 welde r s again.
14 C W ho was that?
15 A M r. G odf r ey, and I can't think of the guy' s 16 name. O n e 'o t h e r individual went.
17 Q Okay, anyone else on Lr. Ross' crew?
18 A I don't r e c all whose crew it was on.
19 Q II e r e is a li s t of inspectors th at file d ,
20 concerns (indic a tin g) .
21 A Okay, this f ello w didn't have any concerns ,
22 I do r e c all he d'dn't have any.
. If you had an organi- -
23 = a tion chart I could put my fin g e r on his name.
24 Three g e ntle m en here C I wish I had one.
25 are just waiting to give me an o r g a ni z a tio n chart.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERylCE. CHARLOTTE. NORTH CAROUNA
Morgan - Direct 85 1 A He would not be on a current o r ganiz ation 2 c ha r t; he would be on a real old one. I just can't 3 r e c all the guy's name.
4 Q Okay, Mr. Godf r ey is welding at C atawba ?
5 A T h at 's correct; yes, sir.
6 Q Is his work being inspected by the people 7 who used to work with him as ins pector s ?
8 A Yes, sir.
9 Q How is he working out?
10 A As far as I know I talked to hi m at the 11 K - M ar t, I guess about a c ou ple months ago. He lik e s 12 being back in welding.
13 He liv e s around Rock Hill s o mewhe r e, so 14 I see him on occasion.
15 Q And he s eem s pleased being back as a 16 welde r ?
17 A Yeah, he's happy to be back welding.
18 Q M r. Morgan, the fir s t level recourses that 19 were addressed to you, you passed them on to M r.
20 W ells ; is that correct?
21 A Those letter s were addressed to Mr. % ells ,
22 yes.
23 Q Some were addressed to you as w ell ?
24 A Some addressed to me, they all went to 25 Bill Bradley and Mr. % ells an s we r ed them.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERylCE, CHARLOTTE. NORTH CAmouMA
Diroct 86 h> organ -
1 Q C ould I see the document th at you are 2 talking about the r e ?
3 A Sure, there is a whole s le w of them there.
Some recourse letter s went to you, Mr.
4 Q 5 Morgan?
6 A That is funny, this is the other guy's name 7 right here (indic a tin g) .
8 Q Who is that?
9 A G ene Lawing, L - A V -I- N - G .
10 Q He did not file a recourse?
11 A No, he went back to C on s t ruc tion.
12 O He is a welde r ?
13 A Yeah.
14 Q At C a tawb a ?
15 A Yeah.
16 Q How is he doing?
17 A I haven't seen him since he has gone up 18 th e r e.
19 MR. GIBSON: He doesn't shop at 20 K-Mart.
21 THE WIT N E SS: I think he lives in 22 Moo r e s ville or some place like that.
23 24 BY MR. G UI L D :
25 O And so the qu e s tio n, were the recourses EVELYN BERG 7R ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROLINA
Morgan - Direct 37 that went to you, they got answered b y Mr. Wcils?
1 2
A Yes, that's correct.
3 Q A ll right, sir; how about in J anu ary of 4 1982, you received expre s sions of concern from one, 5 two, three, four, from four Melding In s p e c to r s : Mr.
McCoy, Mr. K a r rik e r, M r. Godf r ey and Mr. .H e n s o n..
6 7 A Let me see what you are talking about.
8 O Sure (in di c a tin g ) .
9 A No on M r. McCoy, yes on Mr. K a r rik e r, 10 yes on Mr. Godfrey, and yes on M r. H e n s o n..
11 O Did you respond to tho s e ?
12 A No, sir.
13 Q What did you do?
14 A Okay, this was the time where we were 15 c oll e c tin g th e concerns of the u eldin g Inspectors, 16 the technical concerns, and those were forwarded to 17 th e W eldin g Inspector Task Force.
18 T ha t is what I'm saying, o nly a few came 19 to me. I think some are addressed to Larry or M B ill Bradley.
21 Tho se are part of the concerns. Some of 22 th e m typed them out and some did th e m in lo n g ha n d.
5 Q Those four referred to the Task Force?
24 A Yes.
25 Q Who did you send them to, s p e cific ally ?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Morgan - Direct 88 1 A T ha t would be W. H. Bradley.
2 O A nd Mr. B r a dl e y , he was in charge of the 3 non-technical concerns? ,_
4' A M r. Bradley was in charge of the, okay, 5 maybe he wa s n ' t -- M r . Bradley was in charge of--I 6 take that back.
7 Q C oo rdinato r ?
8 A Correct the Record, M r. B radle y was in 9 charge of coordinating , the implementation of the Task i
10 Force r e c o m m e nd a tion s ; correct.
- j. 11 He had other r e s pon s ibilitie s ; he was th e 12 P e r s onnel a dminis t rative man at the time. I f e el i 13 sure those went to him, i
( 14 MR. GI B S O N: The timing was off, 15 he was on P e r s onn el function during that 16 tim e, I b e li e v e , and at a couple other l
17 points he took on those dutie s.
18 THE WITNESS: Yeah, he had both at 19 the time. Mr. Alexander came over and 20 th e y s witc h e d jobs.
j l 21 S SY MR. GUILD:
l 23 O Your un de r s tanding was Mr. Bradley was 24 receiving W eldin g In s p e c to r concerns?
M A Yes, I guess.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA l
Morgan - Direct 89 I
3 Q And the ones you got you sent to him ?
2 A That's correct.
3 C Okay, and you received a later technical 4
concern f rom Mr. Bryant, did you not? Let me show 5 you a handwritten do.ument (in dic a tin g) .
6 It appears to be 7/19 /82 ?
7 A Yes, sir; t h a t 's correct. Okay, I receiv-g ed that document 7/19/82.
9 Q And July 28, 1982, a memo f rom you to 10 Mr. Bryant (ind i c a tin g ) . Does that r efle c t your 11 r e s olu tio n of that concern?
12 A Yes, we asked him to handle this. If there 13 was a cause for recourse that was a qu alit y recourse, 14 that was a new procedure and--let me read the le tte r 15 fi r s t.
16 G Sure.
17 A O ka y.
18 Q Yes, go ahead.
19 A Where was I?
20 Q You said you a sked Mr. 3ryant.
21 A Yeah, t o initia te a quality recourse on it 22 so I could answer him f o r m ally, m Q That was the new procedure?
24 A Yes, quality recou rs e; and then I looked 25 into his concern and this is the response I gave him.
" " " ' " ' ' ' " " ~ ^ ~ "^
. _ . . . . . . . Lt__ _ ___________ '_'_"""_'_""_"*" " " " "" " " " ~"""
T M o r ga n - Diroct 90 1
Q Are you aware of any other uses o f tha t, 2
th e Quality R e cour s e Procedure?
3 A W ell, since I am no longer in the flo w as th e project Quality A s sur ance E n gine e r , I would not 4
5 be .o r i v i l e g e d to know that inf o r m a tio n.
6 Q Do you know of any more?
A I can't recall, there are very f e w. I am 7
8 saying this maybe the only one.
9 Q Maybe the only one?
10 A Yeah, as far as--
11 O It is the only one you know about?
12 A I think it is the only one I have ever had 13 to answer.
14 O And you don't know of any others you have 15 answered? Someone else has taken care of othe r s ?
l 16 A T hi s is th e only one I' v e ever had to 17 answer.
18 O A ll right, sir; you have been responsible 19 for some im pl e m e n t a tio n of the E eldin g Ins pecto r 20 Task Force re comme ndation s ?
21 A T ha t's correct.
22 O What areas have you been responsible for 23 imple me ntatio n ?
24 A One thing that came out was the stickman 25 process, which was the way we handled ve rbal a nd EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERytCE. CHARLOTTE. NORTM CAROLINA
Morgan - Direct 91 1 written inquirie a , verbal inquiries that maybe an 2 inspector or technician would ask us a que s tion, and 3 it is handled through the supervisors.
4 The other way is we have a program set 5 up to make sure th'at we have qu a rte rly me eting s wit h 6 the C on s tr uc tion Department to help improve our 7 r ela tion ship with them.
8 Q Qua rt e rly m ee ting s ?
9 A Quarterly m e e tin g s with the Co ns t ruc tio n 10 Department in various di s ciplin e s , and once a quarter 11 we would talk about C i vil related it em s and in another 12 we would talk about Me chanic al and E le c t ric al, we 13 would talk about Melding with the m.
14 We would sit down and lay our cards on th e 15 table and say here is where our problems are, and 16 they would s ay her e is where our problems are.
17 And we would talk about th at and work to 18 resolve the problems we might have.
19 That was a Task Force r e c o m m end a tion O
1 20 you were re s pon sible f o r ?
l 21 A Yes, another was Procedure Comments.
22 We were charged with making sure that we c olle c t 23 all the co mment s on procedures, make sure they go y
down to the First Line S up e r vi s o r to make sure that 95
~
he gets the documents to c o m rn e n t on a procedure.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTH CAROUNA
Morgan - Direct 92 1 %e are doing that and t h r. t is going real 2 w ell.
3 Q W ha t is the stick man?
4 A Stick man is a big head and a body and two 5 arms going out. It gets the name s tick man because 6 it is a circle that gets qu e s tio n s and answers, and 7 it looks like a little man.
8 Do you want me to draw you a picture ?
9 Q Sure.
10 A I think that wo ul d be it (d e mon s tr a tin g) .
11 It may be in that document you have there.
12 O Nope, afraid not; do some work there, Mr.
13 M o r gan.
14 A You put it in a c o mi c al sense, we have 15 the qu e s tion arises and this is the flow ( de mons tr a tir,g).
16 Q T ell me what you are po in tin g a t.'
17 A Okay, I would have to have the actual 18 d o c um en t.
l9 Q The inspector has the qu e s tion. You are 20 pointing to the head?
o1 A Yes, that is the qu e s tio n , and your flow l
l no chart c om e s down and you ask this person or this l
43 person (in di c a tin g ) .
94 Q Down to th e arms ?
25 A Y e s , and depending an the anewer you go dow n EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE. CHARLOTTE. NORTM CAROUNA
Morgan - Direct 93 i
1 to the next part of the process.
2 Q Down to the legs there?
3 A Yes, 'you go down the leg.
4 Q And whose term is th at ?
5 a That is not Mr. Thoreau, Mr. D a vis o n 6 made this o b s e r va tio n. We will give him full credit.
7 Q He do e s n' t get the free c r e dit though, the 8 s tic k m an --
9 A Stick man process.
10 Q We wo n ' t mark that one as the next. e xhi bi t .
11 What else were you r e s pon sible for in the impl e -
12 m e n t a tio n that comes to mind?
13 A As I r e c all there were two more things, 14 one was the in s p e c to r s in M24, I saw that document 15 laying there, you are givin g me a lead.
16 I do n' t r e c a ll, but it was the M24 and i 17 another one was tell engineers not to make decisions 18 that are outside their realm of r e s po n s ibilit y.
19 Q You mean QA7
.'O A QA, y e a h; our QA E n gin e e r s .
91 Q Okay, what is M24?
22 A M24 is our procedure for internal cleanli-23 ness in piping s ys tems. It is a procedure that 04 s p e cifie s the acceptance c rite ria .
25 O W ou ld that have to do with rust?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORT!NG SERVICE. CHARLOTTE, NORTH CAROLINA
Morgan - Direct 94 1 A Yes. If it is a carbon s te el pipe it c ould 2 have rust in i t, possibly.
3 Q Stainless pipe ?
4 -A I would have to have the procedure to go 5 through all the c rite ria. B a s ic a lly, it gives the 6 inspector the c rite ria for determining whe th e r a 7 s y s tem is clean or not at the time it fits, and they 8 hook up in the pipe to make sure it is not violating 3
9 M24.
10 Q And you have that training to geth e r --
11 A As I re c all, I assigned that trainin g to 12 someone else, and it was done.
13 Q M r. Ross did the training?
14 A Yes.
15 O He did an hour and a -h alf worth of t r ainin g ?
16 A Yes, this is a documentation of the 17 tr ai nin g. It goes on, M24 P ro c e du re, and a p p a r e n tl y 18 he pic ked up some other concerns here because the s e 19 are the references to the concerns.
20 QA3, no, V 13, that is this one right here 21 (indicating).
M Q Okay.
l 23 A l He got his p a r tic ula r, the people that were l 24 -
1 involved in that WI3 concern, and he went over the 25 procedure with them again.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROLtNA u.
Morgan - Direct 95 1 Q So the list of attendees there are the 2 peoP le who had the concerns?
3 A W ell, you have to look at WI3. A ppa r ently 4 WI3 probably references some NCIs or something.
5 I am not f amilia r with W I 3, and those are the people 6 who received the t rainin g.
7 O Why them ?
8 A Beats me, I would have to look; you would 9 have to look in WI3 as it relates.
10 Q Right, but when you had a r e s olu tion that 11 c all e d for training you did not t r .'i n everyone, you 12 just t r ain e d s o m e.
13 What I want to understand is who got 14 trained and why?
15 A Okay, these people got trained and maybe 16 that was all the people that were on his crew.
17 Q Was that all the p eo pl e who got trained as 18 a r e s olution of that re co mmend ation ?
19 A I don't r e c all.
20 Q Well, this is all I got, this one sheet of 21 paper; and I guess my que s tion is you are the one 22 who is in charge of i m pl e m e n t a ti o n.
23 Did that r efle c t, it says, "T rain in s p ec to r s 24 in purpose of M 2 4. " Is that your handwriting ?
M A No.
EVELYN gERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA
M or gan - Direct 96 1 Q It says, " Inspectors have been trained."
2 Who s e handwriting is th at ?
3 A It is Mr. A llu m ' s .
4 Q Okay.
5 A I don't think I can answer your question; 6 I would have to research W 13, and I would--
7 Q I guesa without you ha vin g to do that, wh er.
8 it says, " T r ain in s p e c to r s , " why don't you train all 9 insp ec to r s ?
10 Are you training the in s pec to r s who have 11 the concern or who did not do it right as a r e s ult 12 of the Task Force report or what?
13 A .I would say that would be the logical thin g, 14 to do those who had some dif fic ulty or the ones that 15 needed a refresher.
16 Q Fine, so I'm an inspector and I express l
17 s om e concern, and af te r it goes through all of this l
18 in s p e c tion d et e c tio n, r efle c tio n p r o c e s s in g, the 19 r ec ommend atio n of the Task force is train inspector.s, i
20 and what that role boils down to is train me.
21 A W ell, I think it is train those as they S relate to the concern. You get all the fact together 23 and say okay, here is the problem we had with WI3; 24 what do we need to d o,, w i t h WI3 ?
i j 25 And a p p a r en tly that is a ll' t h e documents l
EVELYN BERGER ASSOCIATES, STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROUNA
.v --
M o r g an - Direct 97 1
on WI3 and that is who got trained.
2 Q The p e o pl e who had concerns?
3 A I don't know. Some of these p eo ple did n o' 4 have concerns, but a p p a r e n tly they must have been 5 r elated to the situation.
6 Q Do we have a copy of the V olum e T wo ther o?
7 MR. GIbSON: Do you want to have 8 him look at % 13 ?
9 MR. GUILD: Sure, see if he can 10 answer that, please.
11 MR. G 13 S O N : All right, Mr. Morgan g 12 has the mystery been solved?
13 THE WIT NE SS : Yeah, I don't know.
14 Mr. A llu m worked for me. He said the 15 inspectors had been trained.
16 It is addressed to me and when we 17 looked at that and one of the issues was 18 an int e r p r e tation of what is heavy rust.
19 20 SY MR. G UIL D :
21 Q Heavy rust, I remember the heavy rust 22 q ue s tion.
23 A That is an area that is not black and 24 white, it ia p r e tty gray.
25 O R ed.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROLINA
Morgan - Direct 98 1 A It was red or brown, so the supervisor 2 will give the guidance as to what is acceptable or 3 not acceptable. .
4 C The heavy rust qu e s tion ?
5 A Y eah.
6 C The p o in t is why there are seven?
7 A There are eight.
8 Q W hy those eight on the heavy rust training ?
9 A I don't know.
10 MR. GIBSON: That is the mystery 11 we have not been able to solve by looking 12 at the documents during that pause.
13 14 SY M R. GUILD:
15 Q How many % elding In s p e c to r s are there 16 out there, a pp r oxima t e ly 5 0 ?'
17 A No, I don' t think there is 50, maybe 35 l
18 O What about the other 28 % eldin g Ins pe cto r s ;
19 how do we know wh ethe r they have ha d approp riate i
20 training on heavy rust 7 21 A I guess the only thing, Mr. A llu m signed 22 this, ac tio n was c o m pl e t e d and they had been trained .
23 C B ut you only had eight of the m t r ain e d; 24 arc-they the only ones that had problems id e n tif yin g 25 heavy rust?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING $ERVICE. CHARLOTTE. NORTH CAROLINA l
M or gan - Direc; 99 1 A I could speculate and say maybe; I just 2 don't know.
3 C Everyone else could id entify he avy rust 4 when they saw it, so they didn't need more training 5 on the subject?
6 A I do n' t know.
7 Q If you c all for t r a inin g you only trained 8 the people identified as having a p r o ble m in that t 9 area? '
10 A You would take the concern and go back to 11 the s p e c ific r e c om m end a tio n and see e x a c tly what was 12 required, yeah.
13 O Who required the training in that in s t an c e ?
14 A Yes.
15 Q And in this instance it was a p p a r e n tly 16 those eight that required the training if you did what 17 you are supposed to do in terms of im ple m e ntin g the 18 r e c om m end a tio n ?
19 A I don't know.
20 Q It was ass i g n e d to you, Mr. Morgan. How 21 come you di d n ' t fi gu r e this o u t '?
22 A T hi s one c am e back to me and said th at U this one was done.
24 G You say Mr. Allum did it?
25 A I don' t think Mr. A ll u m wrote his name on EVELYPt BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Morgen - Dirott 100 1 this piece of paper. He said he did it.
2 Q T ha t is what I mean, he si gn ed a form 3 saying he did it; and as far as you know that ended 4 th e matter ?
5 A I' m saying as far as I was concerned I 6 gave him that a s signment, and he returned that 7 a s s ignm ent as complete.
8 Q And it did n ' t raise any que s tion in your 9 mind that you dealt with anyway, or if you did, tell 10 me about it; b u t. that s atis fie d you?
11 A Yes, now these documents went on into 12 Mr. B r a dl e y, and I am sure they hav3 done them 13 again.
l 14 Q You are the one under oath and sitting i
15 here now. Mr. Bradley is done gone; so as far as l
l 16 you know it was taken care of?
17 A It says, " Inspectors have been trained."
l 18 It has been documented on this document that it was 19 done.
r 20 Q That leaves me with a nagging worry, Mr.
21 .M o r g an, if you have a problem that is identifying 22 heavy rust, maybe you haven't implemented that 23 r e c o m m enda tio n ef f e ctively.
- 24 Do you have any other inf o rmation that i
25 would s atisf y my doubt the re ?
EVELYN SERGER ASSOCIATES. STENCTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
,- -. -, - . - - , - , - . - . - _ ~ . - - . . . , .
t.L o r g a n - Direct 101 1 A No.
2 Q Do you remember inspectors expressing 3 a concern that they needed some kind of a standard 4 of what heavy ru s t was?
5 They wanted Mr. D a vis on or Mr. d aldwin 6 to give them an example.
7 A W o r km a n s hip s am ple.
8 O Yeah, a s a m pl e of what is heavy rust; do 9 you remember that?
10 A No, I know wh at a workmanship s ample is.
11 O You did not know, you weren't aware of 12 prior requests f rom .. eldin g In s p e c to r s to have Mr.
13 D avis on or Mr. B a ld wi n give them a workmanship 14 s a m pl e of what heavy rust was like ?
15 A N o, sir.
16 Q Do you know whether or not Mr. Ross 17 showed those nine in s p e c to r s a s am ple of heavy rust 18 as part of his training ?
19 A I don't know.
20 Q Do you know what the training consisted 21 of7 W A No, sir.
23 Q It took an hour and a-half according to 24 this f orm; right?
25 A Yea, w e ll, he covers more than one concer n.
l EVELYN SERGER ASSOCIATES. STENOTTPE REPORTING SERylCE. CHARLOTTE NORTM CAROLINA
,- r ._. _ _ __ _
Morgan - Diroet 102
=
1 Q More than just heavy rust?
i 2 A Yes.
3 Q You d on ' t know how much of that hour and 4 a-half was heavy rust?
5 A No, sir. _
6 Q Where did they do the t r a inin g ?
7 A I have no idea.
8 Q A ll right, sir; I am not trying to trick 9 you now. It says, " C a tawb a M e e tin g Buildin g. "
10 A Okay, at the C atawba M e etin g B uildin g ,
11 that is where it was.
12 O Where is that?
13 A T h r, t i s the name of the buil din g, it is 14 li k e an auditorium. That is th e name of the f acility, 15 they call it the Me etin g Guildin g.
16 That was ab ou t--it probably holds about 17 two or three hundred people.
18 Q Do you think they might have invit e d two 19 or thr e e hundred and only the eight showed up ?
20 A N o, we have a p ro bl e m g etting a conferenc e I room at the project, and you have to get the one 22 a v a il a bl e ; and you might have three people in a room 23 that holds three hundred.
44 I' v e had t h i t: problem before of c allin g a Q
25 m e e tin g and hoping three hundred would show up and EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE, CNARLOTTE. NORTM CAROLINA
Diroct 103 Mor gan .
1 fi ndin g eight.
2 Did Mr. Rosa have this problem, w an tin g 3 a training s es sion for two or three hundred inspector a 4 and o nly eight showed up?
5 A I have no idea.
6 Q Oh, here is the one you did (indic atin g) .
7 T hi s is the one where you are going to instruct QA 8 P er sonnel not to make engine erin g de cisio ns.
You did this in s t ru c tio n, didn't you?
9 10 That is your signature, right?
11 A Yes, I did this one.
12 Q W hi c h r e c ommend atio n is th at ?
13 A WIll.
And you gave that in s t ru c tion, right?
14 Q 15 A T ha t's correct.
16 Q Where did you give the in s t ru c tio n ?
17 A Where did I give it?
18 Q Yeah.
19 A At C a t a wb a. T hi s would have been in my 20 of fic e or it could have been in a conference room.
21 Q How long did it take to give that 22 in st ru c tion ?
23 A O ne -qua rt e r hour.
24 O That is 15 minute s ?
25 A T h a t 's correct.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE CHARLOTTE. NORTM CARouMA
Morgon - Diroct 104 1 Q It did not take long to get that message 2 across? !
3 A A pp a r en tly not.
4 Q Is that ef f ec tively training anybody?
5 A Yes.
6 Q They got the m e s s a g e, all right. What di<l 7 you do?
8 A I instructed QA Personnel not to make 9 engineering d e ci sio ns a s it related to W eldin g to In s p e c tion and s pe cific ally in r ela tio n to Task Force 11 references.
12 They should be instructed they are not 13 allo w e d to make engineering decisions, Numbe r 14 1114486 4 15 Q That is an NCI number?
16 A Yeah.
17 O T hi s is one attached (indic ating) ?
18 A Okay.
19 Q So what did you do in that training there?
20 A I went over this particular N CI with them 21 and told them in this case the W eldin g In s p e c to r Tash 22 Force had d ete r mine d the s e are the kinds of decision s 23 that s ho ul d be made by the Design E n gin e e rin g Depar n-24 ment; and in the future we would not make these type s M of decisions.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Morgan - Diroct 105 g Q What did they say?
2 A I can't r e c a ll.
3 O Did th ey ask any que s tion s ?
4 A I feel sure they did, but I don't r e c all any .
5 O Not too many if it took 15 minu te s.
6 A W ell, it didn't t a ir e too long to read this 7 p a r tic ula r N CI and t ell them the background. One 8 s p e cific case should not take very long.
9 O Did you use any instructional ma te rial be-to sides that NCI?
11 A In s t ru c tio nal ma t e rial; no, sir.
12 Q Cha rt s, graphs, nothing like that?
13 A No, sir; I used this document that is attached.
14 Q How do you know that they were eff e c tively 15 in s t ru ct ed ?
16 A How do I know they were e ff e c tively in-17 structed--because they were li s t e nin g to me and they 18 do what I tell them to do.
19 Q Do you give them a quiz or s o me thin g 20 afterwards ?
21 A No, sir.
22 O You just told them don't do this any more, 23 and the m e e tin g is a dj ou rn ed , in short?
24 MR. GIBSON: M r. Culld, he just 25 described a moment ago exactly what he did EvgLYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAmouMA
, ,-- . - - - - = -- - -- - , - - - - - -
Morgan - Diroct 106 1 in the m e e tin g, end you have asked him a 2 third time.
3 MR. GUILD: Couns el, I would like 4 him to tell me, if this is a serious s u bj e c t 5 and if this is r efle e tiv e of the serious 6 effort to address concerns, and this is ono 7 he knows about because he did it; I want 8 him to tell me in glaring d e t ail e x a c tly 9 what you did.
10 MR. GIBSON: Would you tell him 11 a gain wha t you did in glaring detail, what 12 you did to instruct that s p e cifi c personnel?
13 14 GUILD:
BY MR.
15 Q I want you to tell me what you did in 15 16 minut e s , and I want you to tell me why that is an 17 e ff e ctive in s truc tion that responds to that concern.
18 A I told them that they would not make 1
19 engineering decisions s imila r to the one made on NCI 20
'L114 4 8 6.
l l
21 I went over the NCI, I read them the NCI; l
22 and I discussed and told them they could not make 23 tho s e types of d ecision s.
24 Q P e r io d, end of dis cu s sion ?
i 25 A I am sure there was a feedback, we did not EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROLINA
Morgan - Direct 107
- 1. feel like it was an engineering discussion or some-2 thing I had to tell them we could no lo n g e r make the se 3 types of decisions.
4 T hi s is the only case that I am aware of
(
5 where we have ever made a decision like this.
6 Q What is the nature of the decision that you i
7 made that the Task Force had d e te rmin ed was an im-8 proper engineering decision?
9 A I don't understand your qu e s tio n.
10 Q What was the natur e of the impro pe r 11 e n gin e e r in g de cision ?
12 A I would have to study thie document to 13 r ef r e s h mys elf.
14 Q Okay, please do.
15 A The situation dealt with thinness of materi al 16 versus thickness of weld s, and we interpreted these 17 standards, the ASTM Standard, to mean that we had 18 acceptable tole r a nc e s to accept the si tu ation at hand, 19 which was a quarter-inch plate; it is kind of like wh en 20 you go to buy a two by four you don't get a two by 21 four; your get one and a-half by three and a-half, U or whatever.
23 It is the same way with a quarte r-inch 24 plate, the manuf acturer of a pa r tic ula r product, they 25 have r o lli n g tole r anc e s in whi c h the plate c ould be EVELYN SERGER ASSOCIATES. STENOTTPE REPORTING SERVICE. CHARLOTTE. NORTH CAROLINA
Morgan - Direct 108 1
a little over or below; and in this case the E n gin e e r-2 ing Department s pe cifie d a w eld to be one-quarter of 3 an inch, and the plate in this pa rticula r case was no 4 .250, it was below the tolerance but within acceptablo 5 standards, and we said that is okay, we don't make 6 th a t type of decision.
7 We are en gin e e r s and we felt we could mak e 8 that p articula r decision, and our management and the 9 Task Force said d o n ' t.
10 We do not think you should be m a kin g those 11 types of decisions. You should go back to the 12 r e s po n s ible department, so it was evaluated by the 13 T ask Force.
14 That is ba sic ally what it was, the fact 15 that there were tole ranc e s and we interpreted the 16 case saying that is okay.
17 Q A nd that is the only instance in which that 18 happened?
19 A As far as I know.
20 Q And that was the s p e cific in s t ruc tion, don t 21 do that again?
22 A Yes, you go through this and read th e 23 s itu a tio n s , most of the people were already f amilia r 24 with this s itua tion because we, during the Welding l
25 In s p e c to r Task Force they talked with the people that EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CNARLOTTE NORTM CARQUNA L.
Mor gan - Direct 109 l
d 1 made the decision, why do you do this; so they had 2 gathered background information on it.
3 It was an easy task to say we could no-4 longer make these ty pe s of decisions, we need to go 5 back to the people m a kin g those decisions to make 6 sure they are correct.
7 F o r tu na t el y, they found our decisions were 8 correct. We are engineers and they are en gine er s, 9 and it is just a matter of where you sit.
10 Q But it is p ro b a bl y a decision f or' D e sign 11 E n gin e e rin g, not QA?
12 A T ha t 's correct, not for us.
13 O End of in s t r uc tion, that is what you told 14 them ?
15 A Yes.
16 O How do you know that was e f'e c tiv e imple-17 menting in c or r e ctin g .the d e ficiencie s that the Task t
! 18 Force identified ?
l 19 A Because I have c o nfid e n c e in the people 20 that work for me that they got the in s t ru c tio n and 21 they understood not to do that any mor e.
M Q And they haven't ?
23 A And they haven't.
24 Q Are you sure?
25 A To the best of my kn owl e d g e .
EVELYN BERGER ASSOCIATES. STCNOTYPE REPORTING SERvlCE. CHARLOTTE, NORTM CAROLINA
Morgan - Di: oct 110 1 O Was this a d ecision as to the a c c e p t a bilit y 2 of the dim e n sio n s of a weld or the dimensions of a 3 P iece of plate ?
4 A A pp a r en tly the base ma te rial had to be 5 ultr a s onic ally tested, and it was detected at that 6 P a r ticula r point that it was below the .250, so the 7 weld was shown as being undersized.
8 Q It was an in s p a c tio n of a weld, not of a 9 piece of base nia t e ri al ?
10 A The situation would have r e s ult e d at the 11 in s p e c tio n of a weld.
12 O And it was the weld that was rej ected ?
13 A I don't think that they wro te it up as a 14 s p e cific weld, I think they wrote up an addition that 15 said we have some ma t e rial that could be below the 16 tolerance quarter-inch plate, and we cannot make 17 qua rte r-inch weld s on it because we inspect to make 18 sure there is a c t u all y .250 there.
19 Q Okay, are there any other Task Force 20 r e c om m en datio n s that you are responsible for the 21 im ple me n t a tion of?
M A Not as far as I know, no.
23 O Did you have any r e s ponsibility f o r imple-24 menting the re com mendation s- o f the n on-t e c hnic al Tas k 25 Force?
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAROUNA
Direct til i Mor gan -
l.
l I
i 2
A I am not f amilia r with the non-technical ll
-i 3 p o r tio n s . If you are t alkin g about Haras sment 4
P ro c e dur e and Quality Re co ur s e Procedures on this, l l
t ,
5- yeah.
i e Q I am asking you whether you k no w, 7
whe th e r you were responsible for imple me ntin g any l l
Task Force recommendations of the Non- t e chnic al I a
', Task Force?
. io A No, only as it would relate to a new pro-I cedure on haras sment I, my s elf, would have to !
l 12 implement with my p eo ple.
13 Q In that instance were you responsible 14 for Har as sment Procedures?
15 A Yeah, probably.
16 Q You have the right to say no. .
17 A I guess I don' t r e ally unde r s ta nd your !.
l 1a que ation. !
l l 19 O You are r e s pon sible for implementing !
20 H ar as sment Procedures in your area of responsi-21 bility ?
I l 22 A That's correct.
23 O As it relates to W eldin g In s p ec tion ?
l 24 A I have no W eldin g Inspectors that report !
I I
! 25' to me now, and af te r the non-t echnical conc e rns came i LYNN B. GILLI A M STENOGR APH REPORTER L
i Morgan - Direct 112 l
out I was no longer in that particular job.
3 I didn't h av e any W eldin g Inspectors re-4 porting to me.
- s. O Okay, how do you unde r s tand the term l
6 "ha ra s s ment" ? j 7 A Haras sment is a situation where I looked a up the definition of hara s s ment it says repeated 9 que s tionin g is har a s s m ent.
to It is what you term ha ra s s ment in your it own mind. Each individual would consider harass-12 ment diff e rent.
13 You have to evaluate all the facts and I
14 the situation at hand a nd talk to each involved and !
is d et e rmine whe the r someone was being harassed.
i 16 Q Is there a standard that relates to 17 haras sment that you unde r s tand is represented by t
ta- th e c o m p a ny 's p o li c y and practice s ? [
b l l 19 N A No, anyone who feels they have been y l !
20 harassed tu any way can implement that procedure, h[i f
21 and it will be evaluated by the P e r s onn el De part-l i
22 m e n t.
23 O You understand th at harassment is pro-
! i 24 j hibited; .o you?
l 25 l A yes, t I :
i l LYNN B. GILLI A M i STENOGRAPH REPORTER
i Morgan - Direct 113 i,
O All ri ght, sir; what is prohibited ? j l
A What is harassment? Hara s s ment is the l 3 l 4
determination if you think you are being harassed l l
3 you should file a charge with you r management to 6
tell them that you f eel you are being harassed.
It can be verbal abuse, physic al abus e; lI 7
8 it could be a nu mb e r of things. !
9 Q And your te s timony is it is the s ubj e c ti e io state of mind of an individual? {
11 A Yes, f
12 O What is prohibited, if anything? j 13 A N o t hin g is p ro hibit ed if you think you a
14 are being ha ra s s ed or bothered, you go and file i
) )
i is your charge and let somebody look at it. j i
16 O Are you aware of anybody filin g a charge 17 of haras sment ?
ia- A Yes, j t
\\
10 Q How many hara s s m ent charges are you 20 L aware of?
li 2i A Off the top of my head I know of two. j 22 O W ha t are tho s e ? J 23 One is not related to the W eldin g h A q 24 l
. In s p e c tion. Shall 1 go into that? c h
25'! d MR. GIBSON: T e ll me about it fir s t.
- l LYNN B. GILLI A M !
STENOGR APH REPORTER
i 1 Morgan - Direct 114 2 ( W h e r eu pon, the w itne s s and hisl l
. 3 Counsel conferred off the R ec o r d. ) l :
4 I
I 5 MR. GIBSON: If he wants to go into 6 them. I suggest you not give the name of t1 7
the person in the no n -w e ldin g h a r a s s m e n t.
a incident.
If he wanta the facts, give them to 30 him.
11 i i
)
12 BY MR. GUILD: l 13 l O Do you know the facts of the non-welding' 14 incident? I want to know about any ha ra s s ment t!
15 l
charges he knows of.
16 A Okay, the situation was a f e male employ $e o l,
37 who was walking through a work area, and one of j
.i is the inspectors threw a little baoycake at her
" and hit her on the buttocks, and she turned around 2
and asked him why he did it, and he said, " Honey, 21 I couldn't mis a that big t a il. "
22 .
So she felt she was harassed. l J
23 Q Did she file a charge? 1 i
24- A !
She filed a charge. ,
i 25-O What happened to that charge? ;
LYNN B. GILLI A M sTENoGR APH REPORTER
i Morgan - Direct 115 l
l 2 A It was in v e s ti ga ted.
- s O What did the y dete rmine ? ,
l 4 A I think they gave the individual a viola- t 5 ti o n of the Rule s of Co nduc t.
6 Q Did they d e t e r min e th at ha ra s s ment had
,i 7 occurred?
l
]
8 A l'm not sure.
9 Q You just don't know ?
'O A I don't know, I'm s a yin g she felt she was being harassed. It was in v e s tig a t e d. ,
i 12 Q What I want to know is did the company l d ete rmine that was ha r as s m ent, if you know ?
14 A I ac=*t know. l 15 Q Who would know, who in ve s ti ga t e d that? !
16 A 1 don't know.
l l
37 O Did you?
ll'
'8 l s A No.
O What was your role in it, if anything ?
20 l
A The e mplo y e e came to me and felt she l 21 l had been harassed, and I told her if she felt she ;
i 22 had been harassed, she ought to file a charge. j 23 Q And she did? ;
24 !
A Yeah, '
25' O With you?
LYNN B. GILLI AM l STENOGR APH REPORTER L
i 1 Mor gon - Direct 116 i
A Probably with P e r s onnel.
Q The E m plo y e e R elatio n s people?
3 4
A Yeah.
O And you don't know what the r e s olu tion 5
i 6
is?
7 A No, I'm s pe culating whethe r the guy got s a violation.
I 9 Q You don't know whether the guy got a i i
io har a s sment charge in that case? q l
A No. f 11 i 12 Q W ha t was the othe r ?
I I
13 A An inspector wrote an NCI as it relates 14 to a weld. I think this was part of the W e ldin g ,
,i i
l; 15 ! Inspector Task Force.
lll 16 And the inspector filed a har a s s ment [
t $
1 17 charge.
l!
e 18 Q A nd what was that, who was that W eldin g;qI i
l' Inspector? ll N
20 A Larry Jackson. 9 1
21 O Was haras s ment found in that case?
22 A I do n' t think so, I think it was just a l I
23 1 c on f ro nt atio n.
24f Q. Those are the only two incidents of i:
y l!
I o 25~ 4 j haras sment charges that you are aware of? g l
LYNN B. GILLI A M STENOGR APH REPORTER ,
I i Mo r gan - Direct, Cross 117
- f i
II I
A (The %itness nodded his head a f fi r m a tiv e 2, 2
ly.)
Q Yes?
4 A I can't r e c all any others.
5 Q Has the company ever found ha ra s s ment ?
A I don't know, that is outside my area of 7
r e s po n s ibili ty.
9 Q Do you know of the company ever having
,o determined that a case o f. h a r a s s m e n t exi s t ed ?
I o
y, A 1 do n' t know, I can't answer that que s tio n.
.i 1
12 That is inve s tig a t e d by P e r s o nn el; I am not privi- l 1
is leged to review that inf o rm atio n, so I can't answer' i
'l 14 th a t qu e s tio n. !
1 i;
15 Q Answer to the best of your ability; do f c:
I 16 you know of any char ge of ha ra s s ment that was ,
i 17 found to be valid by the company? [
[!
18 A No.
19 MB. GUILD: A ll right, thank you 20 very much. That is all I have. g li 21 MR. GIBSON: I have two qu e s tio n s y li 11 22 Mr. Morgan. !
i
(
23 24 CR OSS E X A MIN A TION l 25 GIBSON:
BY MR.
LYNN B. GlLLI A M STENOGR APH REPORTER
i Morgen - Cross 118 l
2 O With re8pect to WI3, the document Mr.
3 G uild showed you re g arding M r. Allum indic atin g ,
i 4 that t r a inin g had been conducted for certain W eld-3 ing Inspectors, do you know how a d e t e rmin a tio n 6 was made as to which inspectors w ould take that l 7 training or ho w a d e t e rmiaa tion was made as to !
a which in s p e c to r s signed the sheet that Mr. G u il d !
9 showed 'u?
io A N o, I wouldn't know that, i
,l l'
11 Q Okay, finally are you aware of anything d i:
12 that would cause you to qu e s tio n whethe r the ll
'1 13 Catawba Nucle a r Statio n was safely built ? l l
14 A I am sorry, s o m e thi n g f ell'o ve r there. t I
i 15 Q Are you aware of anythin g that would i 16 cause you to que s tion whether the Catawba Nuclear 4
17 l-Station is safely b uilt ? l i
la A No. j j
19 ! MR. GIBSON: Anything further, g i s fi l
20 Ni r . Guild ? -
4 21 MR. GUILD: No. l 1
12 MR. GIBSON: That is all I have. j i
23 FURTHER THE DEPONENT SAITH NOT. !
1 24 (Whereupon, the D e po sition wa s 25' adjourned at 4:55 p.m.) i n
LYNN B. GILLI A M STENOGRAPH REPORTER o
i 119 i
2 I, R o be rt A. M o r gan, he reby ce rtif y l 3 that I have read and understand the foregoing tran-
~
l 4 script a nd b eliev e it to be a tr ue, accurate and 5 c om pl e t e transcript of my te s timony.
6 I
7 ;
1 a
l Robert A. Mo rgan 9
l 10 l
11 This D e po s ition was signed in my 12 presence by Robert A. '.. o r g a n on the day of ,
13 July, 1983.
l '
14 ! l I
l 15 l l l
16 l
Notary Public 1l '
17
- 18. j i
l 19 l C E R T I F I C A T E i,
(
l 20 STATE OF NORTH C A R O LIN A l 21' COUNTY OF MECKLENBURG 22 I, Lynn B. G illi a m , do hereby cer-23 tify that the proceedings were by me reduced to ;
I e4 m a c hi n e shorthand in the presence of the Witne s s, l l
25 af terwards transcribed upon a typewriter unde r my LYNN B. GILLI A M STENOGR APH REPORTER j
J , l
, l 1 120 h
I i
2 dir e c tio n; and that the foregoing is a true and 3 correct transcript of the proceedings. n l 4, l 4 I further c e r tif y that these proceedi h
5 ings were taken at the tim e and pla ce in the fore- !!
!i 6
going c a ptio n. s p e cifie d. j i ! i 7 I
! I further c e r tif y that I am not a ll e
a r ela tive, Counsel or Attorney for either Party or h i
o the rwis e interested in the o ut c o m e of this a c ti o n !.
I 10 IN W IT N E S S WHEREOF, I have hereb I'
unto set my hand at Charlotte, North C a r olina, on !
I 12 this the day of July, 1983. l -
l 13 j.
I 14 j!
!I
'8 ll n
j, LYNN B. GIL LI A M ]
Court R eporte r !!
b 17 l j i d, I (l 18 d 4 l
l 19 ! ti l l .
20 '
k 1
21 22 23 !
M y Commis sion expires May 12, 1988. l 24 25' l
t LYNN B. GILLIAM l STENOGR APH REPORTER