ML20106G555
| ML20106G555 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/07/1983 |
| From: | Williams H DRAVO CORP. |
| To: | |
| Shared Package | |
| ML20106G461 | List: |
| References | |
| NUDOCS 8410310243 | |
| Download: ML20106G555 (33) | |
Text
e UN ITED STATES' OF AMER IC.'-
NUCLEAR REGULATORY COMMISSION 1
e j INTERVIEW l
-0F HARRY WILLIAMS Pittsburgh, Pennsylvania November 7, 1983 i
e i s l Appearances:
l l H. BROOKS GRIFFIN, NRC Investigator DONALD D. DRISKILL, NRC Investigator LeBOEUF, LAMB, LEISY & MacRAE By: JOHN S. KINZEY, JR., ESQUIRE Counsel for Dravo Constructors, Inc.
and Harry Williams TAYLOE ASSOCIATES Registered Professional Reporters Telephone (SO4) 461-1984 Norfolk, Virginia 8410310243 840726 PDR ADOCK 05000445 G PDR ,____
EXHIBIT (16)
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-; i E'
! I NDEX l
WITNESS Examination by- Page -
Harry Williams Mr. Driskill 3-
~
Mr. Griffin 19' Mr. Driskill 22 Mr. Griffin 27 f
,o O
O e e e
9
V 2
1 Sworn statement of-HARRY WILLIAMS, taken before 2 .Marcia B. Hall, a Registered Professional Reporter, ll. commencing at~ 3:35 p.m., on the 7th day of November 1983, at 4 the office of Dravo Constructors, Inc., 32nd Floor, One ,
Oliver Plaza, Pittsburgh, Pennsylvania.
~
5 6 ------ -
'7 8 MR. GRIFFIN: For the record, this is an 9 interview of Harry Williams who is employed by Dravo 10 Constructors, Inc. The-lo. cation of this interview is the 11 32nd floor conference room of One Oliver Plaza, Pittsburgh, 12 Pennsylvania.
13 Present at this interview are for the-NRC, H.
14 Brcoks Griffin and Don D. Driskill.
15 The interviewee is Mr. Harry Williams. He is 16 represented by John S. Kinzey, a Dravo attorney, also Mr.
17 Williams' representative in this interview.
18 I need to swear you to the contents of this 19 interview. If you would stand again. Since we are doing two 20 separately.
21 (The witness was first duly sworn.)
22 THE WITNESS: First one doesn't count?
23 MR. GRIFFIN: For our convenience.
24 MR. KINZEY: For the record, there was a 25 colloquy among counsel during the interview which Mr. Griffin TAYLOE ASSOCIATES
^
-l Harry Williams 3 1 undertook immediately preceding this.one. I don't believe_we 2 need to go through that again, and incorporate it here by 3 reference.
4 MR. GRIFFIN: All right.
5 -
MR. DRISKILL: I agree to that. There is no 6 problem with that.
7 HARRY WILLIAMS, being first duly sworn, was 8- examined and testified as follows:
9 10 EXAMINATION
?
11 12 BY MR. DRISKILL:
13 Q. Harry, I would like to find out when did you-14 leave Comanche Peak?-
15 The last day working there?
16 A. Now, see what day did Labor Day fall on? 4th, 17 Sch? The 2nd. Friday the 2nd.
18 Q. September the 2nd?
19 A. '83 20 _ Q. 1983. Okay. What I would like to discuss wi'th 21 you relates to the termination of Ronald Dunham, D-u-n-h-a-m, ;
i 22 who was employed as a protective coatings quality inspector.
23 I believe he was terminated on August 26, 1983, 24 just prior to your leaving. That was on a Friday, August 26?
25 A. Yes.
TAYLOE ASSOCIATES
U y
Harry Williams 4 1 Q. I guess Friday prior to your leaving? {
2 A. Right.
3 Q. Holiday, I guess prior to.your leaving, or 4 Friday.
5 Before we discuss this at any' length, I would 6 like to ask you, have you discussed this matter with anyone 7 since you have left: Comanche Peak?
8 A. Attorney.
9- MR. KINZEY: Aside from ---
10 BY MR. DRISKILL:
11 Q. Aside from counsel, have you discussed it with 12 Tugco counsel, with Brown and Root lawyers? There were a 13 number of people conducting investigations into this matter.
14 Have they called you on the phone and talked to you about it?
15 A. I talked to Rick -- -
16 Q. Nick?
17 MR. KINZEY: Mr. Walker, the other attorney who 18 was here.
19 THE WITNESS: Him and Nick Reynolds.
20 BY MR. DRISKILL:
21 Q. Did you talk to Peter McClaine, an attorney for 22 Brown and Root, Houston?
23 A. I don' t know Peter McClaine.
24 Q. Did you talk to -- I don't k'now the guy that ,
25 works.for Tugco who conducted -- anyway, he conducted an TAYLOE ASSOCIATES m_
, , Harry Willicm3 5 1 investigation into this matter and interviewed a number of 2 people? Tony Vega?
3 A. Vega?
4 He called me one day on the phone. Let me think.
5 Q. That would have probably been shortly after you 6 left?
7 A. Yes. Because I didn't talk to anybody really 8 about Dunham.
9 Q. After you left?
10 A. Right. Yes.
11 ' Wait a minute -- let me think about it. He 12 called.
13 Q. Were you already in San Diego?
14 A. I was in California, yes. Trying to think of 15 the discussion. Can't recall right now.
16 Q. Okay. It may come to you.
17 A. Yes.
18 Q. Have you since talked to Gordon Purdy, Ronald 19 Tolson, Tom Brandt?
20 A. No. .
21 Q. Or any of those people?
22 A. I have talked to Tom Brandt, but not discussing --
23 just talking golf.
24 Q. Okay. A lot of good golf courses in San Diego?
25 A. Yes. The Acey Four.
TAYLOE ASSOCIATES
~
Harry Williams. 6 I
1 Q. -Quite frankly we go down to San Diego, too.-
2' I think that we can all agree on the fact.here, 3 at-~1 east the ones that want to know about it, that Dunham's 4 termination was predicated on what was perceived to be his 5 conduct in a meeting which was conducted on1 the Wednesday, 6 August 23, I believe was the date?
7 A. Yes. It was, correct.
8 Q. Prior to his termination?
9' A.. True.
10' O. I am not exactly sure about that --
11 A. Wed'nesday, Thursday.
12 Q. Did you attend that meeting?
13 A. Yes, sir. .
14 Q. Would you relate.to me what occurred-in that 15 meeting?
w txe h<
16 A. Wi th her- here" 17 Q. Sure.
18 A. He became upset in several cases. Ranting and 19 raving about how good he was and all he had done in his life 20 as a painter, and sort of got away from the program.
21 Q. Okay. This was a meeting that was being 22 conducted for what purpose?
23 A. The meeting was called because of the inspectors.
24 They wasn't satisfied with the way engine.ering was handling a 25 #
lot of the procedures that they were setting up for TAYLOE ASSOCI ATES
l
, i Harry William: , 7 I.
a :.c.%
I construction and the answers back on NCTs, and what-have-you, 2 which has all been agreed with when they make it, it all has 3
to come.through QA, whether it is either yeah or nay, you 4 know.
5 And they sought to find out, myself, Tom Brandt, 6 and QA involved and the QA organization, as far as not 7 backing them up.
O And so Tom, he called in these two engineers 9 from Ebasco. Barry -- I can't think of his last name.
1% mct 10 Q. C:; r io i l ?
yi c, E t 11 A. Pertail, yes. And Tom Kelly.
12 And their sole purpose is to come down there and 13 discuss what engineering can do with paint to be an 14 acceptable method and not lose quality, either.
15 And that's what the whole concept of the meeting 16 was for, to put their mind at ease and say, " Hey, we are not 17 shafting you or trying to get around you or anything else.
18 We are just trying to tell you what can be done and to look 19 for maybe some changes."
20 And this is what the whole concept of the -
21 meeting was for.
22 Q. Okay. Go ahead? -
23 A. And they were opening it for questions. They 24 said: any comments? They would be more than glad to take 25 them from the inspectors.
TAYLOE ASSOCIATES
., Harry.Willicms 8 i
1 The night shift was not there. Just strictly 2 day shift people.
3 Q. As I understand it, then, all the day shif t-4- people or at least the ones available were asked to attend?
5 A. Were they? Right. -
~6 Q. And did they receive any instructions' prior to.
7 attending?
8 A.- Other than the fact they were ' going to be here 9 to have a discussion on paint. -
10 'Q. Were they told if they have any questions, to 11 ask them?
12 A. Yes.
f 13 A. The two engineers told them that before they 14 started. The engineers, they said, "Now, we are_ going to
. Sde 15 discuss. If you have questions, fett free to ask."
16 Q. You attended this meeting?
4 17 A. I was there, yes.
IS 0 What other supervisors or individuals who are 19 not protective coating inspectors were present, te the best 20 of your recolJection?
Nese e M o e < ;s-21 A. My lead which was Mau ::. Everett Maw:cr and 22 Curly Kisler. He was there.
- 23 Q. Do you remember how to spell his name?
24 A. -You would ask me that, wouldn't you? I think 25 K-i-s-1-e-r. I think that is right.
TAYLOE ASSOCIATES
\
Harry Williams 9
1 Q. So the three of you attended as well as these 2 'other individuals?
'3 A. Yes, sir.
4 Q. Protective coatings inspectors. And based on 5 what you said, it is your opinion that Dunham was somewhat 6 disruptive?
7 A. Yes.
8 ,0 Would that'be the appropriate term?-
9 -A. Yes.
10 Q. You
?
felt like he dominated it?
. 11 A. Some respects, yes, he did dominatt .t. When he ca ve 12 rnma forward, he was loud, boistrous, and ranting and raving.
13 Q. Was he upset?
14 A. Yes.
15 Q. Did he make comments which reflected poorly on
- 16. the QC program?
17 A.
He made comments that the craftsman is getting 18 away with everything, and we are setting on our dumb ass 19 doing nothing.
20 And engineering was helping them along.
21 Q. With respect to what?
22 A. Not helping the craf t when they buy off.
23 Q. The way the procedures are written?
24 A. Yes.
25 Q. And did any other persons ask any questions?
1 TAYLOE ASSOCIATES i
-Harry Williems ,' ~10 l' A. I think one.or two of'them did, but there was 2
discussions about what t'he engineers' drawings were about.
3 Q. '
Was Dunham's demeanor in meetings on other 4
occasions the same or similar to what it was on this 5 particular occasion?-
6 A. No. He has always been calm, conservative, you know.
. 7 8 Q. Cool, calm and collected? .
9 A.- Yes.
10 Q. During the course of this meeting, did anyone
?
11 make an attempt.or an effort to ask him to control himself?
12 A. No.
13 Q. Nobody said anything to him?
14 A. (Witness shaking head) 15 Q. How long did the meeting last?
16 A. I am guessing, say, an hour to two hours.
17 Q. Hour and a half? !
18 A. Hour and a half, something like that.
ere t 19 Q. Did perimik and Kelly have an opportunity to 20 discuss the things they wanted to bring out?
21 A. Yes.
22 Q. During the course of Dunham's questions and 23 comments, did they address any of the questions?
24 A. They addressed questions, and more or less went 25-around it because that was not the intent of their meeting.
TAYLOE ASSOCIATES
Harry. Williams
, 11
.I I
1 Q. Some^they_did address?
l
. I 2 A. Now, they just more or less said -- tried to put 3 it, .instead, that they are not down there to discuss 4 construction problems. Trying to put him o,ff and get on with 5- the subject-that they.were there- for.
. 6- Q. I understand, now, that there was a meeting held 7
with respect to his conduct during the' course of this meeting,-
8 after the meeting?
9 A. Uh-huh. Yes.
10 Q. Would you mind telling me what occurred during
. 'll .that meeting and what was -- first of all who was present?
meeste 12 A. Myself, Mewset and Curly, went back into my 13 of fice and discussed his attitude and professionalism at the 14 . meeting, you know.
15 And we all agreed that we needed to take it to 1
16 Tom, and it was unbecoming in front of these two men to l 17 embarrass them like that and get off track of what they were 18 there for. And discuss it with Tom Brandt. -
19 Q. Prior to this meeting or prior to discussing 20 with Tom Brandt, did you have an opportunity to talk with
~
icuLt 21 either}{.rtaitorKellyregardingwhat had happened?
[
22 ,
A. No. I was too embarrassed to.
23 Q. So you then went to talk to Tom Brandt about it?
24 A. Yes, sir.
25 Q. Tell me just what you can remember?
TAYLOE ASSOCIATES
4 Harry Williams .12
. l.-
1 -1 -A. .We'just discussed the situation about what h_e ,-
-2 - d id , and I think it was a mutual' ag reement.- We felt that1he .
- 3 needed counseling about his manner and
- that was agreed to.
- _ 4 -Q. Agreed ,to by whom?
~ '
5 A. By Tom.
6- O. Was this on the same. day that the meeting
., 7_ occurred or was it following that?
8 A. I think it was the-following morning we went and 9 .tal'ked about it because oy the time we got th e'r e , it was late 10 and the bell.had rung.
11 Q. So did you later discuss this. matter with Gordon 12 Purdy, or situation with Gordon Purdy?
13 A. Gordon and' Tom, yes. He was there the following 14 day.
15 Q. Was Ron Tolson there?
16 A. I den' t recall.
17 Q. Where was the meeting held?
18 A. In Brandt's office.
19 Q. Was it just you and Gordon and Brandt?
20 A. Curly.
21 Q. And Curly?
22 A. Yes.
- 23 Q. So Tolson wasn't there?-
24 A. No.
25 Q. And it was agreed that he would be counseled?
, TAYLOE ASSOCIATES
i
' ' 1
' Harry Williams 13- l 1 A. And I-think they was going to, at that time, !
2 think'they was going'to give him a three days cooling off 3^ -period.
4 Q. In other words, three days leave without pay?-
5 A. Yes..
6' O. Whose idea was that?
- 7. A. I think it was mutual ~' agreement by everybody.'
8 Q. Did anybody believe he should- be fired?
9 A. I don't know. I personally, I didn't believe it, 10 no. ,
11 -Q. Based on what?
12 A. His past performance.
13 Q. And his past performance had been what?
A 14 A. Been good.
15 Q. He was a supervisor?
16 A. He was my lead in the back fit group.
17 Q. Did you believe that he was a good lead?
i 18 A. Yes. I 19 Q. Did you have any problems with him handling the 20 people that were working for him?
- 21 A. None whatsoever.
22 Q. Any problems with his attitudes or opinions 23 prior to that time?
24 A. None whatsoever.
i
~
25 .Q.- So then you agreed that -- did you agree that'he TAYLDE ASSOCIATES _
E .
Harry willicms
- 14
'l . should be given three days off? t
_2 A. I agreed, yes.
3 Q. Did any, to your recollection, did anybody
~ 4- disagree with that?
5 A. 'No. . Cike I.said, it was.all mutual agreement on 6 it.
7~ Q. Did you assist in the preparation of the 8 counseling report that was prepared?
9 A.- No, I didn't 10 Q. .Did you ever see it?
f 11 A. No.
12 Q. Who has that?
13 A. I don' t know.- ,
14 Q. Did you know when it was prepared?
15 A. I assume it has to be acco rd ing to procedure, 16 you have to.
~
17 Q. It is my understanding based on comments made ,
i 18 from other several, or people that you were not present on 19 the Friday that this counseling and his termination occurred?
20 A. True.
21 Q. Was it as a result of the fact that he was going 22 to be counseled on that particular occasion?
23 A. No, the fact that I couldn't get out of bed.
24 Q. You were sick?
25 A. Sick. I couldn't move my back. I was in bed ;
I TAYLOE ASSOCIATES ;
l Harry Williams 15 1 all weekend.
2- Q. So 'it was de,termined that he would be given
'3 three days off? That was in agreement?
4 A. To the best of my knowledge,'3'es.
5 Q.. That was in agreement between Gordon and Tolson, 6 basically?
7 A. Basically.
8 Q. And then he would return and be a lead inspector 9 once again; right?
10 A. Wouldn't change his position, no.
11 Q. Then you came back on Monday, and he was gone?
12 A. True.
13 Q. Did you talk to anyone about it on that 14 particular occasion?
15 A. Just what happened.
16 Q. Who told you what happened?
17 A. Well, just by hearsay what happened. I wasn't 18 there. So I really don't know. I am just going by what 19 people said.
20 Q. You didn't talk to Brandt about it?
21 A. Brandt wasn't there either.
22 Q. Brandt wasn't there the fol'1owing Monday?
23 A. He was there the following Monday. But he 24 wasn't --
25 Q. Did you talk to Purdy? Did anybody tell you TAYLOE ASSOCIATES
I I
! .Horry. Williams '
16 E. 5 t
1
-1 what had happened to your lead inspector? ;
-2 A. Curly did.
- 3 Q. What did'.'he say? +
4 A. He told me he was terminated.
5 Q. Did he tell'you why? -
6 A. Uh-huh. .
7 Q. What was that reason?
8 A. That he ranted and raved up there just like he 9 does in the meeting.
i; 10 Q. Did he tell you that Dunham had refused'to s'ign
?
11 the counseling report?
12 A. Yes.
13 Q. Did he tell you that Gordon Purdy had given him 14 the option of either signing the counseling report or being 15 fired?
16 A. He said he gave him the option to sign it, l
17 He asked him to sign it. He said he wouldn' t. l 18 Blankety, blank, blank. '
19 Q. Well, that was the reason he was fired was 20 because he wouldn't sign it; right?
21 A. I think a few other things that were said that 22 caused his termination.
23 Q. So he was terminated for some of the other 24 things he said in addition?
25 A. In addition to that.
TAYLOE ASSOCIATES q
m
~
~*. '
Harry Williams 17 1 0 And how do.you know that? - Did Gorden tell you 2 that? l 3 A. Like I said, from the third-party again, w.e s E.s2 -
4 0, +.: ue :7 7
~5 A. P'mer , yes.
6 0. Who was present at the meeting?
7 A. Uh-huh.
- M c t s a c.
8 Q. Did K+wser tell you what he said?
9 A .~ Yes.
10 0 'g'ould you rela te that to me?
. 11 A. With her here?
12 0 That's okay. She can handle it.
13 A. He said, "Take me to the fucking gate. I ain't 14 signing nothing."
t.t:,o s eC 15 0 "2;>cer said that's what he said?
16 A. That's right.
17 Pardon me, ma'am, meesc c.
18 0 And according to K+*eer , that's what happened?
19 A. Apparently he said that several times. That's 20 what I have been told.
F m a.t.
21 0. - Did you ever talk to Kelly or "c r te44 ?
22 A. On this?
1 23 0 With respect to what happened in the meeting?
24 A. No. l 25 Q. You never discussed it with either of them?
l TAYLOE ASSOCIATES
LA ,
M Horr/ Williams 18
~
No.
i 1 A.-
p: .' l i
. ~2 . i' - Q. At any-time did you ever; discuss it after the i j
3 dact'with either Brandt, Purdy.orcTolson? !
4 A. Just the following day is all.
5 Q. On Monday?
6 A. No. On th'a t1fo11owing day, after the meeting.
7' Only time I discussed it a f ter tha t,- I dropped it. It is'in.
-3 their-hands.
9 Ain't going to ride a sore horse.
10 Q. You never saw the counseling report?
?
11 A. No, sir.
12 Q. Do you believe that what happened was the proper 13 thing to have done?
14 A. 'What do you mean?
15 Q. Did you have any feeling that perhaps he 16 shouldn't have been terminated?
17 A. Now you put me on the spot te answer that.
18 Q. Well, the reason I ask that is that he worked 19 for you?
' 20 A. True.
21 Q. You knew him a lot better, and perhaps his 22 performance was a separate issue aside from -- I am not 23 asking you to second-guess what anybody else has done. But I 24 am just asking you: how do you feel about it?
25 A. Well, a man's performance is one thing, but when .
g TAYLOE ASSOCIATES
'I I
1 d Harry l Williams -
19- ,1 ji
...,_ l'~ f he conducts himself.'in another way, I know what would happen 2' .ho me if I conducted myself that same way.
_ r 3- Q. What?
4= 'A. I would-be out there kicking cans up the-street.
51 Looking for,a' job.
'6 I would expect it. Be a damn fool if I didn't.
7 Q. So'you don't believe that~he should have 8
expected any more than. wha t he got out'of it?,
9 A. He asked for,it.
lio _
Q. But based on -- aside from that particular issue 11 you would have had no objection to him working for you from 12 now on; right?
13 A. No.
14 Q. At least --
15 A. The consideration of his past, no, I had no 16 problem.
17 MR. DRISKILL: Okay.
18 MR. GRIFFIN: I have one other question.
19 MR. DRISKILL: I am through with him.
20 21 BY MR. GRIFFIN:
22 Q. You have indicated a-change of attitude by Mr.
23 Dunham.
24 Do.you know what events led up to this change of l ,
i.
25 attitude that caused him to be that way?
I TAYLOE-ASSOCIATES _
- U i.
i, s20 Httry. Williams '
- o. -
'l : A. Wish I did. I would be making,more money than.I 2
- l. ;
did now.. ,.
3 0. Do you have any personal knowledge of the 41 incident.or confrontation or-anything anybody ha's told you-
'5 since all these events occurred, which.mayfshed some light on 6 his attitude, his action and his attitude. during that meeting 7 and the meeting within which his termination resulted?-
8 Did you ever hear 'anything as to why? ,
9 A. No, I haven i
- t. It just befuddled me, I will b'e 9
10' honest with you. ,
i:
, w 11 0 When this meeting was called --
12 A. Which one?
13 0.- The meeting in which the two engineers were 14 there.
15 A. Okay. >
16 Q. When Mr. Dunham was, you say, ranting and raving, l
. 17 was'he ranting and raving and posing questions? Or was he ,
t -
18 asking questions of engineers? I i
19 A. He wasn't asking questions pertinent for the i
20 reasons they were'there.
21 They were there to discuss, like I said, what 22 engineering can reall.y do with the paint, how far they can go 23 with it and still get a quality product. And the changes 24 that may come down from DBA tests, whatever, that may change 25 ' the ' prog ram. And still have a good sound product.
,. TAYLOE ASSOCIATES L
y... - - -
.y r '
- - ~' '
Harry williams. 21
- l
.y Tnis-is wher.e I think QC was getting their -- I ar 2 don't know what-to call it -- bewilderment because they fel:
- 13 nobody was backing.them'up.
4 And they were going to -- they wasn't shying the
~
program, is what-I am'tryingLto say, and still getting a good 5
,. 'i,-
1 ,-
6 product.
? Our procedures were changing daily. They were 8 changing damn near weekly at times because of the different 9 stuff engineer was incorporating and what we were doing.
l c s 10 And they were just ticked because-they didn't
. 11 feel I was backing them.
12 Tom Brandt wasn't backing them up and QA. But 13 QA is approving what engineering is doing.
14 The reason we brought the engineers in was to 15 discuss this. The why's, and the for's.and so on about it.
16 Try to put their mind at ease and say, " Hey, you are going to 17 get a good prod'act. Still doing our procedurals with it.
18 This what is we can do. This is what you may see coming."
n.
19 Q. This is for the benefit-of the QC inspectors?
20 A. Yes.
21 To put their mind at ease.
22 Q. Besides the way in which Mr. Dunham presented 23 his grievances, what was the nature or was it ever defined of I 24 the nature of his concerns? 'What was he upset about? Based
. . E 25f ., on what he said in the meeting, what was his major concern?
f1 TAYLOE ASSOCIATES
e j; Harry Williams 22
.{-
Well, his concern-was that, from what Igathered,h=
1 A.
2L that he couldn't do anything wrong. He didn't give a shit
- 3 who knew it. He was in the craft. He said, "I done 4 everything, God damn thing.in.the craft."
I
~
5- Q. Let.me reask the question again. Wi hout 6 . characterizing what he was thinking -- what do you think his- ,
7 major concern was as related to his job?
8 What was he complaining about?
9, A. That he just felt the' craft was getting by with 10 murder.
?
11 Q. Did you perceive while you were in the meeting 12 tnat Mr. Dunham's concerns in this area were also shared by 13 the other QC inspectors?
14 A. Nobody else spoke up about the same subject.
i
'15 Q. I am just asking your opinion' '
i 16 A. I don't know. I am assume that they all -- I '
17 don't know, to be hones'. with you. By looking at their face?
18 Q. Yes. I am just asking for your opinion.
19 A. I couldn't tell. One of the gentlemen in the 20 group asked the question and his question was particul'a rly 21 about the painting and why the engineers were there. He 22 answered it and that was it. I 23 MR. GRIFFIN: Okay.
24 BY MR. DRISKILL: .
25 Q. Let me go back a seco ud . There is one other TAYLOE ASSOCIATES
l t
- 2' '- l Harry Milliams-23- R 1; _ thing . I wanted to'ask' you about.--
2' Were you aware-that Dunham had gone-and had a
'3 private meeting .with Gordon Purdy several: weeks prior to that 4 occasion with regard;to some of the things he was unhappy 5 about? ' '
6 A. No . - I' don't remember.
7- O. And were you-aware that he had then been called 8 to-Ron Tolson's1 office? .
9 A. 'I' knew he had been with Ron.Tolson.
10 -Q. ,
With' respect to comments he had made about.
. 11 intimidation and so on? .
12 A. I didn't know what it was about.
13 Q. Did Tom Brandt ever discuss a meeting that he 14 and Tolson had with Dunham in Tc1 son's of fice several weeks 15 prior to this?'
16 A. Yes. But then they had another meeting right 17 after that with me in there.
18 Q. What occurred there, or what did they say?
19 A. That Dunham and a few others were in there, 20 Tolson told them that he would back me up in any way I saiE.
23 That I was doing what he wanted, and that is the way it was 22 going to stand.
23 Q. Was it subsequent to that meeting that Tom 24 Brandt personally interviewed all of the protective coatings 25 inspectors?
TAYLOE ASSOCIATES
,s - .- -
E ,
lier ry Williana 24 1 A. He was interviewing them prior to that.
i 2 Q. Prior ~to the meeting with you? l I
- 3 A. He'had been interviewing them off and on Yes.
j 4~ f or qui te ' awhile. - I knew that. ,
5' .
Q. During the late spring, late summer?
6 .
A. Subsequent to my leaving? !
7 Q. Subsequent let's say to August, okay.
-8 Late spring.. Early summer?
On the same subject?
9 A. -
10 Q. Yes. The. subject being their perception that
, s 11 they were being intimidated?
12 A. I don't-know about intimidated I know-that they 13 were not getting the backing they wanted. That's why we 14 called the engineers in. I think that's why Tom called them 15 in. The same consensus from all of them.
16 Q. But you were aware that Ron Tolson had met with 5 17 Dunham and talked to him about this particular topic? j 18 A. Yes. !
19 Q. Did you know if it was a result of Dunham's talk 20 about these problems, having talked about these problems to- ,
21 Cordon Purdy?
22 A. No, I didn't.
23 Q. Had Dunham ever expressed to you any unhappiness 24 with the way the meeting with Tolson went?
25 A. No.
TAYLCE~ ASSOCIATES
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tiarry Willians 25 I
1
[ 0 In your discussion witn Brandt and Purdy on the I
{ ,
2 day prior to Dunham's being terminated, was there any '
3 discussion of his being terminated if he wouldn't accept the 4
counseling and sign the counseling report?,
5 A. I don't recall at the time. The only thing we e
6 discussed was that he was going to get three days off.
7 0 Did anyone think that he might not sign that or S. might not accept that?
9 A. I don't think -- figure the'y --
10 Q. Pardon?
11 A. I think they figured they might have a problem 12 with him.
13 0 And they said that?
14 A. Uh-huh.
15 0 And what if they had a problem with him with 16 respect to that?
17 A. I don' t know.
18 0 They didn't say that they would fire him?
19 A. No. You can't make that assumption. You need 20 , to see what is going to come up first.
21 0 Do you recall who made the statement indicating 22 that there might be problems with him as a result of 23 disciplinary action?
24 A. Gordon and Tom both felt that.
25 0 What did they base that assamption on?
TAYLOE ASSOCIATES
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t:
7 o
"~+ " J Hsr.ry.Williana 25 e- . +
1- '; A. 1: am just assuming that meeting witn the i
J i
j t
I'
[ 2 engineers.
l 3 Q. I am saying didLthey assume that they may have 4 I some problem with_him~ accepting this disciplinarian action as 5 a result of the' fact that they knew him --
6 A. I don't know.
7 !
Q. --
knew wha t kind of a guy he was or --
- - 8 A.- They knew more about about .him than I did, I-9 guess. Because I had no problem with him.
10- -Q. But they did anticipate that there may be some-11 problems with him?
12 A. Yes.
13 Q. To your knowledge,. there was no discussion that 14 if he gives you a bad time about this, "We will just fire him 15 or if he won't accept,that"?
16 A. I am assuming that, you know, to fire somebody l
i 17 like that they would have to take into consideration what he
! 18 wo uld do , what he would say, and the kind of position he put 19 himself in.
20 Because they are not --
it could be just the i
21 other way. He could have went up there and signed the damn 22 thing and left.
23 Q. Taken his three days?
24 A. Yes. And had a job. ,
25 Q. What alternative would he have had if he had
[ TAYLOE ASSOCIATES L -
at ;,
'. 2
~
!!.or ry Sill ians ' , s 27
' 8
- 1 - .wantid to . keep his ; job?
i 2 .;
' A .' Wouldnt have affected Nis job. -
e
. 3- -
Q. No . . I-am saying is there-some' manner of appeal
~
L4 .that he would 1have prior';to being.given three days off?
5
'InLother words,.it'.is cither take it or. leave it?
t-
-6 .l- .A.- Yes. ;Sasically'.
i 7 0. - So it was understood that -i f he didn' t war.t ' the '
' ~
8 three ---if he didn't.wantoto. accept.the d'isciplinarian 9 action, didn't want.to sign the counseling reports and accept 10 the dis'ciplina,rian' action, the only other alterna,Eive,-he
. 11 would-be terminated?
, 12- A. I think they would have told him he is going to.
13 ~ get three days without pay regardless and then he wouldn't 14 come back.
15 MR. DRISKILL: I d&n't have any other questions.
15 MR. GRIFFIN: I don't either.
17' BY MR. GRIFFIN:
l
-18 Q. Mr. Williams, has Mr.- Driskill and myself -- has 19 anyone threatened you in any manner or offered you any 20 rewards in return for this statement?
21 A. No.
22 0. Have you give this statement freely and 23 voluntarily?
, 24 A. Yes.
25 Q. Is-there anything further you would care to add i
TAYLCE ASSOCIATES
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e--.
iiarrf Willians 28 1 ! to the record?
!, i 2 i A. No.
3 (Whereupon, the proceedings were concluded at 4 4: 10 p.m.)
5 G
'7 8
9 10 11 l}.
-13 14 15 16 17 18 19 30 21 22 23 34 25 TAYLOE ASSOCIATES
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i 1 i COMMONXEALTH OF VIRGINIA AT LARGE, to wit:
1 2 ; I, Marcia B. Hall, 3 Notar/ Public in and for 3 the Commonwealth of Virginia at Large, of qualification i r.
4 :ne Circuit Court of the City.of Norfolk, Virginia, do l -
5 i certify that the foregoing sta tement of HARRY WILLIAMS was 1 -
6 j taken and sworn to before me at the time ar.d place 7 I aforementioned. ,
S ,
t' Given under mf hand this /If day of? tober 4c?< Q 9 1983.
10 '!
h '
11 !
12 b .A 13 Notary Public 14 15 16 17 18 19 20 -
21 22 23 24 25 TAYLOE ASSOCIATES
4 l . .
RESULTS OF I;iTERVIEW WITH EVERT RAYt:0ND I;0 USER AS RECORDED BV fRC INVESTIGATOR D. D. DRISKIg GN SOVEMBER 15, 1983 On November 15, 1983, Evert Raymond MOUSER, Civil Quality Control (QC)
Inspector empleycd by Scientific Applicatiuns, Incorpcrated, and working for Consumers Power Company at Midicr.d ituclear Plant Project, Miclard, Michigan, s.as interviewed by fiRC Investigator D.'D. OPISKILL at the Midland project.
blLSER stated he was employed by Ebasco Services, Incorporated, as a Non-AShE QC supervisor at the Cccanche Peak Steam Electric Station (CPSES) from January 19, 1983 to October 1983.
When cuestioned ccncerning the termination of Ronald A. CUi; hat: by Erewr & Poot, Inc., (B&R) cr. Au5ust 26, 1983, MOUSER stated he was present on the occasion
. DUNHAM was terminated. NCUSER also stated he attendec the meeting for protective coatings QC inspectors which was belo on about August 24, 1983, during which DUNHAM became loud and dominated the cecting with ouestions and ccaments. MOUSEP stated the purpose of the meeting was for tvec Ebasco engineers to discuss and answer questions concerr.irg technical protective coatings concerns. l'CUSER stated he felt DUNHAM w3s "out of line" in displaying such concuct in the presence of " guests" (the Ebasco engineers).
I NCUSER stated that folicwing the meeting, une of the engineers (no further identification) talked with harry WILLIAMS, Curly KRISHER and hiraself. i:0 USER statec the er.gir.eer said this isn't what "ve'rc here for." liOUSER statec he commentec that he was cr.tr.rrassed about what had happenec.
.j MCLSER stated the following day WILLI;t'5, KRISHER and he were talking with Tcm f SRANDT in BRANDT's office cr.d ciscussed DUNHAM's conduc- in -he i.,eeting.
f/0VSER stated BRATIDT called Gordon PURDY, wbc ther, carae to BRAfiDT's office. -
MOUSER stated'that KRISHER e;<plained to them in detail that hac' cccurred.
MOUSER stated he cces r:ct recall discussion of any discipiircry action at that I1me.
tiOUSET. stated that on August 26, 1983, KRISPER told him (MOUSER) that a decision had been made to counsel CUI, HAM, and give him 3 days off viittout pay.
EXIilBIT(17)
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n_ _ _
I;0CSER'rtated that later that day, KRISHER told him the 3 days off portion of the discip!inary action had been disregarded since the action had not been taken in a more timely canner. He' stated KRISHER said this was'the decisico of Ron
. -TOLSON. VOL'!ER stated KRISHER instructed him to bring DUNHAM to PURDY's office at about 4 o'cicck p.m. that day.
MOUSER stated that at 4 o' clock p.m., August 26, 1983, he. accompanied DUNHAM to PURDY's office. MOUSER stated PURDY a'nd KRISHER were aise there. Il0VSER stated that uren their being seated, PURDY gave CLAhAN the counseling report which DUNHAM looked at for cnly a few seconds. He stated that DUNHAM then becace very upset and said, " Fuck i.t, I wcn't change. Just walk me to the gate. I won't sign it." KGUSERstatedPURDYtriedtocalmDUNHAhdcun, without success. MOUSER stated PURDY then said, "Ok," and got up and walked from the room. MOUSER stated FukDY rcturr.ed and said, "If that's the way.it is, just walk him to the gate."' HOUSER stated DUNHAM ~then got up and left NOUSER statec FURDY instructed him to go with DUt' HAM. i MOUSER stated he then acccmpanied DUNHAM to the QC cffice tc gather his (DUNHAM's) personpl effects, subsequent to which DUNMAP t.ent to the B&R' Time Office to check cut.-
F0VSER stated it was his impressign that DUNHAM had quit. MCUSER stated he had expressed this epir.icn to other coatings inspectors cr. that day. MOUSER stated that on Ponday, August 29, 1983, he learned that DUt:HAR was fired rather than resigning.
klher, querieo concerning the counsclirg civen to DUNHAM during the ccunseling sessien, f GUSER stated it was on an 8f x 11 ccurseling foru (not a three-part memorandum) which he believed was typed. ,
l END OF RESULTS OF INTERVIEW WITH EVERT RAYMOND MOUSER GN NOVEMBER 15, 1983 SIGl;ATURE:
D. D. DRISKILL, Investigator OI Field Office, Regicn IV 2 1
.