ML20211C608
| ML20211C608 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/08/1984 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML20211C348 | List: |
| References | |
| FOIA-85-312 OL-2, NUDOCS 8606120354 | |
| Download: ML20211C608 (238) | |
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UN11ED STATES NUCLEAR REGULATORY COMMISSION 1
IN THE MATTER OF: DOCKET NO: 50-445-OL2 ;
50-446-OL2 TEXAS UTILITIES GENERATING COMPANY, et al.
F = " d a Seak . Steam Plectric Station, Units 1 and 2) ,
PREHEARING BRIEFING l
q-l LOCATION: BETHESDA, MARYLAND PAGES: 1- 204 e
DATE: THURSDAY, NOVEMBER 8, 1984 l
i ACE-FEDERAL REPORTERS, INC.
8606120354 860606 PDR F01A Cq!:ial ?r.~xters CARDE85-312 PDR 444 Nh Critol Street .=
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l Washirg.on. 0.C. 20001 l
(202)2 6-3700 NATIct mTot coVERACE
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1 UNITED STATES OF AMERICA 3 2 NUCLEAR REGULATORY COMMISSION 3 -------------------X In the Matter of: :
TEXAS UTILITIES GENr. RATING : Docket Nos. 50-445-OL2 5 COMPANY, et al., : 50-446-OL2 6 (Comanche Peak Steam Electric :
Station, Units 1 and 2) :
7 :
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x 8
Room 422 9
Phillips Building 7920 Norfolk Avenue Bethesda, Maryland 10 Thursday, November 8, 1984 11 The briefing in the above-entitled matter was convened i 12 !
pursuant to notice at 1:00 p.m. !
3 13 APPEARANCES: :
14 On behalf of the Applicant:- ,
15 McNEILL WATKINS II, ESQ. . >-
16 ERIC L. HIRSCHHORN, ESQ.
SCOTT M. DuBOFF, ESQ.
Bishop, Liberman, Cook, 17 ,
Purcell & Reynolds 1200 Seventeenth Street, N.W.
18 Washington, D. C. 20036 1 19 on behalf of the Nuclear Regulatory 20 Commission Staff: _ __
STUART A. TREBY, ESQ.
21 i
Office of the Executive Legal Director 22 U. S. Nuclear Regulato'y Commission Washington, D. C.
23 24 e Feder:J Reporters, Inc.
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2 1 APPEARACNES (Continued):
2 On behalf of Citizens Association for 3 S und Energy: l l
ANTHONY Z. ROISMAN, ESQ.
4 Trial Lawyers for Public Justice, P.C.
2000 P Street, N.W.
, 5 Suite 611 Washington, D. C. 20036 6
ALSO PRESENT:
7 JAMES LANDERS Dallas Morning News MEMBERS OF EG&G TEAM:
9 BRUCE KAPLAN, EG&G Idaho 10 WILLIAM E. STRATTON, Idaho State University
- . CHARLES M. RICE, LRS Consultants 11 NEWTON MARGULIES, University of California, Irvine 12 (m': 13 !
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3 1 CONTENTS
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2 WITNESSES EXAMINATION 3
Bruce Kaplan )
William E. Stratton )
Charles M. Rice ) .
4 Newton Margulies )
S by Mr. Roisman 14 by Mr. Hirschhorn 132 6 by Mr. DuBoff 164 by Mr. Hirschhorn 165 by Mr. DuBoff 170 7
by Mr. Hirschhorn 17C by Mr. DuBoff 182 8
9
, EXHI BITS '
10 NUMBER IDENTIFIED '
Exhibits 1 and 2 ~23 12 Exhibit 3 61 13 Exhibit 4 65 14 Exhibit 5 96 15 Exhibit 8 132 Exhibit 9 142 16 Exhibit 7 153 17 ,-
Exhibit 6 159 18 19 l 20 -._
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20989.0 4 .
BRT 1 PROCEEDINGS ,
2 MR. TREBY: My name is Stuart A. Treby. I'm 3 Assistant Chief Hearing Counsel for the Nuclear Regulatory 4 Commission, and we are here today to hold a briefing s Hon '
5 session in accordance with the se7s' ion of the licensing 6 board at transcript _page 18,069. I would like to state 7 that the staff has made the team members of the EG&G Idaho 8 report available today voluntarily; that this is pursuant 9 to,our agreement that we would be holding a briefing 10 session; that this is not, as the staff understands it, a 11 deposition in the sense that there has been a request for 12 a deposition in accordance with the regulations of the
,- 13 Commission, but that it is a briefing session so that the 14 parties can become familiar with the team members, what 15 roles they played in preparation of this report, and ask 16 any questions with regard to the report -- how it was 17 prepared, what the conclusions are, the basis for those 18 conclusions -- so that they are knowledgeable about the 19 report.
20 I think that for the purposes of thic meeting, the 21 staff determined that it would be appropriate to have a ,
22 transcript made of the briefing session, and a transcript 23 is being prepared at this time.
1 24 MR. WATKINS: Stuart, is it your understanding 25 that a copy of the transcript will or will not be given to
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1 the board?
2 MR. TREBY: I believe that a copy of the 3 transcript probably will be given to the board as part of 4 the discovery aspects of the proceeding.
5 MR. WATKINS: The board has seen all of the 6 documents that the staff produced in response to discovery 7 requests?
8 MR. TREBY: That is correc't. We have filed 9 ccpies of all of those documents with the board and the 10 parties.
11 At this time it might be appropriate .just to have each 12 of the people who are present here identify themselves for 13 . the record. '
14 Perhaps first we can have the members of the EG&G team 15 who are present here identify themselves.
16 MR. RICE: Charles Rice, with LRS Consultants.
17 DR. MARGULIES: Newton Margulies, University of 18 California, Irvine.
19 DR. STRATTON: William Stratton with Idaho State 20 University.
21 MR. KAPLAN: Bruce Kaplan, EG&G, Idaho. _
22 MR. TREBY: Now perhaps we should have the 23 attorneys for the parties identify themselves.
24 MR. WATKINS: I thought we already did that.
25 MR. TREBY: Well, we didn't do it on the
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1 transcript, though. I think it might be worthwhile just 2 to have a complete record of this meeting if we did that.
3 If the applicant's attorneys would ideritify themselves 4 first?
5 MR. WATKINS: My name is McNeill Watkins for 6 applicant Texas Utilities Electric Company, et al. With.
7 me from the firm of Bishop, Liberman, Cook, Purcell &
8 Reynolds are Scott DuBoff and Gary Hirschhorn.
9 MR. ROISMAN: I'm Tony Roisman with Trial' 10 Lawyers for Public Justice, and we represent Case,.the 11 intervenor. ,
12 MR. TREBY: And the record will reflect that g
s 13 there is an observer here from Texas Utilities Electric 14 Company. At the beginning of this session before,we 15 started we determined to flip a coin to see which of the 16 parties would go first. Mr. Watkins won the flip of the 17 coin and determined that he would prefer for Mr. Roisman 18 to go first.
19 Also, before we had started this session, I had some fellphon e n1 20 (estimon(] conversations with each of the attorneys for the 21 respective parties, and indicated that I proposed that 22 each of the team members make very brief statements 23 identifying who they are, and what role they played, so 24 that that would be available to them before we started:
25 and that after that was completed each side would have
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20989.0 7 BRT 1 approximately three hours of uninterrupted time to ask 2 whatever questions they wanted to today, and that we would 3 resume tomorrow at 9:00, at which time Dr. David Bowers 4 would be available, who is a fifth team member, that he 5 would be available for questioning for one hour by each of 6 the parties and then each of the parties could have an 7 additional hour to ask any other questions they might have 9 of any team member.
9 With that, I guess we ought to start with the' team 10 members. Perhaps we ought to start with Mr. Bruce Kaplan, 11 who was the team leader.
12 MR. KAPLAN: My name is Bruce Kaplan, I'm an 13 organization development specialist at EG&G Idaho. .
14 EG&G is a contractor to the Department of Energy, and 15 does research and development work,for the Government. My 16 work involves efforts to increase productivity and quality 17 of working life through individual and organization 18 effectiveness.
19 In general, I focus on people and their relationship to 20 the job, the technology, organizational structures, and 21 organisational goals and directions. I work with 22 individuals, groups, relations between groups and 23 relations between various groups in a larger organization ,
24 as well as organization in relation to the different 25 companies in its environment.
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O-20989.0 . 8 BRT 1 My graduate studies included organizational behavior at 2 Case Western Reserve, Cleveland and I have a master's 3 degree, master of science degree in organizational 4 development from Pepperdine University.,
5 My expertise is in diagnostic and improvement processes 6 in complex organizations, and my work commonly involves 7 assessment, management, and organization effectiveness.
8 My thesis was on organization climate; in particular, 9 support of climate and its significance for results-oriented 10 management.
11 What I add to the team, I believe, is a perspective 12 from an internal specialist. I deal with management and 13 organization problems on a daily basis. I"have some 14 knowledge of organizational behavior, organization 15 development, business research, and the nuclear industry, 16 and therefore felt comfortable playing a coordinator role 17 on this task.
18 My role on the task was to be,a project manager for 19 this study team. I was responsible to define the scope of 20 the task and subject of the study. I needed to define the 21 disciplines needed and assemble the team. I,_did this on 22 the basis of NRC needs and my knowledge of the situation.
23 I have served as coordinator of the team internally and 24 as contact with EG&G ' and with the NRC. I have served as 25 content editor on the paper, and actually wrote the
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20989.0 . 9 BRT 1 abstract for the report. I have not done the reading of 2 the depositions and the office inspection reports; that my 3 , views are primarily from the expert opinion and 4 information proyided.me by Rice, Bowers, and Margulies.
5 The scope of this task that the study team did was 6 based on a fairly narrow charter. Our job was to develop 7 an expert opinion concerning the climate of intimidation.
8 We did not do a general managen ant and organization 9 assessment. We did work to advise the NRC staff on their 10 position. And I just wanted to point out that, when we 11 undertook this task, it was to advise them as to what 12 their position should be. At that time our understanding
-s 13 was they did not have a position.
14 We took -- developed an interdisciplinary team and 15 developed an interdisciplinary perspective. Doing the 16 readings -- reading all the d'epositions and reports were 17 Newt Margulies, who represented the discipline of 18 organizational behavior; Chuck Rice also did readings, and 19 he was my industry expert -- expert on the nuclear 20 industry; analyzing the surveys was David Bowers who was 21 an expert on survey, survey analysis,and organizational 22 climate; and serving as an integrator and interim 23 coordinator role in my absence was William Stratton.
24 My findings are just as stated in the paper. Basically, 25 I found that management may be criticized in some aspects
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20989.0 ,
10 CRT 1 of their style and approach, but these did not constitute 2 a climate of intimidation. My conclusion is that there-3 neither was nor is a climate of intimidation at CPSES. So 4 my views haye been fully integrated in the report and I 5 fully support the paper of this study team.
6 MR. TREBY: Mr. Stratton?
7 DR. STRATTON: My name is Erwin Stratton. I'm 8 an associate professor of management at Idaho State j i
9 University. I have been on the faculty there for 10 years.
10 My basic background, I have an undergraduate degree in 11 mechanical engineering, a master of science in industrial 12 administration, and my Ph.D. degree is in organization 13 behavior from Case Western Reserve University. *
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14 With respect to my contribution to this report, my
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15 initial involvement was simply some informal consultations 16 with Mr. Kaplan, with respect to nossible resou,rce people, 17 for the study. At a later period -- point, then, I was 18 invited to join the team. My roles really were as --
19 initially, I acted as coordinator during a couple of 20 periods of time when Bruce was not on the job. I served 21 as the primary integrative writer of the repo_rt, bringing 22 together -- integrating the information that the experts 23 in their analysis provided. I was also the person who 24 would reintegrate the report subsequent to group meetings, 25 where we would discuss the report, item by item as,a team.
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' 1 A couple of introductory sections I was "the" writer of, 2 on my own hook. And beyond that, simply a general 3 questioner of contributions and of the analysis and 1
4 thought processes as we went through producing the report. .
5 DR. MARGULIES: I'm Newt Margulies, first name 6 is Newton; currently professor of management and the dean 7 in the Graduate School'of Management at the University of l 8 California, Irvine. I have been at Irvine for 14 years.
9 I have an undergraduate degree in civil engineering from j 10 Brooklyn Polytech, was involved early in my career in
, 11 bridge design, and had some relationship to the 12 construction of bridges and modification of bridges.
f 13 I have a master's in industrial management from MIT, k
14 and a Ph.D.'in organizational behavior ~from UCLA.
15 I have done extensive writing and publishing in .the 16 field of organizational behavior, specifically in 17 organizational development. It constitutes -- I'm sure 18 you can s'ee that in the resume -- but I have written some 5
19 five books on this subject, and over 40 articles. I have 20 done quite a bit of research on management behavior and in 4
21 general the field of organizational behavior.,_
22 In addition to my early work experience in civil i
23 engineering I was out of academia for two years, and 24 worked as an internal consultant at TRW systems in Redondo 25 Beach. It's a highly technical organization, as you know.
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20989.0 12 BRT 1 This is the aerospace installation in California. And, 2 from there, went to I,rvine.' -
3 While my major role right now is teaching and being a 4 university administrator, I have a fairly extensive 5 consulting practice. I work with a variety of 6 organizations, most of them rather large and complicated, 7 including TRW, Northrop Corporation, Rockwell and the like.
8 I think what I did on the project probably encompasses 9 three' major activities, although I really see this as an 10 integrated team report. I probably took more of a lead in, i
11 first, trying to conceptualize this, I think, very
.12 complicated phenomenon called " climate of intimidation."
,.. 13 I was very active in the data analysis.and'took a very 14 active role, also, in writing portions -- at least 15 drafting portions of the report.
16 MR. TREBY: Mr. Rice?
- 17 MR. RICE: My name is Charles Rice. I am 18 president of LRS Consultants. My experience primarily is 19 in the nuclear field. I have been in nuclear activities 20 for about 33 years; most of it in the project management 21 and construction, to some extent, and general,_ management 22 aspects. At the present time my company provides 23 consulting services in safety in nuclear analysis and 24 nuclear management to a dozen utilities or so with 25 operating plants, and also for about four utilities with
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20989.0 13 BRT 1 plants under construction.
2 I would have to say my primary expertise is in the 3 field of nuclear management. My contribution to the 4 report was in the area of the practical aspects of it. I 5 read the vast bulk of the depositions and did the initial 6 definition of the analysis of the -- of what the climate 7 of intimidation would be, and much of the practical 8 information in the analysis of that climate that occurs in 9 the middle part of the report.
10 I was involved in the analysis of the 1979 survey 11 information and did the initial integration into the first 12 draft of the report, pulling Dr. Margulies' information in,
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14 MR. TREBY: Okay. It's'the staff's hope that 15 with this brief introduction by each of the team members, 16 the parties now have a better idea of what roles each 17 played, and that may be helpful in their directing of 18 questions.
19 I guess at this time I would like to turn it over to 20 the parties. As I indicated earlier, I guess Mr. Roisman 21 will continue -- will begin, and continue this briefing 22 session.
t 23 MR. ROISMAN: I will sit over there.
24 (Discussion off the record.)
25 MR. ROISMAN: Mr. Kaplan, do I understand that e
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20989.0 14 BRT 1 you were also the chief contract officer for EG&G on this?
2 MR. KAPLAN: Chief contracting officer, I 3 believe that would be Carl Obenchain.
4 MR. ROISMAN: He's not around; is that right?
5 MR. TREBY: That's right. He's not here.
6 MR. ROISMAN: Let me put you on notice on the 7 record that I will want him here.
8 EXAMINATION 9 BY MR. ROISMAN:
10 Q Mr. Kaplan, what is it that you initially 11 understood was to be your goal in doing this report?
12 A (WITNESS KAPLAN) My goal in doing the report
, 13 was to advise the NRC on what their position should be 14 with regard to climate of intimidation.
15 0 And who was it that came up with wha't "a climate 16 of intimidation" meant? They or you or Mr. Obenchain?'
17 A No, the study team came up with the definition
- 18 of the climate of intimidation.
19 Q There is'a document in all of this mass of 20 materials which you all were so kind to provide us with, l
j 21 and then of course we have to read it; and that I want you 1
22 to take a look at. What I want you to take a look at, 23 this is a letter from Mr. Obenchain to Mr. Sims. And in 24 it he has, in the second paragraph, a description of what 25 I think is the working definition.. But I want you to take
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< 1 a look and make sure that we all have the same working 2 definition. Would you look at that?.
3 A Of the climate of intimidation? Second 4 paragraph --
5 Q Yes. Just take a look at that.
6 DR. MARGULIES: What's the date on that?
7 MR. KAPLAN: August 28.
8 It says, "The team established a working definition for 9 a climate of intimidation and then assessed the repo'ts, r 10 definitions, survey data and othar information available."
11 Findings -- you must be referring to that sentence?
12 MR. ROISMAN: I may have given you the wrong one, 13 too. Let me see -- ,
14 MR. TREBY: Let me ask another question here.
15 Should we mark each of these documents and attach them, do 16 you think?
17 MR. ROISMAN: No . - If you do that you take my 18 copies, so --
19 MR. TREBY: We have a Xerox outside, so we can 20 give them back to you immediately.
21 MR. ROISMAN: You can do that if you like; but I 22 don't need it, I see no need for it.
23 MR. TREBY: Do you have any views on the subject?
24 MR. WATKINS: Just the standard one that the i
25 transcript will make a lot more sense if you bind things i
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20989.0 16 BRT 1 in. Do you have extra copies here of the discovery 2 documents? -
3 MR. TREBY: I have a set of discovery documents, 4 but I would have to rummage through each time one is 5 pulled out. As I said, I have a Xerox machine available 6 and can immediately replace the copies, so I think it 7 might be easier.
8 MR. ROISMAN: If you want to,do that, that's all 9 right.
10 MR. WATKINS: If you just have the reporter mark 11 them and then at the end of the day perhaps we can have -
12 them Xeroxed.
13 MR. TREBY: Why don't we' do that,.because I 14 think the transcript will be more meaningful that way.
15 BY MR. ROISMAN:
16 Q When you developed the working definition that 17 you were going to use, what did you use as your touchstone?
18 In other words, how did you know what the definition ought 19 to be? Is this a commonly used term in organizational 20 management? You could go to a text, find it written up?
21 A (WITNESS KAPLAN) My understanding is that it is 22 not at all a commonly used term as far as climate of 23 intimidation. Others might want to comment on that, but 24 the definition was put before the group by Chuck Rice as a
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25 working definition to help us get started.
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20989.0 17 ERT 1 Q Maybe, Mr. Rice, you could tell us. What's the
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3 A (WITNESS RICE) The origin of the definition was 4 my concept of what " intimidation" was and then my concept 5 of what, in an organization, the atmosphere of 6 intimidation would be.
7 Q All right.
8 A What I did was put some ideas down on a piece of 9 paper -- and you've got a copy of that along with the rest 10 of the things -- and threw it out on the table. We 11 discussed it among the team and refined it-and wou'nd up 12 with that as the definition.
13 O Maybe you are the one I should be asking, then.
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14 This is a draft of a letter from Carl Obenchain to David 15 Bowers, and I believe in the relevant sections it is what 16 you all used as your working definition.
17 Looking at the fourth -- particularly the fourth 18 paragraph, teli me is that the working definition that 19 evolved in the team meetings?
20 A No. This doesn't really attack the question of 21 atmosphere of intimidation as it relates to our definition.
22 O Was what's said in that paragraph, is that an 23 incorrect statement of at least one of the concepts that 24 you all used?
25 A Can I read it out loud? Would that be all right?
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20989.0 18 BRT 1 O Yes. <
2 A ,
"The basic question you are to attempt to answer 3 is: Did management by its actions create an atmosphere of 4 intimidation for the QA/QC inspectors such that they 5 performed their duties in such a way that there's some 6 likelihood that the plant may be unsafe? This is distinct 7 from intimidation that some inspectors may have felt from 8 some actions on the.part of craft personnel. The intent 9 is to establish if a pattern of intimidation existed, as 10 opposed to whether certain individuals were intimidated.
11 There is also some distinction to be made-in terms of what 12 is a climate of intimidation compared to what'may be g3 13 described as a fairly hard-nosed management style in the 14 plant."
15 ' Most of these things were involved in the overall thing, 16 but our definition of " atmosphere" went into considerably 17 more detail than the one statement that really approaches 18 the climate question.
19 Q Are you saying everything in there is right but 20 it's not enough? Or are some of the things that are in 21 there incorrect, in terms of what you did? _
22 A No, I'm saying some of the things that are in 23 there are not part of the definition of climate of 24 intimidation that we used.
25 0 Which are the ones which %:re ultimately not s-W w
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1 part of it?
2 A All right. All the ones that refer specifically 3 to intimidation actions. Well -- I'll take that back.
4 Although not in line with the details of the definition, 5 I'd say that that probably is not an unreasonable overall 6 statement of what' we were looking at in terms of climate.
7 Q What you did in fact look at? You did, in fact 8 look at? "
9 A Yes.
10 Q Okay. How did you come up with the decision 11 that the craft interface with'the QA/QCC inspector would 12 not be part of the analysis?
13 A I don'.t believe thaIt we did. We assumed both 14 in fact we we're involved in craft management, assessment 15 of craft management and craftsmen themselves, to establish 16 whether we felt there was a climate.
17 A (WITNESS KApLAN) Also, the question we started 18 with was whether management created an atmosphere of 19 intimidation.
20 Q And that question originated at the NRC7 21 A Yes.
22 Q And, so you were not attempting to answer the 23 question was there an atmosphere of intimidation at the 24 site. You were attempting to answer the question: Did 25 management creato an atmosphere of intimidation at the
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1 site?
2 A I'm not sure -- tell me the distinction you are 3 trying to make.
4 O Well, one is were you looking for who did it and 5 the other is were you looking for whether it was there?
6 A I see your question.
7 Q And, as I understand it, what you are saying is 8 that your charge, your contract, if you will, was to find 9 out who done it, if it was there?
10 A My charge was to find out if there was a 11 management-created climate.
12 Q All right. Does that mean -- and I guess I 3 13' would really like all of you to answer it -- if there was 14 a "somebody else-created climate," given what you had to 15 do and what you were supposed to do and your substantial 16 time constraints in doing it --
17 A Yes.
18 Q -- that you wouldn't know the answer to that 19 question?
20 A (WITNESS RICE) I guess I we'lld have to say I 21 think we were -- at least from my own personal standpoint, 22 I was concerned with whether there was a climate of 23 intimidation no matter where it came from; whether it was l 24 caused by management, caused by craft or caused by the l
25 conflict that frequently exists between OA/QC and craft.
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20989.0 21 BRT 1 A (WITNESS KAPLAN) Bill, you might have something, 2 because Bill and I discussed the subject early on. I felt 3 that if there were a climate -- if crafts were 4 intimidating QA/QC inspectors, and management --
that the 5 management had some responsibility for that and what the 6 response to it was, and just the fact of its being there.
7 So, in that sense I didn't feel that by looking at --
that 8 management had created a climate that we were excluding 9 intimidation of QA/QC inspectors by crafts.
10 A (WITNESS MARGULIES) My view is overlapping, but 11 I think is more pointed.
12 A (WITNESS NAPLAN) Good.
13 A (WITNESS MARGULIES) I'm sure there are some 14 nuances here. I thought the charge, as I understood it, 15 was did there ever and does there currently exist a 16 climate of intimidation at Comanche Peak. And, secondly, 17 could we ascertain whether, either implicitly or 18 explicitly, actions on the part of the management helped 19 to create and sustain such a climate. I felt that that 20 was the charge. And I must -- I should also add, if you 21 don't mind, I also started out in my ndnd, clearly, that 22 the attention was on the QA/QC organization.
23 0 You mean to look for the consequences or 24 existence of the intimidation was in the --
25 A The concentration was in OA/QC as we started; 6
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20989.0 22 BRT 1 right. And in the report we did touch on some of the, I 2 think mediating f actors that emerged in our study. But I 3 think to start out with, that was the concentration.
4 Q And, Doctor, were you attempting to -- were you 5 attempting to find out whether others than management may 6 have been acting in a way which would have created the 7 impression, in QA/QC, that they were being intimidated?
8 A I think that might have been an emerging finding.
9 But I don't --
we did not start out with that as a study 10 question. l 11
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Q This draft letter that's in front of Mr. Rice, 12 that paragraph that he looked at, you'll notice that it 3
13 appears to exclude activities by craft. '
14 A Yes. Yes.
15 0 Was there a time when you understood that was to 16 be your goal? That is were you to exclude --
17 A There was a time initially that I thought the 18 concentration was on OA/QC.
19 O And how long did that last, in terms of the time 20 during which you were doing your work? When did that 21 begin to change? ._
22 A I think as we kind of became immersed in the 23 data and the information, and -- for example, the one -
24 thing'I think that you may be pointing to is that as it 25 became clearer that there is a difficult interface problem
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20989.0 23 ERT 1 between craft and QA/QCC, that that in fact is a conflict-2 full situation that may result in some feelings of 3 intimidation -- that emerged, I think, once we got into 4 the data. But I think at the beginning I didn't see that 5 as a question.
6 Q Did that look that you did, attempt to look 7 beyond intimidation into things that affected but weren't, 8 in your mind, intimidation as such?
9 MR. ROISMAN: Would you mark this 1 and this 2.
10 (Exhibits 1 and 2 identified.)
11 BY MR. ROISMAN:
12 ~Q Doctor, in terms of the idea of intimidation,
-) 13 when you started the deport what did you think was 14 intimidation? I don't mean intimidation in the nuclear 15 context or in the context of the contract, but what did 16 you think you ought to look for when you looked for that?
17 A (WITNESS MARGULIES) Okay. Let me make a couple 18 of distinctions, if I might.
19 O Okay.
20 A Because, while it was necessary to hone in on a 21 definition, for me and I think for the rest of this team, 22 the target always was climate of intimidation. So I need 23 to make that distinction as you kind of hone in.
24 What did I think about? I thought, first of all, I ,
25 would like to underline, I think, a question you raised e
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20989.0 24 BRT 1 earlier. In the organizational behavior literature and e <
t 2 literature on climate, there is very little, almost nil, 3 to help one conceptualize that idea; very little.
4 However, there is some information, for example in 5 literature on power, that one can build on. So what I had 6 in my mind was that there are a number of components that 7 comprise intimidation. Let's start with.';, hat first.
' ?
8 One is,the act or behavior on the part of one party; 9 the manner in which that act or behavior is perceived; and 10 the resulting consequences, what that person does.
l 11 However, an important part of that definition of
' 12 intimidation is that intimidation, to be explicit, has to 13 have attached to it a threat or the potential use of a 14 negative sanction like: "If you don't do such and such 15 you are fired." You know, that's a threat or negative j 16 sanction. Or: "You are not going to get rewarded," or 17 whatever. So we kind of started out with that as a notion 18 and began exploring the complexities of trying to make 19 that determination.
- 20 How would you know if somebody, for example, is simply 21 aggressive and that aggressive behavior is perceived on -
22 the part of the other party as intimidation, even though 23 it doesn't have this threat or negative sanction attached 24 to it? So trying to observe those things is important.
I 25 0 Let me just stop you for a second.
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l 20989.0 25 BRT 1 A Sure.
2 O You would draw the line, whether you were using 3 thd concept of intimidation, doing your work, between the 4 misperceived intimidation and the legitimately perceived 5 intimidation?
6 A Right.
7 Q So the guy who says: " Boy, did I feel 8 intimidated from what he did." And you sayi "Well, what 9 did he do?" And then you hear what he did and then you 10 say, "My God, he didn't threaten your job, didn't threaten 11 you with bodily, harm, it wasn't reasonable for you to have 12 felt that way, it's a perception that you have." For 13 example, if I reach across the table and pound on the k . ,,
14 table to make a point you might not feel intimidated at 15 all. But if I did it *for Stu, he might.
16 O Probably just the opposite.
17 A or just the opposite. But the point is, with 18 that piece of behavior, it's simply a matter of what's in 19 your mind and what triggers your feeling of being 20 intimidated.
21 However, if you look explicitly, I have never said 22 anything about threat. You may have felt threat, but I 23 have never explicitly said: "If you don't do this or you 24 don't comply, this is what happens next."
25 I was also giving the example, if I have to give a talk
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20989.0 26 BRT 1 before 350 people, I usually feel a little intimidated, 2 although they don't do very much. Right? It's all -- the 3 other part of it is I can be very gentle and tender and 4 tell you: Gee, Tony, if you really don't do the following 5 you are fired. And that's just as intimidating.
6 So it's a matter of the explicit communication in some 7 cases, and, in others when it's implicit, it's a matter of 8 the perception of the other party. So that was the first 9 real struggle with trying to conceptualize what's going on.
10 Now, the real question for us was: What's a climate of 11 intimidation? And that gets a little more tricky.
12 Because it's a matter of how extensive the perceptions or 13 feelings are among people in an organization that would
(" 14 lead one to say: Whew, there's a predominant climate here.
15 People are really feeling that there are many, many 16 attempts at using negative sanctions or threats to get 17 people to do certain things in this organization.
18 What we did, in trying to define that -- because that --
19 is to try to identify a number of indicators, descriptors, 20 that we thought, if we could find, would at least give us 21 some indication that such a climate existed. _ And those we 22 kind of identified as targets to help us look at the data.
23 Now I'm not sure I answered your question.
24 Q No, no, you did. Let me just make sure that I 25 understand exactly what you are saying. That, when you e
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20989.0 27 BRT 1 found a person who honestly believed they were intimidated 2 but whose description of the events which caused the 3 intimidation feeling projected to you -- indicated to you 4 something, that they shouldn't have felt intimidated, in 5 your analysis that was not marked down as a intimidation 6 event?
7 A I wouldn't put it quite that strongly. What I 8 would do is, I would not deny that people are feeling 9 intimidated.
10 I remember now the question that you originally asked --
11, yes, there was an additional target for us. And that is, 12 could you discern whether or not management was doing 13 explicit -- was employing explicit behaviors that would s.
14 lead to the creation and maintenance of this climate?
15 I guess that was the point I was trying to make. On 16 the implicit definition I can't govern -- I can't discern 17 from the data what goes on in people's heads; that is, 18 that the feeling of intimidation and the climate of 19 intimidation may largely be a selection process. Like, if 20 I just had a different set of people it wouldn't exist.
21 !!owever, if I could discern that management was using 22 explicit threats or negative sanctions, then I could say 23 something: Yes. Because the probability of that behavior 24 being interpreted as intimidating is very high.
25 Q So you were looking for the clearest signs --
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20989.0 28 BRT 1 A Right. Right.
'2 Q Did you feel that, given both the time 3 constraints and the data you were working with, that if 4 there were more subtle signs it would have been 5 substantially mora difficult to find them?
6 A I agree.
7 Q If you had been called in by the utility, gotten 8 a call from them, and they said: Doctor, we've got 9 nothing but time and money. And we want to know the 10 answer to the question "Is there a intimidation atmosphere 11 at this plant site"; how would you approach answering that 12 question differently than the way in which you did 13 approach answering the question as put to you through the
{m 14 NRC and the EG&G subcontract?
15 A I think the clearest -- you know, I would be 16 really stupid if I said anything else but really what you 17 do is you start out with what the phenomenon is you want 18 to study and from there you design specific data gathering 19 methods from specific relevant parties to begin making 20 that determination. And my quip at the beginning was we 21 work only with the data that we had., _
22 O If I understand what you looked at, you looked 23 at almost everything, and I assume you looked at the 24 direct testimony of Dr. Goldstein?
25 A Yes, sir.
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20989.0 29 BRT 1 Q Do you remember in there Dr. Goldstein laid out 2 how he would go about approaching an attempt to answer the 3 question?
4 A Yes, sir -- yes.
5 Q Is that pretty consistent with the way you would 6 go about doing it?
7 A Oh, yes. I think I wouldn't disagree with that.
8 He said, number 1, there is the, I think, the 9 credibility of external data gathering. And he also said 10 that he would be more careful about data gathering, 11 vis-a-vis either surveys or interviews or whatever, that 12 was pointed specifically to the data that you are l 13 interested in. ,In fact, I have that document here. I
- 14 don't disagree with that general approach.
15 Q How far -- I don't know, this may be a 16 quantitative --
i 17 A I'm hogging all the time here.
18 Q What?
19 A I'm hogging all the time.
20 Q Right. Quantitativeness may be impossible for 21 you to get, but can you give me some, idea, how far off 22 that ideal would you say the work product that you all 23 were able to produce here, with the limitations that were 24 built into it, how far off that ideal that Dr. Goldstein 25 described would you say this report was?
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20989.0 30 BRT 1 A I think -- actually I think, given the data that 2 we had, I have a relatively high level of confidence in 3 what we found. But I would also --
4 ,Q No. No. My question was how far off the ideal
)
5 was the data that you had, versus the data that you would 6 have had if you had been able to approach it the other way?
7 A Got you. That's hard.
8 A (WITNESS RICE) I think that's an impossible -
9 question to answer.
10 Q It's very difficult to answer?
11 -
A (WITNESS MARGULIES) It's not ideal. "How far 12 off" is tough.
13 Q There were no direct interviews you contacted?
14 You heard us do our number. I'm sure as scientists you 15 found that an offense process to try --
16 A (WITNESS RICE) I'll answer that question, yes.
17 Q Like the three blind mice looking for the needle?
18 A (WITNESS MARGULIES) I wouldn't use the word 19 " offence." I thought the whole thing was rather comical.
20 I'm just kidding.
21 Q I can tell you as a participant it.was neither 22 comical nor pleasant.
23 A --
in fact that's right. We didn't talk to 24 anybody. In fact, we were explicitly instructed not to 25 talk to anybody and that's for good reason, I'm sure. But, e
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4 20989.0 31 BRT 1 no -- there was no specific data gathering that we 2 designed. It was all things that existed.
3 Q Did you make any attempt to assess the truth or ,
. 4 veracity of statements made by people? Any effort to say 5 whether -- when somebody said that they were intimidated -- l 6 whether they were now telling the truth about that?
7 A What I did -- what I personally did, 8 particularly with the depositional data, is I made some 9 judgment about the relevance of the information -- of the
! 10 data.
- 11 Q Can you give me an example? There were a number i
- 12 of depositions in which the focus of some of the
. i 13 examination appeared to be to attack the credibility of -
l 14 the person who was speaking. Either the person's job 15 performance was brought into question or whether they had
['
16 been truthful at some earlier time.
17 A No, I didn't. I didn't do that. What I'm j 18 saying is if the deposition went off in the direction of
- 19 exploring a particular personnel procedure, and it was 1
20 nothing in there that was relevant to my making the I
! 21 determination around questions I was. interested in, I !
l 22 excluded it as being irrelevant information.
i i
i 23 0 You mean you skimmed it instead of sitting down 24 and taking detailed notes on it?
l 25 A I wouldn't say that. I would say I read it i
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20989.0 32 BRT 1 carefully and said no, this it not relevant to the 2 questions I had to answer. -
3 Q How about you, Mr. Rice? How did you deal with 4 the question of veracity? Did you accept all the 5 statements as honest statements by all the people?
6 A (WITNESS RICE) It would be impossible to do that, 7 because if you did you would go crazy because you'd get 8 one person saying this and one person saying the exact 9 opposite.
10 Q Right. _
11 A Where there was an opportunity because of 12 corroborating witnesses, several people involved in the
~, 13 incident indicated:
( Yes, that was what,had happened or, 14 no, that wasn't what had happened, I tended to make a 15 judgment on it that, yes, this would put a point on the 16 curve of a climate of intimidation.
17 Q or the opposite?
18 A or the opposite.
19 Q As the case may be. So you did attempt to make 20 some assessment?
21 A Where there was a suf ficient amount. of 22 infor.aation to do it; yes.
23 Q And Dr. Stratton, I was a little unclear as to 24 exactly what your role was -- sort of, when Mr. Kaplan was 25 away you were doing what he did? or whether you had a b
O
20989.0 33 BRT 1 role that got you more into the substance of the report?
2 A (WITNESS STRATTON) I would say my role is more a 3 coordinative, pulling together the pieces and making them 4 flow into one report. I looked at that as kind of a 5 technical role. Because whatever I produced went back in 6 th'e group, we had group meetings and went through it and 7 discussed things in detail and worked through it. So --
8 and I did not read all of the material. I read some of 9 the material. But, really, not a very large percentage of 10 the material. So I'd look at my role more as a 11 coordinator, facilitator, integrative writer and not --
12 Q As opposed to an evaluator?
13 A Yes.
(' i .
14 Q And I know, Mr. Kaplan, you said that was your 15 role as well?
16 A (WITNESS KAPLAN) I was an evaluator.
17 Q I'm sorry?
18 A I said I was an evaluator. Bill was making sure 19 that it flowed. I wanted to make sure that what they said, 20 even if it flowed, that it made sense to me and was 21 defensible.
=4*
22 Q So you did look at the underlying data?
23 A (WITNESS RICE) No, he's saying he was an 24 evaluator of us.
25 Q So basically, Mr. Rico and Dr. Margulies, were 9
0
20989.0 34 BRT 1 you responsible -- of the four of you who are here -- to 2 sort of look at the raw data? And the two of you were 3 responsible for seeing to it that when the raw data was i
4 turned into conclusions and findings they could make sense 5 out of it and that it was written in a report that was 6 understandable and met your contract obligations?
7 A (WITNESS MARGULIES) That's fair.
l l 8 O Mr. Rice, if you can remember -- let's take an
- 9 example. There was a fair amount of controversy with j 10 respect to an event involving Sue Ann Neumeyer -- '
11 A (WITNESS RICE) Several events.
l 12 O That's right. And the one particularly I'm
(- 13 thinking about is she had claimed one night whether she
- 14 was working on a night shift, she had been compelled 15 against her will to sign off some documents, liner plate 16 documents, that she did not want to sign off and that she l 17 complained and that they told her: You are going to do it 18 or you are going to work through the whole weekend, and it l 19 was a weekend, first three-day weekend they had and so l
l 20 foeth, and that she did it under great duress. I believe 21 Messrs. Woodyard and Blixt testified: "We didn't pressure 22 her at all. We didn't tell her she had to do it. We told 23 her what her job was and she proceeded to do it." And 24 then there was a Ms. Gregory, you remember, who testified 25 that she had heard at least one time when she believed S
20989.0 35 BRT 1 that, I think it was Mr. Woodyard was saying to 2 Ms. Neumeyer, "if you don't do it you are going to be in -
3 trouble."
4 Now, taking that incident, one, was that one of the 5 incidents that you looked at?
6 A Sure.
7 Q And did you draw any conclusions from what you 8 read,,as to whether Ms. Neumeyer was right, that Woodyard 9 and Blixt were telling her you have to do it, or whether 10 they were right that they didn't force her to do it, they 11 simply told her: this is the job, please do it, and she 12 proceeded to do it?
13 A Let me say, yes, that was a significant incident, ,
14 or appeared to be, at least. It certainly was significant 15 to Sue Ann.
16 Rather than try to draw conclusion from conflicting 17 testimony by different people, what I did was go back in 18 my mind to what was it she was really being asked to do?
19 And what she was being asked to do was take data from some 20 chits and initial off on a piece of paper that would 21 probably -- based on what I know about construction jobs 22 construction travelers and that sort of thing -- would 23 allow it to pass through the rest of the system and get so 24 that it is now turned over to the utility.
25 What I said to myself: If she was intimidated then she e
__~ -__ . _ . _ _ _ . _
20989.0 36 BRT .
1 just would have signed those of f and worried about her job 2 and so forth. Instead of that, what she did was asterisk 3 every place she signed off and put a note down at the 4 bottom that said she was signing these off in accor, dance 5 with the chits that were there.
6 My assessment of that was, if she felt comfortable in 7 signing that thing off and putting that asterisk there and 8 putting the note down at the bottom, she was not 9 intimidated by management. Because thtt would be 10 something that, presumably, management would not want her 11 to do because all she was doing was making a sign off.
12 So, if she had been afraid, or if management had been 13 really intimidating her, she would not have felt
- 14 comfortable with putting that note down on there. So the 15' assessment I came out with was: I couldn't see that as --
16 and this was one of the ones where there were 180-degree 17 differences between. In fact some of the them couldn't --
18 in fact either Blixt or Woodyard -- one of them --
19 couldn't remember the incident had occurred, it was such a 20 minor thing. And several of the people who worked with 21 her over that one night, because she,did it in one night, 22 as I recall, so she could get her three-day weekend, that 23 the people who worked with her that night really were not 24 in a position, either, to say that they recalled all this 25 information.
~ ~ ,-
20989.0 37 BRT 1 MR. TREBY: Can we take a minute break?
2 (Discussion off the record.) -
3 MR. KAPLAN: I guess I had one point of 4 clarification. You were trying to make a distinction 5 between the intimidating behavior and feelings of 6 intimidation. The working definition, the clarification I 7 wanted to make, is why we began with focusing on behavior 8 that might cause intimidation. We also added to our 9 definition a final bullet, a fifth bullet, which intended 10 to pick up just the feelings of intimidation. So we felt 11 like we had covered both.
12 BY MR. ROISMAN:
13 .Q Mr. Margulies, did you also have occasion to
~
14 look at the sue Ann Neumeyer event? Tell me, how did you
'15 deal with the question of the dif ferent testimony of what 16 happened?
17 A (WITNESS MARGULIES) I tried very hard not to 18 make judgments about who was right or who was wrong; 19 whether it happened or not. Seriously, I felt that was 20 the realm of the attorneys to sort that out and say it 21 happened or it didn't. , __
22 For me it was an incident that I recorded as a data 23 point. There was an incident, there was an alleger, there 24 was a, quote, intimidator" I tracked as as data. What 25 I tried to do was try to get a feel for the gestalt, a y
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9
20989.0 38 BRT 1 feel for what happened. I did not make judgments.
2 O In other words, did you take.Ms. Neumayer at 3 face value and say what she said happened, happened, and 4 what she felt she felt, and what she said these other 5 people did, they did?
6 A I took it as an incident as there were some 7 disagreements around the actual act. But I also took it ,
8 as a data point indicating there were some feelings as 9 being intimidated.
10 0 Did it qualify -- let's assume, for a moment, 11 that Ms. Neumeyer's version was the correct version, just 12 for the sake of discussion. Did that qualify as an event
, 13 that met the report's definition of " intimidation"?
14 A Well, whether she was right or wrong didn't 15 matter. What I wanted to see was overall, how many 16 incidents are surfacing like this? How many allegers are 17 there? How many people are identified in this 18 organization as "intimidators"?
19 So I was more interested in the whole process around 20 this notion. How many people are saying these things are 21 happening; how many people are identified as. creating them?
22 So I really tried very hard not to make a judgment about: '
23 Yes, it happened. No, it didn't.
24 0 I don't understand how you fit that into how I 25 had understood as your description of what you had dono.
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.-. . . ~ - . . . - l 20989.0 39 BRT .
1 Here you have an incident in which one person says "I 2 didn't do anything to intimidate this p.erson," and the 3 other person says: "Oh, yes, you did." You have to get --
4 to know whether you have a data point that is a person who 5 is either lying or a person who has misperceived an event 6 or whatever it is. You have to know or make some 7 judgments about who was right and'who was wrong. I'm 8 trying to understand how you factored this liner plate 9 incident into your process? -
10 A There are two kinds of behaviors that could lead 11 to this climate.
~
There could be explicit behaviors, where 12 people are very clearly threatened. or there could simply 13 be behavior that people perceive to be intimidating.
All 14 right? Regardless of what those behaviors are, the 15 climate can exist.
16 Let me say it again. There could be the more clear 17- situation, where behaviors are explicitly intimidating.
18 They have attached to them threats or some sort of use of 19 negative sanction. That's very clear.
20 There also could be behaviors that people perceive as 21 intimidating even though they don't have thrgats attached 22 to them. Right? In either case, what gets created is 23 this climate of intimidation. People feel intimidated, 24 they perceive intimidation in some way. I was more 25 interested in getting at that.
20989.0 40 BRT 1 So, in a sense I was less careful about discerning the 2 explicitness or implicitness of the intimidating behavior, 3 if you will, and more -- I was more interested in the 4 extent to which the general perception exists that people 5 feel intimidated.
6 Q But if I understand, going back to the working 7 definition --
8 A Right.
9 0 --
if, in this case Ms. Neumeyer said "I felt 10 intimidated, but there had been no threat of any 11 consequence that would occur to me; nobody said to me:
12 'You won't get the weekend, or you'll be demoted' or 13 whatev,er it was," then you would have discounted it e'ven 14 though she felt intimidated you would say her definition 15 of " intimidation" doesn't fit our definition of 16 intimidation, so she's not an example of intimidation; is 17 that true?
18 A (WITNESS KAPLAN) Can I take a shot at that?
19 It's registered as data, the fact that she cl' aims 20 intimidation, she felt intimidated, and it would just be 21 recorded as such. -
22 You know, in my work I commonly have to interview 23 people and I get many different versions. There's a 24 phrase we use: "We all attend the same different meeting 25 together." You knowh We expect that different people e
9 r- .-_- ._ ., ,_- - . - _ . , ,
209'89.0 41 BRT I have different perceptions. But, by talking to everybody 2 and gathering and just taking it as a perception, as their 3 view, as their version of what was going on, when you add 4 those up you start getting a feel, a perspective for the 5 situation.
6 That's what I heard Newt saying he was doing when he 7 just took his data. Just took a report, and didn't have 8 to judge whether in fact she was intimidated or not.
9 0 You had relatively few actual individuals who 10 had claims of intimidation that were contained in those 11 depositions or in the prefiled testimony.
12 Do I understand from what you are saying that that was 13 r.eally an important consideration in your evaluation of k/
14 whether you had a " pervasive atmosphere? It was that 15 there were only 10 and you are looking at a workforce of 16 literally thousands?
17 A (WITNESS MARGULIES) That's right. That was one 18 of the indicators.
19 A (WITNESS STRATTON) Of the five different kinds 20 of indicators that we came up within terms of a definition 21 of a climate, that simply talks to the first one: How 22 widespread was the pattern?
23 There are four other indicators as well that we looked 24 at in addition to that.
25 Q But your ultimate conclusions on the study about s-
- . - . . -. --. n . - . - . - - . - ..--,- . . - -
i 20989.0 42 BRT i
I 1 a climate of intimidation not existing, do I. understand 2 .that if there,had -- let's just assume for the moment that 3 the total number of people at that site over the course of 4 the five years, '79 to '84, whoever said that there was 5 any intimidation, was 10 --
l 6 A (WITNESS MARGULIES) Right.
! 7 Q -- that that alone would be sufficient for you 8 to conclude that there was not a climate of intimidation l 9 at the plant site?
10 A No.
11 O What is it, then? What are the other things --
12 A Indicators. Right.
13 A ,
(WITNESS KAPLAN) You might say why, too.
14 A (WITNESS STRATTON) These five indicators I don't l 15 think are independent in any one of them -- if you have a 16 lot of any one of them or if any one of them indicates, it 17 doesn't necessarily mean you have the climate.
18 Nor does the absence of any one of them necessarily l
19 mean that you don't have a climate of intimidation.
20 Q And what, in your judgment, was the weight that i 21 you gave to that first factor, based upon what you got in , ,,_
l i 22 the information that you looked at? Did it turn out that 23 that factor poir.ted toward or away from the existence of 24 the climate?
25 A (WITNESS STRATTON) You want me to answer that?
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20989.0 43 BRT 1 0, It doesn't matter.
. 2 A. Relying on the data, or the analysis that Chuck 3 and Newton provided, I looked at those numbers and -- as 4 very minor indicators of a very low level of -- that 5 raised a.very low level of concern on my part. And 6 there's other parts of the report explaining why we would 7 think that's a low number in relation to the number of 8 people, to the inherent conflict-full nature in some of 9 the relationships.
10 0 Were you looking at the data that you had in 11 front of you for the purpose of reaching your conclusions?
12 or were you at some point confirming, from the data that 13 you saw, conclusions that you preliminarily reached?
14 A (WITNESS MARGULIES) Well, I can say what I did.
15 I believe that I approached this as an organizational 16 scientist. I was extremely interested, and still am, in 17 this concept, because there's just nothing in the 18 literature. It's intriguing. And I asked some of my 19 colleagues: "Have you ever see'n anything in the 20 literature?" There's nothing.
21 So I really approached it from the point of view of the 22 scientist.
23 Would it be okay if I just said a method --
24 Q It's okay for you to say anything you want, or 25 to loosen your tie.
e
20989.0 44 BRT 1 A I don't want to go too far off what the question
,2 is. ,
3 Q No. No.
4 A In terms of methodology, I already said I'think 5 there were some limitations on the data that we had, but 6 nevertheless there was the data. I think it was kind of 7 an inductive process of looking at the data and trying to 8 make sense out of what was there. So, in that sense I 9 personally didn't have any preconclusions in mind. I was 10 just intrigued with trying to find out about this question.
11 The second thing that's important is that even though --
12 and I agreed with these indicators and I also -- I find 13 the. legal mind is somewhat different from, for example --
14 that's what I meant, Tony. I don' t want to go ' too far.
15 Q Listen, I get the same thing from Dr. Goldstein.
16 A The point I want to make is that you really have 17 to take the five indicators together as a kind of gestalt, 18 as a kind of system of data that talks to you, that speaks 19 to you. So it simply i's underlining Bill's point. Any 20 one of these by themselves give you some hints but you 21 have to look at all of it. . ...
22 For example, Newt, take that piece -- see, the 23 depositional data is very specific and very limited and 24 very pointed.
25 The survey data, on the other hand, is more global, is e
e
20989.0 45 BRT 1 mora inclusive, if you will. It covers more people. It
, 2 covers more of the kind of questions that the phenomena ,
3 really calls for.
4 So I felt that I was using, basically, a kind of 5 inductive process of really looking at the data and 6 exploring the questions without any preconclusion about 7 what I might discover.
8 0 Your contract, at least initfally, expected you ;
t 9 to get a final draft to the NRC by the 10th of August, 10 which was just at the conclusion of the deposition process. ;
11 Did you all make that? Were you all?
12 A (WITNESS RICE) No. That was supposed to be the 13 end of the deposition process, which it wasn't. ;
k_- !
14 Q When did you first -- get your first draft l t
, 15 conclusions together, roughly?
t 16 A My recollection is it was like -- and this was a 17 rough draft, was like the 6th, 7th, 8th -- someplace 18 around there, in August.
19 Q In August.
20 A It was not a draft for publication. That was a 21 draft for us to start shooting at internally._ ,
22 Q okay. Now, subsequent to that date there was 23 profiled testimony and then the hearings, formal hearings ,
i 24 started in September, the 9th or 10th, something like that.
25 And I noticed in your contracting documents and in some of 6
= -. - - _.. _. .. .-
20989.0 46 BRT 1 your bills that were submitted, that you all were working 2 still into the end of August and there are some hours and 3 days in September, not counting these days in November.
4 A (WITNESS MARGULIES) Yes.
5 Q Now, how did you integrate into your thinking 6 what you were picking up subsequently? Let's just take an 7 example: Corey Allen. He never existed, as far as the 8 data that you looked at, until he came as a board witness 9 and testified down in Fort Worth.
10 What was your process for dealing with those new pieces 11 of data that came in, one way or the other?
12 A (WITNESS RICE) Let me go back a step and then 13 get to there. The process of finalizing and formalizing 14 our conclusions basically began the 10th of August, and 15 probably concluded about two weeks later, the latter part 16 of August, 24th, 25th, 26th, someplace around in there.
17 The charge that we had from that point on, I don't even 18 know if this was formal, but this was the essence of it, 19 was: As you read the prefiled testimony and the trial --
20 or the hearing testimony, keep an open mind. And if this 21 affects the conclusions that you have arrived.at, be ready 22 to modify the conclusions of the report.
23 0 I take it those of you who are psychologists 24 understand that the chances that you will modify them once 25 you have reached them are less than they are that you will
/
9
.m_ _ ___ . -
20989.0 47 BRT 1 reach them dif ferently in the first instance if you 2 haven't read them out?
3 A I'm not even a psychologist and I'll admit to 4 that.
5 O Have you read everything now that has come out, 6 including the hearings that developed out at Fort Worth 7 and Whatever prefiled testimony is now around? or have 8 you changed the way you have been looking at data since 9 the time of the conclusion of the original report?
10 A I'll answer -- I think each one of us probably 11 has to answer that one. The answer is "No." I have read 12 as many as I could. I have read the 9th through the, I
. 13 think, the 12th. I have read most of the' prefiled
(~ 14 testimony from the NRC and from Case. And I guess that's 15 probably all. I have been up to my ears in other work, 16 basically, since completing the draft the latter part of 17 August. So I have -- I have read what I could When I 18 could, but I have not read all of it.
17 O And how about you, Dr. Margulies?
20 A (WITNESS MARGULIES) I have read all the 21 depositions at this point. I'm almost through all the 22 prefiled testimony.
23 0, When you say " depositions," are you using 24 reference to the stuff taken in Glen Rose as opposed to 25 the testimony that was taken in Fort Worth?
/
, e v #
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20989.0 48 BRT 1 A That's right.
2 Q All right. Go ahead., .
3 A And I haven't looked at the most recent passage 4 which included, actually that's just duplications, but I 5 haven't seen, for example, people's notes and other pieces 6 of information that other people were using. I haven't 7 seen all of that. But I have that complete package now as 8 well.
9 MR. WATKINS: I didn't catch -- prefiled 10 testimony --
11 DR. MARGULIES: I'm almost through with that.
12 BY MR. ROISMAN:
13 O 'How about the actual testimony in Fort Worth?
14 A I'm pretty sure I'm through all of that.
15 A (WITNESS RICE) In front of the Board?
16 Q When the Board were sitting and we were just --
17 the Board was through sitting and just the lawyers and 18 witnesses in the room?
19 A Yes. I'm pretty through with that.
20 Now, I'm on the data, I'm open about changing my mind 21 on certain things. Right now I can just tell you, though, 22 that while the numbers increase they don't change 23 proportionately. So there is some steady sort,of increase, 24 for example, in the number of allegers and the number of 25 people who identify. But proportionately it doesn't
-i
20989.0 49 BRT 1 change a hell of a lot. <
2 O When you say." proportionately," proportionately 3 to what?
4 A (WITNESS MARGULIES) Add 20 additional data 5 providers and I add allegers by one or two --
6 0 When you say " data providers," is that witnesses?
7 Is that a scientific term for witnesses?
- 8. A Ric at.
9 Q I finally caught somebody making something more 10 complicated than a lawyer?
11 A Yes. I just said how many people are providing 12 data and how many are allegers and how many intimidators t , 13 are identified in the incidents. That's the way I sort of
(, .
14 began sorting the information.
15 O Talk to me a little bit about what is the 16 pertinence of that, that combination of factors? What if 17 we had only one intimidator? Would that change --
18 A Sure.
19 Q What would it do?
20 A Sure. Then it becomes more an isolated 21 managerial problem versus a pervasive. climate.
22 O What if that one intimidator is at the top of 23 the chain of the people who are claiming to be intimidated?
24 Why should we beat around the bush: Ron Tolson, okay? He 25 is the site QA/QC manager for most of the years in
.=,
.. * - - . . ~
20989.0 50 BRT 1 question. He is labeled as being " intimidating."
2 Forget whether he meets your definition for a moment.
3 Ian't he a bigger number than Woodyard who is 4 substantially down the line?
5 A (WITNESS KAPLAN) Perhaps the answer is, all 6 things being equal, fewer intimidators would indicate less.
7 If it were higher in the chain, obviously that matters.
8 In what the person had done, if'they murdered somebody, it 9 wouldn't take as many, probably.
10 0 That's our premise also.
11 A (WITNESS RICE) Let me answer that in probably --
12 almost a totally different way. And.that is that an
()
13 intimidator, or whatever his ac.tivities may be, at a given 14 spot in the organization, does not really -- take Tolson 15 as the manager of QA/QC on the site. The influence that 16 he has on what happens at the QA/QC or at the QC inspector 17 level, and the supervisor, and the next line of 18 supervisors, doesn't necessarily fit at all.
19 I have seen it in organization after organization. A 20 guy at the top or very high in the organization may be one 21 kind of a manager that you would expect all kinds of good 22 things or all kinds of bad things from. And the 23 organization itself is an organization, if you will, and 24 it works the way it works.
25 That individual has very little influence as a specific
-5
20989.0 51 BRT 1 individual in a management spot. And I take that right up 2 the line to Clements, and I'd take it up to Fikar, and I'd 3 take it up to Spence, and right up the line.
4 O I couldn't quarrel with you about everybody 5 outside of Glen Rose. I think their impact on the plant 6 was very dubious. But let me ask you about, in the Tolson 7 eituation particularly: What was the universe of 8 potential "intimidatees," if I can coin that word for our 9 discussion? What did you understand was the universe, in 10 terms of numbers of potential intimidatees?
11 A If I would remember the numbers correctly it 12 would be -- oh, of intimidatees?
13- O Peop'le who could be intimidated. Not just as a 14 result of him?
15 A Let's make the assumption it was all of the 16 people in QA/QC, which as you recall was 120 or 130 or so 17 at one point in time.
9 18 A (WITNESS MARGULIES) Sure; that would sound right.
19 Q And your perception is that Tolson alone 20 couldn't be an effective intimidator of them?
21 A As a matter of fact --
22 A (WITNESS MARGULIES) That's what I was going to 23 say. If that's what the case or if anyone at that level 24 was really influential in creating this climate, and I say 25 that in quotes, I would see a lot of " incidents" going on
~
20989.0 52 BRT 1 through his agents.
2 O By " incidents" you mean people who work for him 3 doing something which then showed up?
4 A Right.
5 Q As a complaint not against Tolson but as a 6 complaint against some subordinate of Tolson's?
7 A Sure. It w'ould be my hypothesis that I would 8 see that.
9 Q How did you,.Dr. Margulies, how did you factor 10 in the learning theory, if you did at all? In other words, 11 how much credence do we give to Mr. Kaplan's somewhat 12 facetious, "Well, if there had been a murder - " if the (j 13 first person who spoke up about a safety factor at the 14 site had a severe and publicly-known reaction, how much 15 credence would you give to what the learning impact of 16 that was on the other workforce?
17 A I tried to point up that one of the vehicles for 18 creating this organizational climate which I do think is a 19 perceptual phenomena, is what I -- Bill took out -- what I 20 call the Chinese telephone game. You remember that?
l 21 Chuck tells me a messa'ge and we pass.it along.--
22 O Russian gossip. 'We had different enemies when I 23 was young.
24 A You remember that game -- so, obviously if he' 25 tells me something and I believe it, even though he's e
.,.,.-.a . - , - , - - -.w-. .
- 20989.0 53 BRT 1 distorted it and I pass it on, then an incident that
. 2 happened ~to him could in fact persuade me to believe
~
3 certain things about the organization and about the 4 management, even though nothing has ever happened to me 5 directly. And I think that happens. That happens in 6 organizations.
7 O Were you able to make any assessment on the 8 basis of the data that you had, as to whether that has or 9 has not happened here? .
10 A How extensive? I really couldn't make a 11 judgment like that. I would just say theoretically I 12 thought that that's obviously a reality in organizations.
13 That's how organizational cultures build up. But I really 14 would have trouble connecting a specific incident with 15 specific outcomes in that regard. But I think that 16 theoretically that's what happens.
17 But I want to say another thing because I think, if you 18 are referring to Dr. Goldstein's learning theory --
19 O Sure.
l 20 A -- there are some assumptions, I think, that one 21 needs to remember about positive and. negative.
, 22 reenforcement and positive and negative climates and 23 positive and negative morale, vis-a-vis organization l
l 24 behavior and productivity and quality, et cetera.
i 25 It doesn't necessarily mean that if we now have this h
I l . , _ . . . -
~
20989.0 54 BRT 1 low morale and this negative feeling about the management, 2 that we are necessarily going to perform badly.
3 In fact, the data, the studies on those kinds of 4 phenomena absolutely do not correlate. There are ,
5 instances where those kinds of phenomena do affect 6 performance negatively, and instances where they do not.
7 So it's a more complex matter.
8 O So you'd need to do a lot more work at this 9 plant. Newt wanted to know the answer to that questio,n?,
10 A A lot more specific information, I think.
11 Otherwise'it's still, right now, for me, too theoretical.
12 I couldn't guess about it, vis-a-vis Comanche Peak.
13 O Let me follow onto that with a question. .As you' 14 know --
15 A (WITNESS KAPLAN) If I could get a clarification?
16 Q Yes.
17 A It seemed to me, again, that this fifth bullet, 9
18 here, picked up a good part of what you are asking about 19 here -- the generalized concern on the part of employees.
20 This picks up the people who may not have been directly 21 intimidated but who may have heard about it through the Russian 22 gossip system. And we did I think have some strong and 23 very convincing data on that level.
24 Q From what source?
25 A Primarily I think the two surveys that we looked e.
20989.0 , 55 BRT 1 at.
2, O So, to the extent that the surveys were reliable 3 documents, that they gave you some data on that?
4 A Maybe -- you guys keep me out of trouble here --
,5 I have a little trouble with saying they have to be 6 reliable documents. For the purpose that we wanted to use 7 them I think they were, to the extent that they were 8 reliable indicators --
9 Q Well, let me give you an example of what I mean.
10 I notice in the report here there's some discussion about 11 the fact that the 1979 survey is done by people off the 12 plant site, and that gives us a certain plus.
13 A Right. .
b 14 Q But the people who did it who were off the plant 15 site were all employees of the company who were doing it 16 at the site. It wasn't like they had hired the four of 17 you to do it. It was Mr. Vega who did the plant audits, 18 you know, and other people who had an identification.
19 So that if you are evaluating the quality of the 20 responses you get on the '79 data, you have to have some 21 evaluation of whether it was a good enough survey to give 22 you reliable data or not; isn't that true? And that's a 23 question that, for instance -- well, I suspect -- and 24 correct me if I'm wrong -- that Dr. Bowers is the one who 25 did most of that work.
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20989.0 56 CRT 1 A (WITNESS MARGULIES) No.
, 2 A (WITNESS RICE) That was the 1983.
3 A (WITNESS MARGULIES) David looked at the '83 4 survey and Chuck and I did the --
5 A (WITNESS RICE) Even if that generated some very _
I 6 reliable data, the fact that the people took the '79 7 survey had been unable or unwilling to answer or make any 8 response to their management, a survey expert might say, 9 "Well, that's not a reliable survey,,but as far as the 10 survey team is concerned, it still provides some very l'1 interesting data for us -- just the fact that people were 12 not willing to answer it."
(
(j 13 0 Iq$asn't suggesting much to the contrary. I 14 think I too see some credibility in it. But I was trying 15 to distinguish between treating it as the ideal, or best 16 available data, versus whether it has any use at all.
17 I may have misunderstood what you were saying when you 18 indicated that you had some very strong data on your fifth 19 bullet, and that it was the surveys. That you were sort 20 of giving the Good Housekeeping Seal of Approval to the 21 quality of the surveys themselves. _. __
22 A No, I'm not trying to give the Good Housekeeping 23 approval to the surveys themselves. But there are some 24 conclusions that can be drawn from those surveys that I 25 think are strong.
e
~_
1 20989.0 57 :
BRT 1 Q There's a little bit of Catch-22 in there, isn't 2 there?
3 A That's what I was trying to --
4 0 Yes. On the one hand, if nobody was complaining 5 and the whole survey came back .with really a glowing ,
6 report on the company, then you wonder: is the 7 intimidation so great that they won't even say? So that 8 they looked like independent people? And on the other 9 hand if they complain and grou,se and say, "Well I'm really 10 not feeling that much support from my management," does 11 that say they are feeling comfortable in their position?
12 A This is one of the things you do. You take the 13 fact that one of the two bas.es for the survey'was being 14 done was complaints about pay and that sort of thing. And 15 you find the people perfectly willing to come out and say 16 things that are anti-management, if you will, in terms of 17 wanting more for themselves, and at the same time when 18 they are doing that, if they have other concerns it's 19 obvious that they are going to be equally willing to come 20 out with the other concerns.
21 Q Dr. Margulies, when you were looking at this 22 data, how did you deal with the issue of management, or 23 the expressed concern by a number -- I won't put a 24 qualitative value on it -- but a number of people that 25 their supervisors were not supportive of them? What is
20989.0 58 BRT 1 that -- if it's indicative of anything, what in your 2 judgment is it indicative of?
3 A (WITNESS MARGULIES) Let me think for a minute.
4 oh, one possibility -- I'm trying to think of what 5
correlates between that and what I_ heard --
6 A (WITNESS KAPLAN) Could you repeat the question, 7 Tony?
8 0 I wanted to get an understanding how 9 Dr. Margulies dea.it w.ith the expression by some. people 10 that their management, their supervisors, were not 11 supportive. And, as I understand it, in the report that's 12 sort of treated as a neutral, in terms of the report. I 13 wanted to understand better what it is indicative of, if -
(a) 14 anything?
15 A (WITNESS MARGULIES) What do you mean it was 16 treated as a neutral?
17 Q Well, as I understand --
18 A Oh, on the support question there were 99 19 individuals were split, 48 were positive, 51 were negative.
- 20 Right? So does that --
21 Q Let me just find the exact . --
l __
22 A (WITNESS RICE) Page 5 of 11.
23 A (WITNESS MARGULIES) That's the survey.
( 24 MR. TREBY: Maybe you could indicate what page?
25 A (WITNESS MARGULIES) I was looking at page 26, "5
i i
( .
__ _ _ _ ..__.~m - . _
20989.0 59 l BRT l
1 which is an analysis. On page 27, under analysis of !
2 questions 2-A, and 2-B, they were questions .specifically
)
3 about perceived supervisory support and quality of 4 supervision. I guess Tony was saying, if you saw a lack 5 of support, or at least people reporting a lack of support 6 on 5he part of supervision, what would that be indicative 7 of?
8 0 Yes. I take it you did not treat it as 9 indicative of intimidation?
10 A No. And I'll tell you'why.
11 O' Go ahead?
12 A one of the things I liked about the '79 survey --
13 let me back up a minute. The issue of survey construction 14 and David Bower is known -- that really is his specific 15 area of expertise. But the issue of survey construction 16 has more to do with a research interest of certain 17 phenomenon and whether the construction of the survey 18 actually allows you to measure accurately the phenomenon 19 you are interested in. From an organizational point of 20 view I think we can be a little less sophisticated about 21 the construction of the survey. What we want is just data 22 on how do people feel, perceive, et cetera. The advantage, 23 I think, of the '79 survey, at least the part of it that I 24 liked, is there were quite a number of simply open-ended 25 questions, where people can answer or not.
s ,,n- ee- m. o.-
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20989.0 60 BRT 1 Say, "Tell me what you see are the five key obstacles 2 to your performance."
3 A People can say, and they did, there are no 4 obstacles. Or they can say it's the cute waitress down 5 the block whom I keep thinking about and not concentrating 6 on mp work, or whatever they want to say.
7 What I like is, I was able to look at these sort of 8 open-ended responses to try to make sense out of it.
9 ,Now, the answer to the question is let's -- "I don't 10 feel my supervisor is very supportive of me." That's 1
11 because I went last week and asked if I can get a raise 12 and I got turned down or my performance appraisal didn't 13 turn out as good as I expected or I asked for two weeks .
14 vacation last month and he said no. There are a lot of 15 reasons. -
16 A (WITNESS RICE) Bigger office.
17 A (WITNESS MARGULIES) There are a lot of 18 speculations as to why I would receive not as high support 19 from my supervisor as I would like.
20 Now, what --
why would that -- what would happen, what 21 would really trigger -- if I saw a low respon_se on that, 22 what would really trigger it in relationship to the 23 que'stion of intimidation? Well, I try to cor. relate or 24 connect responses on that question with what they 25 qualitatively said were problems. And the issue of
.=,
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20989.0 61 BRT 1 intimidation did not come up.
2 As a matter of fact, you p.robably have my notes of the 3 category -- there is a category --
- 4 Q Which --
5 A What I did on the survey --
6 Q Are we looking at this?
7 A Yes, that's it. On my notes. I really tried, 8 first of all -- I now have the responses. I have a set of 9 notes that I used for categorizing the responses which I 10 think you all have.
11 Q And which sheet? Are you going to look at a 12 particular one? The one that's got "5" at the top?
13 A Yes. What I was searching for, if I can find it, 14 there was a category that had to do with --
15 Q Here, number 2, entitled " supervision support"?
16 A Yes. But what I'm trying to do is look 17 specifically for the piece of data that is related to, I 18 think, the question that you were raising, Tony. Let me 19 just kind of find it in a moment.
20 Here. I'm sorry, look at -- yes -- question number 5.
21 At the very bottom -- _
22 MR. ROISMAN: Let's have the reporter mark it.
23 (Exhibit 3 identified.)
24 DR. MARGULIES: There's a factor, fear factor -- by 25 the way, those are in my words. This is a laundry list I
~
. . _ , _ . , m. *.o..m-es- - - * ' * * * *
- 20989.0 62 BRT 1 took off the data and then in the end I tried to 2 categorize things --
3 BY MR. ROISMAN:
4 O These are words that appeared on the surveys and 5 you were looking at the raw surveys, not the summary of 6 the surveys?
7 A Yes, sir. You got it . So this is my kind of 8 taking the data right off the surveys and creating these 9 kinds of lists that I then try to make sense out of.
10 But, anyway the point I wanted to focus on is twofold.
11 Number 1, the connection to intimidation is I expected 12 to see more things that were like that, fear factor 13 prevalent, or things like that.
(-
14 So I would have a lot of trouble connecting low support 15 from my supervisor with intimidation. However, if you 16 look at the data, there's a lot of reasons that they did 17 mention that could very easily be hypotheses for that
- 18 connection: Lack of consistency - " goddamn it, I don't 19 get enough support from my supervisor. One day ~he tells 20 me to do this, the next day he tells me to do that" --
21 that would be a reason. . _
22 There's a lot in here, if you'll forgive me, and it's 23 not my data, right off the surveys. Unsophisticated 24 management has come up in a number of questions. You know?
25 Lack of feedback on job performance. The quality of
.=
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7- .
20989.0 63 BRT 1 supervision. All of those things, Tony, can result in a 2 , low rating o.n lack of support from my supervisor.
3 What I try to do is say: All right. Frankly, I 4 thought a 50/50 split wasn't too cool. I didn't think 5 that was very -- that's why I said later on in the report, 6 I don't think this site is without its management problems.
7 I didnt just make this up. But I really didn't find a 8 lot in the qualitative data, the fill in stuff that would 9 even imply intimidation.
10 Indeed, if you look at page number 5 --
11 O You mean the page that has that number, 5, at 12 the top?
13 .A Yes, sir. Look at " pay inequities." Boy, I t.
14 would really feel like my supervisor wasn't supporting me.
15 Q or you might feel like they were supporting you 16 on the pay and that upper management was turning it down; 17 right?
18 A Yes. Sure. Oh, by the way, the interesting --
19 0 What I'm saying is you don't'know whether the 20 high number of "I don't get much support from my 21 supervisor" is related to the pay inequity or_one of the 22 other problems?
23 A That's true but I got to tell you something.
24 Even if it's upper management that's turning down, if I'm 25 an employee, I don't give a shit about that. What I care
_ _ . . -_ , , - _ _ m .
20989.0 64 BRT 1 about is: You are my boss and how come I didn't get the
. 2 raise?
3 Hey, I tried. But you didn't try hard enough. Or 4 whatever. .
5 So it gets focal -- the focal point is my supervisor.
6 But there were some things about upper management that 7 they did say -- I'm having a little trouble finding it but '
8 there were some comments.
9 A (WITNESS RICE) That's under 2-A. l 10 A (WITNESS MARGULIES) Oh, it's 2-A. I felt okay 11 about the survey. I felt boy, people weren't bashful.
12 They weren't bashful. And I thought they would not use 13 the word " intimidation," they would use other words.' 'B.u t 14 I didn't see a lot that I could even -- and I was ,
15 interested --
even remotely connect and say: Wait, 16 there's something here. You just couldn't see it. !
17 Q You realized, didn't yod, that it was not their 18 words? The '79 survey doesn't represent the words of the 19 QA/QC inspector. It represent's the words of the people !
20 taking the interview. It was different from the written 21 comments on the '83 survey. ._ .
t 22 A That's right. That's right. I'm saying that's ,
23 kind of, you know, a problem.
24 A (WITNESS RICE) I wculd add in there that 25 question 4-C, which was "Do you sea excessive pressure t
4
. - - - - .--.-e
20989.0 65 CRT 1 from construction," was the one that probably had the
. 2 kinds of comments that you are referring to. .
3 O Maybe I'm just missing it. I don't see 4-C in 4 Dr. Margulies' notes.
5 A That's in mine, my notes.
6 A (WITNESS MARGUL1ES) That's what Chuck did -- we 7 had some overlap but he looked at one question I didn't 8 look at and so there was a slightly -- I did one that he 9 didn't --
10 0 Let me get yours out here for a second.
11 A (WITNESS RICE) I thin < the one is the summary 12 that shows the number down the left-hand side and then
( 13 " intimidating" ct "potentially intimidating," and "not 14 intimidating."
~
15 Q okey. These are divlded by each of you but the 16 tabs inbetween -- here we go. Here's " Rice." Is it this 17 sheet?
16 A No.
19 MR. HIRSCHHORN: Tony? It's this -- almost 20 illegible.
21 MR. ACISMAN: I was at the. start of_the pile --
22 okay. Here we go. Let's mark that 4.
23 (Exhibit 4 identified.)
24 BY MR. ROISMAN:
25 C Talk to me about this sheet now that we have it.
~ ' " -^ --
20989.0 66 BRT 1 What were you telling me about it?
2 A (WITNESS RICE) We did essentially the same thing 3 that Newt had done. We selected these seven items and l 4 said: These are items that may show us something with 5 respect to a climate of intimidation. Then we went 6 through each one of the questionnaires and categorized the 7 answers in the specific areas as no indication at all of 8 intimidation; the possibility of intimidation; and fairly 9 definite indication that the people felt intimidated. And 10 then we went back over them again and said: All right, if 11 somebody felt they were intimidated here it ought to show 12 up in some other -- some other area also. And ultimately
- 13 came down with the conclusion that there were some, as I 14 recall nine people, that fell in the category of feeling 15 that there were intimidating circumstances or definitely 16 indicated that they felt that they had been intimidated.
17 Q What were you ruling out? Were you ruling out 18 as intimidation the people who said that they felt 19 pressure from the craft?
20 A (WITNESS RICE) No. No. We included that.
21 O You included that in? ___
22 A Yes.
l 1
23 Q So what you are saying is there were only nine j l 24 people who indicated they were feeling pressure from the 1
l 25 craft in the 1979 surveys?
i l
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20989.0 67 BRT 1 A Ch, no. Not pressure -- not nine feeling 2 pressure in the craft. .
3 O Okay. I'm sorry.
4 A This was a total of nine people. If you add up 5 the other five that answered 1-D -- 2 -- in a way that 6 might have been considered intimidating, six potential on 7 item '2-A, and one that was more solidly intimidating, and 8 so forth. You'll notice that there wasn't a single one 9 that responded to item 2-C, which was " supervisors" -- let 10 me check and see what it is. How well do your 11 supervisors answer. your questions."
12 Nothing that came out of that indicated an intimidating 13 - sort of thing.
14 On question 2-B, which was "
supervisory support," we 15 came down to the conclusion that there was one potential 16 intimidating comment there but the rest were -- wherever 17 there was a comment the supervisory support was not in an 18 intimidating climate.
19 Q Are your notes such that you are able to go back 20 and identify which of the surveys and which of the answers 21 to questions represented the intimidating sta_tements?
22 A Yes.
23 O Okay, is that --
24 A And you got that.
25 O Is that here in your notes?
.. ...m,e. -e. , = ==,m ,.- - ~ + , .
20989.0 68 BRT
, 1 A That is there in the -- what I did was, because 2 for one thing I didn't anticipate that this was going to .
3 become the subject of this kind of thing so that 4 everything is not the neatest that one would anticipate it 5 would be --
6 Q You are not being graded on neatness or 7 originality.
8 A And what we did was run the first page of each 9 one of the'ones that we felt fell in the category of being 10 ' people that were potentially, or potentially had been 11 intimidated or felt some aspects of intimidation.
12 O What I'm really getting at is that at the 13 appropriate time you would be quite able to go back to, 14 with -- as long as you have the documents in front of you --
15 and say: Here's a statement that indicates to me, and 16 this is how come I put the little mark here on 1979 QA/QC 17 question sheet that we have been looking at. That's why I 18 put the mark under " potential intimidation" or " intimidating."
'19 A Ves.
20 Q All right. Now let's talk about pressure' from 21 craft to sign off, which is what I think was_usually meant 22 when they are talking about pressure from the craft.
23 Was that. intimidation? Just by itself? That happened, 24 a person who reports in the survey or otherwise and says:
25 The craft guy pressured me to sign off on it when I
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20989.0 69 BRT 1 thought I shouldn't?
2 A No. Not by our definition of intimidation. ,
3 Q What would have to have happened in addition to 4 that before that rises to intimidation?
5 A That either the individual inspector's 6 supervision or upper management at some level said "do it" 7 and he did it.
8 O And the part "and he did it" would be a crucial 9 factor, right?
10 A Yes.
11 Q I mean if you told him -- you gave Sue Ann 12 Neumeyer -- to you the fact that she didn't do it was
~ .
13 significant in evaluating whether she' wa's or not?
- 14 A Yes. Yes.
15 Q Dr. Margulies, what's your perception, in the 16 workplace environment, of what are the kinds of people who 17 come forward as Sue Ann Neumeyer did, versus the kind of 18 people who may have had the identical experience and don't 19 come forward at all? Are the ones that come forward 20 likely to be the stronger personalities?
21 A (WITNESS MARGULIES) They are likely to be more 22 economically secure. Hey, I'm going to do this because 23 it's okay. In the event something happens. So the people 24 who are likely not to may be more economically insecure.
25 That's one possibility.
G
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20989.0 70 BRT 1 O Yes.
2 A It's likely ,they are -- I would 1-ike to find a 3 different word for stronger personalities -- but tend to 4 be more self-asserted, self-assured, confident.
5 0 And probably.less likely to be intimidated?
6 A And probably less likely to be intimidated. And 7 also they might be people who are sociopaths who really 8 enjoy attention who like -- no, you know what I mean.
9 Q No. I understand. 9 10 A Hey, this was a big thing. I'm going to make a
- 11 big thing of it so I'll get a lot -- there.'s that shape of'
' l' 2 it as well. .
13 ,
So I think that there's a variety.
14 Q But it is the case, isn't it, that the people 15 who are most vulnerable to intimidation are probably the 16 least likely to say so?
17 A I think that's a reasonable statement.
18 O So that unless you can do the kind of analysis 19 that you and Dr. Goldstein talk about, you may not know 20 whether you have smoked them out or not? Whether you have 21 really found them? _
22 A I would agree. I think that's a reasonable 23 statement. The question is -- and this is a struggle for i
24 us at the very beginning. We understand the phenomena.
25 Are we confident that we have the "right data" to answer
- . _ - . . ~ _ _ . _ __ . .____ __. m_ ..
- ~
.20989.0 71 BRT -
1 the question. There are limitations given the data pool 2 we have to work with. I think that's true. So I think 3 what you are saying is a reasonable statement, from my 4 point of view.
5 Q All right . - If I understand the testimony or the 6 report -- not your testimony, but the report -- it is that 7 given the data you had before you, the conclusions that 8 you reached you are. confident are correct?
9 A Yes, I am.
10 0 What about the question -- but aside from the 11 limitation "given the data we had before us," starting 12 with you, Dr. Margulies, and going down the line.
(, 13 Mr. Rice, I'll let you* bat clean up.
- 14 With regrri to the generic question "does the Comanche 15 Peak plant sito form an atmosphere of intimidation at it?"
1
'6 Can you confidently answer --
17 A Wait. Say it again. Say it again.
18 O Is there an atmosphere of intimidation at the i
19 Comanche Peak plant now or was there at any time in the
{
20 five-year period from '79 now.
21 A Given the data? I'm sorry. Say it- again.
22 O Answer the question yes or no. In effect, what 23 I'm asking you is, did you have enough data to answer that 24 question or did you only have enough data to answer the 25 question: Given the data that we had, this is what the l
l
. I
20989.0 72 BRT 1 data showed?
2 A. The questionnaire information, while more 3 generally applicable to this investigation, was still not 4 focused enough to draw unequivocal conclusions. Okay?
5 Q You are reading now from --
6 A From our summary and conclusions.
7 Q Okay.
'8 A So the question is what's the level of 9 confidence. I think I would not say these things 10 unequivocally. No way. But I have a reasonable level of 11 confidence but I wouldn't say this unequivocally, given 12 the data, because ' chat's -- is that still avoiding? I'm
(, ,
13 not sure but --
14 Q Well, no. My understanding is that among the 15 scientific community there's a point at which you are 16 willing to say: I can give you an answer. And if you 17 define the question narrowly enough -- here the question 18 was: "Look at this data and tell me what does the data 19 tell you?" And I take it you had a number of options.
20 You could have said that it tells us that there was an 21 atmosphere, it tells us that there wasn't an. atmosphere.
22 But there's another question that could be asked, which is 23 Answer for me the matter in a general way. Is there an 24 atmosphere of harassment and intimidation at the Comanche 25 Peak site or was there in that five-year period? And here
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. .- . ~ - -. -
20989.0 73 BRT 1 is all the data you have to look at to answer that
,2 question. Now the question is a preliminary question: Do 3 I have enough data to answer the question at all? And 4 that's the question I'm asking you.
5 A okay. I'll try to answer that but I'm sorry, I 6 need to qualify.
7 Q Do.
8 A Because from a scientific point of view I can 9 only respond with a kind of level of confidence. It can't 10 be either/or. It can't be yes or no. But I'll try to 11 respond.
12 Q Okay.
13 '
~
A I think what I would say is, and first let me 14 deal with what I have. If you said to me: Given the data 15 that you have, what judgment would you make? And I know 16 we have gone around it but let me just one more t'ime 17 repeat it.
18 Q All right.
19 A Given the data I have, the pool of information 20 that I have available, I would say "no."
21 The next question is, if you were. allowed..to get 22 additional data, would your answer be the same? And then 23 I'd say I'm not sure. I don't know. I might come out 24 differently. But I couldn't say for sure I would come up 25 with the same conclusions if I was allowed to get other
'.~
20989.0 74 BRT 1 data. '
2 O So,,in other words, the data that's missing 3 might be important enough?
4 A Might be. Might be. Might be.
5 Q Okay. All right. Doctor --
6 A You know, it's hard.
7 Q In a way I had asked you this question at an 8 earlier time, when you were asked about qualitative and 9 quantitative and I said rank this data f,or me. , ,
10 A Yes.
11 Q And if I knew you had the 99 percent of all the 12 potential data and were missing 1 percent, you could make 13 one set of conclusions versus another set of da,ta knowing 14 you had 1 percent of the data and were missing 99.
15 Dr. Stratton, what do you think?
16 A (WITNESS STRATTON) I think what Dr. Margulies 17 said, I basically agree with what he said and the way he 9
18 said it.
19 0 okay. Mr. Kaplan?
20 A (WITNESS KAPLAN) I would agree also with what 21 Newt said and there is one thing -- given the- view we got 22 from this piece of data, would we want more? Do we think 23 it is implied or indicated? Would we suggest dropping 24 this?
25 0 okay. What would you say to that? I think
_,m .s y, a >w , . + ---g ------r--
20989.0 ,-' 75 BRT
~
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' 1 that's a good question. Answer it as th6 ugh -- let's take 2 the NRC.out of it because I think Dr. Goldstein answered 3 this question. Answer it in the context if you were
? - ,
4 advising management should they stop now or should they 5 look further.
~
6 A Okay. On f the things I would start with
,7 would be to consult my experts'here.
8 Q Okay. All right. .
9 A I certainly would strongly consider dropp.ing.
10 subject at this point. I think we have some very 11 convincing evidence to the side that there is not a 12 climate of intimidation. In fact, it wasn't a hard 13 judgment call. Itwasavery{strongindication. And 14 given that, I don't think I would, generally, advise my 15 client to dig deeper. '
16 Now, if we had some good conversation here and my 17 experts, I could be convinced otherwise.
18 Q Okay. Mr. Rice?. I think Mr. Kaplan has added .
19 another question which is a good one. I'll go back to the 20 two doctors, too. Why don't you answer both questions?
21 A (WITNESS RICE) I may answer a totally different 22 one.
23 Q Okay. Fair enough.
24 A I used to be a scientist, a lot of years ago.
25 I'm not any more. I am much more a practical practitioner l
--u.
20989.0 76 BRT 1 and evaluator of management.
2 If you -- and very few of the depositions contain the 3 word " intimidation," except where, in many cases, in 4 several cases pushed int,o it and kind of as an 5 afterthought.
6 There are many indications of harassment, intimidation 7 in the definition that we used for it, which was basically 8 that someone did not do something according to procedures 9 because of acts of management or supervision,or whatever.
10 Based on that definition there were very few that fell 11 in the category of even being credibly intimidated. I 12 come away from the bulk of this data feeling very, very
-'~~
13 strongly that there was not an atmosphere of intimidation.
14 There was an atmosphere.of, perhaps one might call it 15 archaic management that failed to recognize the needs of 16 today?s more participate management than used to be the 17 vogue. But I feel very comfortable with the statement 18 that I do not see an atmosphere or climate of intimidation 19 at Comanche Peak.
20 Q Before you answer the second question, can you 21 elaborate a little bit on the archaic management? What
- 22 exactly did you mean by that?
23 A There is a management style that almost all 24 utilities have had, that is extremely autocratic; is not 25 basically looking for feedback from people. You see Texas
20989.0 77 CRT 1 Utilities, in this case, struggling in' the period between '
' 84, to move in that direction.
2 '79 and '83 or It appears 3 that they are trying and I think they recognize the need 4 to move in that direction.
5 I see many evidences, even in the instances of the ,
6 Neumeyer and Darlene Steiner that management went out of 7 its way, even though it might have been misinterpreted, 8 but management went out of its way to not intimidate .
9 So my feeling is I'm very comfor, table with the 10 conclusion and I see little if any possibility that more 11 data would change my conclusion.
12 Q You suggested that the company is attempting to 13 move from.one management style to another. What's wrong 14 with the other style? What's wrong with the autocratic 15 style? Doesn't that make the trains run on time, so to 16 speak?
17 A It used to. '
It used to before the 60s.
18 Q What is its impact now? Why should management 19 care? They don't win the "we love our management award" 20 each year but by God the plant gets built.
21 A Well, back in 1949 or 1950, if somebody had 22 alleged something had gone wrong there, management fired 23 them. Period. There was no place to go to blow a whistle 1
24 and to raise this into the public eye. That no longer l 25 exists.
- c ** - anaw p , +y,e,-., y-,.- - - . , , , , , . , .
20989.0 78 BRT 1 A (WITNESS KAPLAN) I just want to interject one 2 thing. When we are talking on this level of management 3 style and archaic management and such, that we are ,
4 definitely getting beyond the scope of our study per se.
5 The fact that we have read the material and are familiar 6 with the case, we have some views and opinions on this, 7 but it was really not what we did our study on.
~
8 Q But it's what you chose not to do your study o.n.
9 So it's pertinent. You chose to exclude it. We might 10 differ as to whether it has anything to do with the issue.
11 A Whether it has 'anything to do with the climate -
12 of intimidation?
, 13 Q That's right. But it's important for me to 14 understand what you understood it was and why you thought 15 it didn' t matter as well as so that -- that's the reason I 16 want to know the answer to the question.
17 See, I don't accept your definition of intimidation. I 18 don't -think that's a definition that we are operating with.
- 19 And at some point here or when we are on the witness stand 20 we are going to find out how it came to be.
21 Are you going to tell us what your definit. ion of 22 intimidation was?
23 A Are you going to tell us what your definition of 24 intimidation was?
25 O Read in my proposed findings.
.=
+
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20989.0 79 BRT 1 A It's already there?
2 O Yes. Let me go back to the question I had for 3 Mr. Rice. Why should management care about this stylistic 4 difference? And I'm still not sure I understand.
5 A (WITNESS RICE) Why should management care?
6 Q Yes. Why should it matter? Why should it be 7 something you would want to change from? Why identify it 8 as a negative factor?
9 If I told you e,verybody came to the office in a suit, 10 we wouldn't automatically assume it was a negative factor.
11 It's just a fact. This office at one time was more toward 12 the autocratic side and now moving toward the other, but 13'
'{ why is it even anything to talk about? .Why does it matter?
14 That's what I'm asking you.
15 A I guess I'd say it matters because in today's 16 world, the requirement for all employees to have a greater 17 say in their destiny than existed back in prior days is 18 necessary for a number of reasons. It's necessary for 19 employee morale reasons. It is necessary for media and 20 public perception reasons. There are probably a lot more 21 than I could think of. Probably more. -.-
22 O What's the employee morale aspect? I take it 23 back in the '40s, if somebody had a problem they got fired, 24 that also had an impact on morale. Nobody gave a damn 25 about it?
'T
, = - -.
20989.0 80
, CRT 4
1 A I think the morale was good because they were 2 careful not to do things that got them fired. >
3 Q And why is morale a concern now? That's one of 4 these concerns that I think, doctor, you have on your
~
5 sheet on things that.the, employees identified. What is 6 the relevance of morale, the employee morale?
7 A There are several relevances of it. One of them, 8 if you have low morale on the part of employees, one of 9 the things .that's happened as a result of that is an ,
10 excessive turnover in employees, which means you have to 11 retrain and hire new people and so forth. -
12 Generally, and I know there's not complete agreement on
( ,, 13 this, but generally it has been my experience that with 14 high morale you get better productivity and -- better 15 quality of work out of people. So I'm interested in good +
16 morale. Any kind of an operation.
17 O So that a lower morale might actually produce a ,
18 poor quality inspection, for instance, by a QC inspector?
19 A Might develop a whole bunch of things.
20 0 But that is one of them; isn't it?
21 A I doubt it. I really do. I think-people are
- 22 interested in --
l 23 0 I'm sorry. I thought you just said it did?
i 24 A -- as long as people are there they are 25 interested in doing their job and doing their job right.
_5 i .
A d f
- -- -- - : _ - - - . . -~
20989.0 81 CRT 1 I think the bulk of people want to do a good job. And 2 even though they may bitch and moan about it and morale 3 may be low, they still may have their own personal pride 4 and want to do a job right and they do it.
5 Q So_yoy,r premise as you look at the question of 6 intimidation, which in your definition includes not only 7 that it occurred, that you felt it , but that it affected 8 your performance, you start with the assumption that 9 there's a tremendous back pressure against doing the' job 10 right? That the employee sta'rt with a lot of resistance 11 to that? :
12 A To doing the job wrong? That's right.
{ Do we h' ave -- I've not read every single
~
13 0 Okay.
14 piece of this material you were so kind to lay on us.
15 It's one of the prices that you pay for asking for it, is 16 that eventually you have to read it. Does the material 17 that we have from you tell us with whom you are currently 18 doing contracts? Your organization?
19 A Yes. I think it does. It -- on the -- I sent a 20 letter to Bruce after he asked me to -- if I was e
21 interested in participating in the study, and he didn't 22 know me and I didn't know him and he asked me for some 23 information. I sent him a letter that had attached to it 24 about six or seven pages of utilities and other 25 organizations that we were doing work with.
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8
. _.- :- -n . . . - . . . - . . . . ..
20989.0 82 BRT
)
1 Q Have you ever done a study of a utility, a 2 nuclear utility, when you.were not doing.it for the 3 nuclear utility? This area?
4 A Let me put it this way. I have done it for a 5 minoriyy owner of a plant under construction.
6 Q But --
7 A To see whether the -- what the majority owner 8 and project manager was doing.
9 Q Is this the first time you have done it for an 10 independent regulatory agency?
11 A Yes. .
12 O Even state ones?
(~ 13 A Yes. ,-
14 (Recess.)
15 BY MR. ROISMAN:
16 Q Mr.' Rice, you had been answering the first of 17 two questions. I think Mr. Kaplan had put on the table 18 the second one. Do you mind restating it again so I have 19 everybody answering as you phrased it because I thought 20 you phrased it well.
21 A (WITNESS KAPLAN) I'm not sure I remember it. It 22 had to do with, given the data that we have seen, would it 2.3 be necessary or advisable to go back and dig deeper to try 24 to get more data.
25 O That's right. What do you think about that, s-e
+. - .,,s - . , - , --- -~n -m - - - - . , , ,-
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l 20989.0 83 BRT l
1 Mr. Rice?
2 A (WITNESS RICE) I guess,my feeling is, I don't 3 believe it's necessary.
4 Q All right. Dr. Margulies, Dr. Stratton, you 5 didn't get to answer that before. Why don't you answer 6 that second question that Mr. Kaplan --
7 A (WITNESS MARGULIES) Given the data?
8 Q Given what you do know, if management came to 9 ypu and said: Should we have you go and do the more 10 expansive investigation, would you recommend that we do it?
11 That we do it or,not? What would you say?
12 A (WITNESS KAPLAN) This is more expansive
(- 13 investigation of climate of intimidation?
14 Q Yes. Exactly.
15 A (WITNESS MARGULIES) My response, part A, is I am 16 confident that with this pool of data I think the 17 conclusions flowed pretty well and I feel pretty confident 18 about it. But from, if you will , from an objective 17 scientific point of view, to be honest, I would -- if 20 management asked me to come in, I'd say: Well, I think 21 there are some things I would sort of like to explore.
22 Very simple. I wouldn't make a big deal about it. But I 23 thought the '79 surveys were very good. What if it was 24 done on an anonymous basis? I would like to see whether 25 it would change the responses.
-?
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20989.0 84 BRT 1 So, I think I'd suggest making some slight 2 modifications in the data collection.
3 Q I guess the question really is t Do you see 4 anything in what you've already seen that makes you feel
.,_, 5 that, if you did the complete investigation, you might 6 find that there was more of a problem, or a problem --
7 A Well, I think my major motivation is, as a 8 scientist, I guess I would like to raise the level of 9 confidence. And that 's -- you know, I can't say there are 10 any triggers in here that make me think -- gee, maybe we 11 ought -- but I would just like to clean up the data.
12 Q Okay. Dr. Stratton?
I' 13 A (WITNESS STRATTON) I think, as a behavioral 14 scientist, looking at the data, we took what we had and I 15 think used it well. It's not ideal, and I think we made 16 several statements to that effect. And it would be 17 interesting -- I think it would be interesting.
18 For example, if you really want to find out about 19 climate of intimidation, design an instrument that really 20 looks at that specific factor and go after it. But I 21 don't feel like I'm on shaky ground with the-conclusions 22 we are able to draw.
23 O Based on the data that you have?
24 A Yes, based on that data and the different kinds 25 of data from different timeframes. You know, the gestalt --
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20989.0 85 BRT 1 I think is the term tha't Newt used -- the gestalt from 2 different data, different timeframes, kind of points 3 enough in the same direction to me that I feel confident 4 in the conclusion.
5 So I wouldn't say: Good, before I can really sign this, 6 we better go out and do something else.
7 Q I understand that. But what you've signed is a 8 statement with that important caveat: Based on the data
~
9 that we've got, this is what the data shows. And now the 10 que'stion I'm positing is: If management came to you and 11 , said look, if we have got any harassment or intimidation 12 problem on this site we have to know about it so we can 13 take care of it. We a,re really determined that that not 14 exist. You have looked at this subset of potential data 15 and you have reached some conclusion for us. Here are the 16 conclusions. Now tell us: Should we stop our look now?
- 17 A (WITNESS MARGULIES) I think the dilemma -- it's 18 an interesting question -- the dilemma that I think we 19 feeI, maybe a little bit more than Bruce or Chuck, is we 20 in fact live in two worlds. On the one hand we are 21 providing a consulting service. And on the other we are 22 also bound by the values of our profession. And I haven't 23 seen a study anywhere any time that was put together that 24 somebody wouldn't say: Hey, if you would have done such 25 and it could have been at least some increment better.
.*~
1
g h.Ah a4 mu me== 4w# A- - - + - - r *N N*M' 20989.0 86 BRT 1 I think, Bill, I would like to hear your response to 2 this, but I think part of our response, I know mine, is:
3 I think there's an increment better in the data collection.
4 So -- ,
5 Q What I'm asking you to look at is as the 6 consultant, not as the academic. Answer in the context:
7 Here -- we are assuming now your contractor is not the NRC, 8 but it's CPSES. And they just say to your We want to 9 know if there is a climate of harassment and intimidation 10 at the plant site. We have a cheap way of getting an
. 11 answer to that. We are going to give you this pile -- the 12 data already assembled, not exclusively for the purpose of 1
13 answe' ring this question. Go through it and tell what does 14 that data show. You go through that and you give them the 15 report we have here.
16 Then they say: Okay, now should we have you get the 17 rest of the data? Should we have you design the study 18 that we talked about and so forth, go out and gather that 19 data? Or do you feel that we can feel confident that the 20 harassment and intimidation does not exist at our plant 21 and we don't need to go get more data to confirm that?
22 And that's the question I'm asking you: What's your 23 advice to the CPSCS management if'they put that question 24 to you?
25 A (WITNESS STRATTON) I guess I would tell them
. - - - = -
20989.0 87 BRT 1 that that expenditure probably wouldn't be warranted.
2 Q And as I understand it, Doctor, I wasn't certain 3 but I thought you said you probably would tell them you 4 wou.ld think the expenditure is warranted; am I right?
5 A My curiosity -- I think I would do some things 6 differently. I don't -- I think the incremental time and 7 effort might be interesting. And it is primarily my
- 8. curiosity. But I think I would --
9 0 You would recommend it?
10 A (WITNESS MARGULIES) I would do something.
11 A Are you' saying you would look at other issues?
12 A (WITNESS STRATTON) For example, the '79 surveys, 13 if they were done anonymously and not recorded by a
('"]
14 recorder, I would just like to see if there were some 15 differences in what the response set looked like. I would 16 just like to see it'.
17 I wouldn't suggest a big massive redesign of the study, 18 but I would just -- my curiosity, I.think, would dictate 19 that I would suggest that.
20 Q Earlier we talked about Dr. Goldstein's 21 description of how you would go about answering the 22 question in the first instance. And I think that you said 23 that you would agree that, in general, he had described:
24 You go in, you try to identify the problem, you design a 25 study based on that. That would be more extensive than
'.~
88 20989.0 BRT 1 just in effect reasking the '79 survey --
2 A Absolutely.
3 0 -- but doing it with the anonymity protection in 4 there?
5 A Absolutely. Really under the best of conditions, 6 that's the way to conduct -- that's the way to conduct the 7 study. I mean really.
8 O In the work that was done here, Dr. Stratton, 9 how did you deal with something that is below the 10 definition of intimidation, as I gather you all used it in 11 the study, and just dealt with the factor of inhibitors 12 and facilitators? I take it we all understand that the 13 , goal was to have the QA/QC inspection force inspect the 14 plant to the specifications and report deviations. And 15 that the subset, before we get to anything quite as grand 16 as intimidation was: Was there an inhibition or was there 17 a facilitation of them carrying out that task?
18 Did you make any effort to form a judgment as to 19 whether you felt there were inhibitors or facilitators or 20 what on that issue?
21 A Okay. Me personally, since I didn'..t look at the 22 raw data, I'd say no, in the sense, other than maybe 23 asking questions of the other people as they wrote their 24 parts of it. But I personally didn't make that judgment.
25 O Okay. How about you, Dr. Margu11es?
e
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- _ _ - - _ . _ _ _ , _ _ _ _.______._.___7_*________[
20989.0 89 BRT 1 A (WITNESS MARGULIES) Please repeat the question.
2 O In looking at all this data, did you look to see 3 whether there were inhibitors and facilitators of the 4 conduct which was the ultimate bottom line? The conduct 5 being that the QC inspectors did their job, to put a 6, shorthand on it?
7 A I think some of that emerged from the data.
8 Q And what did you find? Did you find -- and did 9 you record that in the data here?
10 A Sure. If you look at the results of the '79 11 survey, for example --
12 Q Reference me to a page.
13 A Page 26.
14 0 okay.
15 A If you look, page 27, second paragraph from the 16 bottom, 11 categories emerged, et cetera, et cetera. One 17 of those items is " interface with craft." And that is a 18 very difficult working relationship.
19 Q Would you say that's an inhibitor?
20 A Sure. It's very difficult. It's one of those 21 sort of suppress points that got to work to get the job 22 done. Sure.
23 Q Not necessarily intimidation but an inhibitor?
24 A Absolutely right.
25 Q okay. I want to make sure that we distinguish
20989.0 90 BRT 1 that.
2 A Absolutely right.
3 Q What about the communication issue?
4 A Same. Same category.
5 Q It's an inhibitor?
6 A Ch, sure.
7 Q What were the facilitators that you found in the 8 data that you. looked at?
9 A I think I may have been specifically looking for 10 those kinds of things. ,
11 Q I'm sorry?
12
~
A I may have been specifically looking for those 13 kinds of things. But -- I don't have'that information in 14 front of me because I really tried to focus on what were 15 the things that were getting in the way, so I don't have a 16 list of positives, in that sense -- things 6 hat really 17 facilitate getting that job done.
18 Q Mr. Rice, you mentioned earlier that either the I7 neumeyer and the Darlene Steiner incidents, or -- one or 1
20 the other, that the management may have tried to do 21 something that might have been even misinterpreted by what 22 they did. And I wondered if you would elaborate on that a 23 little bit. Did you see in those incidents some apparent 24 effort on the part of management to be a facilitator of 25 the people doing their job right that may not -- it may
O 20989.0 91 BRT 1 not have worked but that they were trying?
2 A (WITNESS RICE) Yes. At least I felt that was 3 the case.
4 Q What was it?
5 A Let me give one of them. I'm not sure, even, 6 which one of the female names, it was Net' tie Gregory or 7 Linda Barnes or Sue Ann Neumeyer -- one of them who left ,
8 the plant, didn't come into work on Monday, didn't come 9 into work on Tuesday, talked to the QA/QC manager, one of 10 the supervisors, Grant or whatever, and he went out of his 11 way to say: I will meet you at such and such a place.
12 And they met at the courthouse or someplace in town, in 13 trying to tell her we are interested in your coming back
(_s .
14 to work and so forth, we don't want to terminate you and 15 so forth.
16 Do you remember which one of those it was?
17 Q No. I can't -- I don't remember. It wouldn't 18 have been Matty Gregory, I know. I don't think it was 19 Susie, either.
20 A But obviously -- and she confirmed that this had 21 occurred, went out of his way to try,and not. terminate her 22 because of not showing up.
23 In the area of facilitators, whether it always works 24 that way or not, I think Spence's memos, Clements' memos --
25 ones that wound up on bulletin boards that seem to raise 6 -_5
._ . _ __ . _ _ _ ~ _ .
20989.0 92 CRT 1 so much problem -- some of Vega's work in several areas, I :
2 saw as facilithting the coming together of craft and QA.
3 Q Did you agree with Dr. Goldstein, that the '
4 actions speak louder than words?
5 A I think that's generally true; yes.
6 Q Did you find in what you looked at, evidence 7 that the company went out of its way to publicize its 8 facilitator actions?
9 A The ones that occurred in ' 83, ,in the 8-point 10 program, I think were certainly ones that the company went 11 out of.its way to publicize.
12 O How about before that?
13 A I would have to say I don't recall much in the 14 way of data between '79 and '83. As a matter of fact, as 15 I recall the depositions, there wasn't an awful lot of 16 depositions that hit the timeframe between '79 and --
17 there were a few, but not an awful lot.
18 O Did you all get the data or. Chuck Atcheson? Do 19 you remember?
20 A Some of it.
21 A (WITNESS MARGULIES) Some of it; yes.
22 O Do you remember what you read? Did you read the 23 Department of Labor findings on Chuck? There was a 24 deposition --
25 A (WITNESS RICE) A deposition related to it, of
20989.0 93 ORT I his.'
2 Q . Were you aware that the Department of Labor had 3 found that he had been fired for "pretectural reasons" I 4 think was the words they used?
5 A (WITNESS MARGULIES) Yes.
) 6 A (WITNESS RICE) Right.
7 Q And that I take it as best you could tell from 8 the depositions was a fairly well-known event on the plant t-9 site? Atcheson was somewhat of a cause celebre and there 10 were a lot of investigations. -
11 What was your evaluation, Mr. Rice, of how the company 12 dealt with the Atcheson event in terms of giving the
(, -
13 workforce confidence that whatever had happened to Chuck,-
14 Atcheson was not policy and wasn't going to happen to them?
15 A (WITNESS RICE) I have no recollection one way or 16 the other on it.
17 Q Dr. Margulies, do you remember anything?
18 A (WITNESS MARGULIES) Gee, I don't remember 19 anything either, as a matter of fact.
20 Q Do you think the Atcheson event was viewed at 21 the plant site -- would you expect it was viewed at the 22 plant site, by the workforce, as a pretty big thing? I 23 mean something that a lot of people knew about it?
24 A (WITNESS RICE) The only thing I can say there is 25 the one, one investigation by o and I, which looked into
~ ~_~ _~~~___. - __ _
'~
20989.0 94 CRT I what kind of an impact the Atcheson thing had on 1 1
2 inspectors, as I recall that was the November 3rd report 3 that came out in which they had interviewed --
4 O OIA I think it was --
6 A (WITNESS RICE) They had interviewed something 7 like 76 inspectors, some former inspectors, and I believe 8 that there were a total of like three out of -- there were 9 four that said they had, some kind of an intimidating sort 10 of thing; three out of the four said what had happened to 11 them as a consequence of the Atcheson affair was that they 12 were more careful now in evaluating before they go to NCR.
( ,
13 One of them indicated a feeling of, in some way, of 14 intimidation.
15 As far as I can recall, that's the only offshoot of the 16 Atcheson thing except it showed up in a couple of 17 depositions.
18 BY MR. ROISMAN:
19 Q Is the kind of work that these QC inspectors do --
20 and, Mr. Rice, you are probably the best able of any of 21 the people here to answer this -- is- it the kind of work 22 in which their judgments are a big piece of their job? Or 23 are they dealing with something in which there isn't a 24 whole lot of room for judgment and you are just dealing 25 with very objective criteria?
. s-
20989.0 95 CRT 1 A The attempt is to make it as nonsubjective as
. 2 possible; make it a very objective -- it meets the 3 criteria or it doesn't meet the criteria.
4 Q How close did Comanche Peak get to that, in your 5 judgment? Or did you look at that?
6 A It's impossible to tell from what I looked at.
7 Q Would it, Dr. Margulies, would it affect the 8 impact of an inhibitor if the person was more susceptible 9 to dealing in a, way in which their subjectivity was 10 involved in doing their job as opposed to objectively 11 testing? Would a smaller inhibitor have a larger impact .
12 on a person whose job depended upon their subjective
{1 13 judgment than on a person whose job depended only on 14 objective criteria?
15' A (WITNESS MARGULIES) I think you lost me.
16 0 Well, if a person is asked to come in and do an 17 inspection and the inspections is asking the question ,
18 How many inches is it between these two pieces of pipe?
19 If it's 10 or more it's okay. If it's less than' 10 it 20 flunks. That's one kind of thing.
21 If he's asking a question: Are the two pipes too close 22 together? And when he goes to the criteria he doesn't 23 have a 10-inch number. He knows it's a range of numbers 24 and it depends upon a lot of other variables.
25 Which one is more vulnerable?
F I
=
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20989.0 BRT 96 ,
1 A' The more subjoctivity.
2 O 3
Is more vulnerable to the same inhibitor impacting on how they do their job?
4 A Sure.
5 O Mr. Kaplan, 6
I would like you to take a look at --
7 I finally found, ofter all that oaylier discussion with 8
the draft of this letter to David aowers a document ,
9 that's dated July 31, 1984, to Mr. Sims from Mr. Leach, transm,ittal of task team description and qualifi cations, 10 11 task schedule for Comanche Peak issues team .
Attached to it -- most of what 12 it is is the resumes of a number of the people who were on the team.
( t 13 I'll give it
{ 14 to you in a second unless you happen to have it there in front of you, but I'll just asp, the 15 reporter to mark it as Exhibit 5, if you would, pleaso.
16 17 (Exhibit 5 ideritified.)
BY MR. ROISMAN:
18 Q On the first page of the letter there's " Background 19 Task Team Description of Qualifications and TaokcSe h u de."
l 20 And the bottom of it says:
21 "The basic question the team must attempt 22 Now, to answer is - " and then theretc a paragraph .
my understanding is from what yod end 23 the other team members said, is that 24 that's not what was used as the working definition. Just 25 want so we are clear on the roccrd, I to find that out and I'm particularly interested in a-
._ _ ._..2=._ ..__. _ __. _ . _ . . m--
20989.0 97 BRT -
1 the exclusion of the craft pressure.
2 A (WITNESS KAPLAN) Okay. This is not what we have 3 referred to as our working definition.
4 0 Is that inaccurate?
5 A No. This is accurate.
6 Q That is accurate?
7 A Yes.
8 Q I guess what I don't understand -- if I may just 9 have it back for a second -- on this it says: "This is 10 distinct from whether certain individuals - I' underlined 11 --
"were in fact intimidated or from any in,timidation that 12 some inspector may have felt from actions on the part of 13 crafts personnel.'"
(
14 A Right. -
15 Q Now, what did you understand was to be the way I 16 in which the team dealt with a particular allegation? And 17 let's take the Messerly event; okay? You remember 18 Mr. Messerly said that he saw a craf ts foreman physically 17 abuse a QC inspector.
20 A (WITNESS RICE) He was 230 pounds and the 21 inspector was a short stocky guy. .._
22 Q Tears in his eye --
23 A That wasn't the grabber, that was the fist 24 shaker.
25 Q What was the team supposed to do when they found c
e m s
._._.4 -~- -
20989.0 98 ERT ~
1 this data from Messerly?
2 , fL (WITNESS KAPLAN) My question was, how did 3 management deal with that? Did they know it happened to i
4 begin with, and if they did know, how did they deal with 5 it? Did they encourage it? Did they condone it by not 6 doing anything? Did they take action that would be 7 appropriate to managers in creating a work environment for 8 people?
9 Q Is that what you did with it, Dr. Margulies?
10 A (WITNESS MARGULIES) We surfaced that interface 11 as being one of the inhibitors on the data. I still think 12 the initial focus as we understood Jt was concentrated on 13 the QC organization.
14 Q on the Oc organization's intimidation of its own 15 people?
16 A Right. That was my understanding of the charge.
17 Q Do you remember Mr. Messerly said there were a 18 lot of people around when this happened and it was a 19 rather open event. Is it --
20 A (WITNESS RICE) On the other hand, I don't recall 21 an,y substantiating depositions or testimony that confirmed 22 Mesnerly's accusation.
23 Q or attack it.
24 A Either way.
25 0 The person accused was not brought forward to e
V' m.. :._.. -
20989.0 ,
99 BRT 1 say it never happened either,' was he?
2 A I didntt see anything in the depositions that 3 supported or denied it; no.
4 0 Why would you have any question about it? Mr.
5 Messerly was under oath? The company didn't produce the 6 other person?
7 A I don't recall that he gave a name of the guy 8 intimidated or intimidating. I may be wrong. I read an 9 awful lot but I don't rememb,er a name.
10 Q Yes. He gave the name Robinson.
11 A He did give the.name?
12 Q Yes. But why -- I mean, why would you have any 13 doubt that Messerly, who testifiedIunder oath about an 14 event that he said a lot of people saw, would not have 15 been telling the truth?
i 16 A I wasn't implying that he wasn't.
17 0 But you just mentioned it. I'm very curious. I
. l 18 think it's very important to understand, if you will, 19 where you are coming from? What is it that would make you 20 make the statement you just mado about, that nobody came 21 forward to corroborato it, when I was asking the question l 22 hcw did you all factor this in?
l 23 A Well, because that's part of the way in which we 24 factored -- at loaot I did -- factored things in. Was 25 there corroborating evidenco? What was the credibility of c
t _ . -
20989.0 , 100 BRT 1 the individuals involved? And was there corroborating 2 evidence?
3 Q Did you look at whether the corroborator was 4 someone who had,a motivation to corroborate?
5 A Tried to factor that in, too; yes.
6 Q How did you read the first week of the hearings 7 themselves, when Messrs. Tolson and Vega were on the 8 witness' stand when we were back in Fort Worth in front of 9 the board? What did that do to your perception of their 10 truthfulness and veracity, in terms of evaluating their 11 earlier statements made during depositions? Let's focus 12 on the T-shirt incident as an example.
13 Well, let me help you through it; okay? Mr. Tolson's 14 testimony about whether there was or was not destructive 15 testing being done in the electrical building and what 16 impact, if any, that had on his decision or -- to want to 17 transfer people from the electrical building. ,
18 What did you glean from reading Mr. Tolson's testimony 19 as to his veracity?
l 20 A Let me put it this way. As far as Tolson is t
21 concerned, I consider he is one of the people-that I would, i
22 based on everything I see, place in the category of an l
23 intimidating personality. Whether he in fact intimidated 24 people or not was not our charge and I didn't really look 25 at it. But I can see, with him, that that would have been e
e
20989.0 101 BRT -
1 a potential.
2 The question of the destructive electrical inspection 3 is not very clear again, including testimony from the NRC 4 people that went in and found only one wire and it hadn't --
5 didn't have scraped on the end like it had been pulled out, 6 and so forth and so on.
7 The subsequent indication that Tolson had called the 8 ,
NRC the day before, which didn't come out to me, anyway, 9 until late in the testimony, I guess it's almost 10 impossib1$e to say anyone of the people that I read the 11 depositi,ons of were lying or not lying.
12 I took the approach that everybody was saying what they 13 perceived'to be the case, regardless of wheth'er -- whether 14 that was the actual case.
15 In my business, and I'm sure a lot of other people --
16 you have five people et a meeting and you ask five of them 17 to tell you what happened in the meeting and you'd think 18 all five of them were in a dif ferent meeting. So the 19 truth is in the eyes of the perceiver, and I used that as 20 my approach on all of them.
21 Q What does that mean? You had conflicting 22 testimony on a number of these incidents and you are 23 telling me that you couldn't tell who was right and who 24 was wrong? How did you reach any conclusions about it?
25 A okay. Our charge was not to decide whether s-
~
20989.0 102 BRT 1 somebody -- whether any particular individual had bee'n 2 intimidated or not. Our charge was to see whether there 3 was a climate of intimidation.
4 Q But part of that was to build the building with 5 the bricks, wasn't it? The particular brick was whether-6 or not a particular person was intimidated?
7 A Not a particular person. In this case, whether 8 there were a significant number of intimidatees or 9 intimidators.
10 Q Well, we keep coming back to that. I'm still 11 . unclear. Let's try that again.
12 I would like each of you to tell me that. We had, at 13 the time that you did your original draft of this report 14 when you reached your first set of conclusions, what we 15 can readily concede were a small number of actual 16 individuals who testified and said: I believed that I was 17 intimidated. And they include some people who said: But 18 I still did my job.
19 So, if you take your definition that they both had to 20 be intimidated, feel intimidated, not do their job, the 21 number is smaller than the 10. . . -
22 A That's right.
23 Q And the impression that I get whether -- because 24 we keep coming back to it -- is that that really drove the 25 engine here. That factor alone was the dominant?
'a
sfL 20989.0 103 BRT 1 A (WIThESS MARGULIES) That's a mistake. That's 2 the factor you keep-leaning on. .
3 O But when I get to a starting point one of you 4 keeps going back to the number. I want to understand it.
5 A Let me add, because what I wanted to say a 6 little while ago -- I think what you are saying is 7 accurate as far as it goes. That's one source of data.
8 I probably have said this sometime.this afternoon, or 9 someplace this morning, I don't even remember. I think 10 the depositional data is not a good source. The survey 11 data -- and I.really think, even with some of the 12 difficulties in the survey data, it's good data. It's
~'
13 good data. And the survey data is much more global, is 14 much more, I think, comprehensive in terms of what was 15 going on.
lo So, 1 : agree with you. I think if you just stick with 17 several incidences or a dozen or whatever they are, that's 9
18 not going to tell you the whole story. You have to take IF that in the context of the survey; in the, context of the 20 reports; and then try to see what emerges.
21 Q By " reports" you mean the OI or OIA.. reports?
22 ,
A (WITNESS RICE) Yes.
23 A (WITNESS MARGULIES) If we had nothing else, I'd 24 start wondering what we were saying. But it was a piece 25 of a picture. And I think what we tried to present was
.. =
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~ . .
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20989.0 104 BRT -
1 the overall picture. So I think it's not just the numbers.
2 A (WITNESS KAFLAN) I might point.out too, being a 3 piece in a picture is maybe a different metaphor from 4 being a brick in the foundation.
5 Newt has been arguing about a gestalt, an overall 6 impression, of which this is e factor. And that is 7 different than building an argument up piece by piece --
8 one piece doesn't fit then the rest falls. That's not the 9 case with -- in this type of thing you guys are the logic 10 experts. There's a deductive or inductive process.
11 0 So in your picture analogy we have more of a 12 Grant Wood than we do a Monet? And you are telling us 13 that you have more of a Monet than a Grant Wood? Is that
~.
14 fair?
15 A (WITNESS RICE) Not bad.
16 O You are saying the linea aren't that sharp and 17 they do tend to blur over one into the other. Okay. I 18 understand.
17 A You turn the whole numbers game around if you 20 change that definition. If you change it to harassment as i 21 opposed to intimidation. _
22 O Then you get.a different set of numbers?
?
23 A Yes.
24 A (WITNESS MARGULIES) Sure.
25 O How did you deal with the possible linkage that.
' ' *J . . . -- . .. .._ _ . _ , _ . . . - - _ . _
20989.0 105 BRT 1 takes place between the employees who felt that the craft 2 was pressuring them -- all right? For lack of -- I'm not 3 talking about Messerly, because that was a unique -- in 4 terms of testimony, ar.yway -- relatively unique event.
5 But just the ones who felt that when they tried to do 6 their job the craft people were around there and you, I'm 7 sure, saw the testimony that indicated that that's a 8 natural tension between the cop and the people on the beat 9 and everything -- all right.
10 So you have that as a phenomen6n. You have as an 11 additional phenomenon that there were a lot of people who 12 felt like their . supervisors weren't behind them, whether 13 it was over pay equity issues or whether it was "every 14 time I went to them and complained that the craft guy is r 15 breathing down my neck they said" -- well, whatever it is.
16 There's a possible linkage there between "the craft people 17 are doing the pressuring, the supervisors are sort of 18 playing laid back, and then you get a potential impact or 19 inhibitor." How did you factor that somewhat amorphous i
l 20 idea into your conclusions in this report?
21 A (WITNESS STRATTON) Didn't we have a_whole l
22 section dealing with that --
management response to l
23 intimidation?
24 O Are you using " management" and " supervisor"? i 25 A We mean from first level supervisors on up.
'T l . -.-._ -
20989.0 106 CRT 1 Q Because when you talked about Messerly you <
2 talked about management's response to the Messerly event.
3 But it was a supervisor, that is, a foreman, who was 4 alleged to be the perpetrator. I didn't notice whether 5 you meant by management, we start at the Grant, Tolson 6 level -- but you did not mean that then?
7 A The whole section 3213 basically deals with 8 nanagement's responses. I think what we tried to set out 9 early on, back in our definitional stuff, was that we 10 weren't looking to see if craft was in fact intimidating 11 people. But, .if they were, what was management's response?
12 Management being responsible for the aura in which the 13 people operate or setting up a system so that those two 14 kind of naturally antagonistic functions in fact are 15 performed adequately, or well.
16 O What did you do with -- let's take Darlene
. 17 Steiner, for instance? You remember Darlene Steiner said 18 that she was getting a lot of pressure from Grant and 19 Tolson, because she was going to testify and then 20 eventually did testify at the hearings. And they -- and 21 she said "they were calling me into their office and they 22 were -- you know, and I felt intimidated or pressured by 23 that." .
24 Their explanation of the identical event was that they 25 were caring. She was pregnant. They didn't want her to
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20989.0 107 BRT 1 get hurt -- and they meant " hurt" by being in a position 2 in the plant where she might slip and fall; they were 3 concerned about her health benefits so they called her 4 back every week and checked on that. They wanted to know 5 if her doctor said could she keep working or did she have 6 to start her maternity leave, et cetera, et cetera.
7 There you've got an employee who says: " Boy, I'm 8 getting an awful lot of management attention and it makes 9 me nervous." And the management is saying. "We are '
10 reaching out. with our hand to help."
11 How did you sort that out? Which was it?
12 A (WITNESS RICE) That's an interesting one. A 13 very interesting case. In fact the entire gamut of the 14 Darlene Steiner case is fascinating. I would like to have 15 had the opportunity to interview her. That would have -
16 been good. I would like to know what the real factor was 17 with respect to the two black" gals that she said were 18 going to beat her up. I would like to know what the 19 influence of her husband on forcing her, quote unquote, 20 according to somebody, to do it -- I would like to know --
21 I guess there was enough discussion in some of the areas 22 that supported a nonintimidation and other areas that i
23 supported the fact that she probably did feel intimidated.
24 I would like to know about the four moves in two days.
25 There were a whole bunch of things that would be fun too
.=
. ~.__ . ._ , _ - _ . - _. _~
20989.0 108 BRT 1 get into.
2 The. net effect of it was, I felt that, at best, 3 Comanche management had led Darlene Steiner to feel that 4 she was intimidated. I don't come down on the side that 5 she was -- that there was intent to intimidate.
6 Q Was intent a part of what you were looking at?
7 It wasn't, wasn't it? You all didn't add that additional 8 piece into your equation, did you?
9 A Sure. A climate --
10 0 Sure you did or sure you didn't?
11 A Sure we did.
12 Q Oh. Okay. -
13 A A climate of intimidation would include the 14 intent to intimidate.
15 A (WITNESS MARGULIES) One was the assessment of 16 the climate. The second question is, is there any 17 evidence that indicates that management by its actions 18 deliberately tried to create that -- explicitly tried to 19 create that.
20 A (WITNESS STRATTON) Or by inaction allowed it to 21 continue. That whole section we in fact went_into five 22 subsections and went into quite a lot of detail, looking 23 into what we felt could have been indications -- assuming 24 management is not going to come out and say: our goal 25 here, goal number 3 this week is to intimidate, we look 4
. _ , _ , _ , . . . . - . -. -w -
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20989.0 109 CRT 1 for indicators. And that's why that section kind of ended 2 up being elaborated into subsections.
3 0 What was the role that you assigned to -- I mean 4 you have a whole section that talks about management 5 response to intimidation allegations. You indicated that 6 intent was obviously a part. I take it the intent to 7 intimidate was part and the intent to do the right thing 8 was also part of your evaluation.
9 Now, you have management's witnesses there for you to 10 see what they said, and you used what they say as part of 11 making up your conclusions about management's response.
12 How did you decide whether management was telling the ,
13 truth? What if they weren't telling the truth? How does 14 that change your conclusiods? Dr. Margulies?
15 A (WITNESS MARGULIES) I just assumed that 16 everything I read I assumed was -- I took at. face value.
17 Because I didn't have a crystal ball.
18 O What if it wasn't so? Let me give you some "what -
19 ifs." What if the T-shirt incident actually was part of a 20 plan -- the T-shirt just happened to show up -- by Tolson 21 to drive tough electrical inspectors out of the safeguards 22 building and get some wimps in there so he could get that 23 building signed off and turned over and be done with it.
24 Which is one, at least, possible scenario of what all the 25 events were.
-- ...# .m+,em m. m..w.y. q%+cee.. . . w-- - * - . . , - , -
. _ _ _.e-- -. --. - - -
- 20989.0 110 CRT 1 A (WITNE55 RICE) Are you implying that the eight 2 that showed up at his office were the ones that he wanted 3 to get out?
4 O No.
5 A All right, that's --
6 0 What I really think happened was the eight were --
7 there is a scientific name for that. They were the 8 confounding factor. How the hell did they end up --
9 Tolson had a neat plan for getting six guys, only three of 10 whom were in the eight, the hell out -- under our theory 11 you understand -- to get them the hell out of that 12 building, and somewhere else. And if I were to tell you 13 what I thi,nk really happened, what I think really happened k/ 14 was when they walked into the office he saw some of those 15 guys and he was so angry he forgot that they weren't all 16 there; so that the T-shirt incident was just sort of a 17 glitch in an otherwise planned -- telephone calls to the 18 NRC and so forth -- effort to get these gups out. +
19 Let's assume that Tolson's version about that wasn't a 20 true one, he wasn't telling the truth about what he really 21 had in mind. That there really was this plan; just that 22 one alone. Remembering now that it happened in 1984, six 23 months into the eight-point program, what do you conclude?
24 Does that change your mind? Is it an important blip in
, 25 the data, if that turned out to have been the other way?
.=
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20989.0 111 BRT 1 Dr. Margulies?
2 A (WITNESS MARGULIES) I don't think it would be an 3 insignificant piece of data.
4 Q Would it color your other perceptions? Let's S look at the management response aspect of the report.
6 MR. TREBY: Wait. I haven't objected to any cf 7 the questions, but I'm not sure how productive it is. You 8 could ask them about any factor. "
If this changed, would 9 it affect this?" Where is it going to get you?
10 MR. ROISMAN: If I could tell you that Tolson 11 had personally murdered three inspectors, it would change 12 his perspective.
13 MR.. RICE: That's intimidation. '
14 MR. ROISMAN: I'm talking about a change in the 15 facts that's been represented to the board, proposed by us.
16 These people are saying they took everything at face value.
17 If you don't get the answer to this question, then all we 18 have to do is change one fact-finding from what was said '
19 on its face and then we don't know what value the report
! 20 is. So I'm trying to rank it.
i l
21 BY MR. ROISMAN:
22 O Tell me, is this a biggie or a little one?
23 A (WITNESS MARGULIES) What you are telling me is 24 you are changing my data.
25 0 You have conflicting data on this.
.=,
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20989.0 112 BRT 1 A (WITNESS RICE) There was conflicting data on 2 almost everything.
3 A (WITNESS MARGULIES) What I'm saying is this is 4 okay. But if you are saying this is the " truth" you
'5 change the data.
6 Q I'm trying to find out how important is it.
7 Change the data that the Messerly incident happened on a 8 Thursday instead of a Tuesday, you'd say "Yes, it changes 9 the data, but it doesn't change anything?"
10 A Yes. It's probably a 1 or 2 on a scale of 10.
11 That would probably be --
12 O What is this on a scale of 107 13 A (WITNESS RICE) Before we put this on a scale let ,
14 me make sure we are talking about the same thing.
15 O Okay.
16 A On Monday of that week, as I recall, or maybe it 17 was Tuesday, most of the electrical QC inspectors wore the 18 nitpicking T-shirts into 'the plant.
- 19 On the day in question, which I think was a Thursday --
20 I'm not positive of that --
21 Q You are right. Thursday.
22 A But, again, the whole bunch of theh[,17 of them 23 or whatever it was, or most of that 17 --
24 O More than eight did.
25 A -- wore the T-shirt and put shirts on over them,
.=
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20989.0 113 BRT
- 1. changed shirts and so forth and so on, as I understand the 2 situation. s To assume that a Machiavellian scheme by a 3 manager to select six people out of that organization to 4 get them transferred out, and to get the involvement which 5 it would have required, on the part of Clements and -- who 6 is the project manager? What was his name? That he went 7 to -- Merrit?
8 Q Merrit?
9 A That he went to his office to call -- I think is 10 a pretty far-fetched scheme.
11 O We call it "the T-shirt incident," but the 12 T-shirts were sort of irrelevant. The scheme I'm talking 13 about is whether there had been a plan afoot to get the
-/ 14 six people, only three of whom were in the eight that 15 showed up in his office, transferred out of the electrical 16 QC function that they were performing in the safeguards 17 building, and that the T-shirt incident just happened to 18 superimpose itself by the weirdest coinciden,ce on the day -
19 on which they made the management change from Bennetson to 20 Mark Welsh.
21 And my thing is, even if the T-shirt incident hadn't
'~
22 happened, even if that had never occurred, the management 23 position is that the people who eventually got transferred 24 out of the safeguards building into another building got 25 transferred there for reasons that were completely benign
-7
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20989.0 114 CRT 1 and had nothing to do with either discouraging QC 2 inspection or anything else. I think that's a clear story 3 that they told and the T-shirt incident just sort of plops 4 into the middle of that; and not everybody who wore the 5 T-shirts got transferred and not everybody who got 6 transferred wore the T-shirts, and so you've got some 7 explanation for that.
8 'I'm asking you to posit that the transfer of those six 9 people who headed the safeguards electrical task --
10 electrical QC task force, postconstruction task force, 11 that transfer was done by Tolson because Tolson was being 12 responsive to the concerns of craft that these guys were 13 finding too many problems and slowing up production.
~
14 If that were the truth rather than what Tolson says was 15 what was going on, how does that rank on your scale of 1 16 to 107 17 A (WITNESS MARGULIES) The only thing I would say 18 is if you change my data configuration -- not you, I mean -- -
19 Q Yes. Right.
20 A -- then I don't feel in any way that I'm j 21 absolutely wedded to the conclusions in this report.
22 You change the data set I want to look as objectively 23 as I can and see what emerged from that.
24 O But how do you deal with the data where it is l'
25 inconsistent data? It's part of your data. Now all I'm l
-7
20989.0 115 BRT .
1 doing is positing that some of the inconsistent data was 2 wrong and the other was right. Didn't you have to do that 3 to reach some conclusions? '
4 A Yes. And I argue that I tried to look at 5 everything I had, rather than nitpick.
6 A (WITNESS RICE) To use a terrible expression.
7 Q Good for you. You learned your lessons at Glen 8 Rose very well.
9 A (WITNESS MARGULIES) I try to look at the whole 10 thing -- oh good, Darlene Steiner, she says this, they 11 said that -- fine. I treated it as an incident.
12 O But what did you do with the safeguards building 13 thing? I.mean there's a lot of testimony, and very little 14 of it really dealt with the T-shirts except, I guess, to 15 the extent that it was testing the credibility of some 16 conclusions.
17 MR. TREBY: May I have your name, please?
18 MR. LANDERS: I'm Jim Landers of the Dallas '
19 Morning News.
20 MR. TREBY: I just wanted to note that this is a 21 briefing of the parties by these witnesses. This is not 22 evidence in the case. And, while NRC proceedings are open, 23 to the extent that you are here, you are certainly welcome.
24 But you should recognize that this is not evidence of !
l 25 record. It's just a briefing to the parties.
l l
'T
{ _
20989.0 116 BRT 1 MR. ROISMAN': For instance, no one is under oath.
2 You came in after it started. This is a convenience that 3 it's being transcribed. This is not a deposition. %
4 MR. LANDERS: Thank you.
5 MR. TREBY: You should know that.
6 BY MR. ROISMAN:
7 Q How did you decide, when you were doing your job --
8 you had a lot of stuff on the T-shirt incident. How did 9 you decide what it was that that incident exemplified?
10 A (WITNESS MARGULIES) I never tried to gauge ~the 11 sort of magnitude or impact of a single incident. I 12 couldn't gauge it.
13 O Put aside its magnitude. How did you decide
('
14 'what the incident was?
~
What do you think -- forget what 15 you think.
16 In this report, what was your conclusion about the 17 T-shirt incident as you used it for making your 18 conclusions in this report? '
19 A I treated it as an incident. I tracked it --
20 '
O An incident of what? What happened? What did 21 you treat it as?
22 A As an incident contributing to the climate.
23 It's something that contributed to the climate -- one of X 24 number.
25 O When you say "the T-shirt" do you mean the
~~~:
1
20989.0 117 BRT 1 actual incident of the eight people, sending them home,
- 2 searching their --
3 A (WITNESS RICE) Going through their desks --
4 Q What about the surrounding stuff? The whole 5 question of the postconstruction verification task force, 6 electrical inspectors in the QC building? Did you 7 consider that?
8 A (WITNESS MARGULIE'S) I don't remember dealing 9 with that explicitly. I can't remember.
10 A (WITNESS RICE) I have a comment. I don't recall 11 it coming out prior to the time we wrote the report.
12 O That's right; but as I understand it you are up 13 to date now?
14 A Yes.
15 O It came out in Fort Worth. It came out in the 16 hearings, not in the depositions. You are correct, 17 Mr. Rice.
18 A (WITNESS MARGULIES) It's not processed. -
19 MR. TREBY: I don't mean to interrupt you again, 20 but let me indicate it is approximately three hours. We 21 took three breaks; that totals about 20 minutes or so, so 22 in fairness I'll give you another 20 minutes [ But I think 23 I ought to wind up at this point.
24 MR. ROISMAN:
I assumed it would have been 5:00 25 and that would have accommodated their opening statements l
20989.0 118 BRT 1 and the breaks .
- 2 BY MR. ROISMAN: -
3 Q Dr. Margulies, you are the one, at least of the 4 four here, who has been doing the major work in reading 5 everything, even the things that came out af"ter you got 6 your report together. Mr. Rice, you said that you have 7 been able to look at some but not all of it. And I gather 8 Mr. Kaplan and Dr. Stratton, you are not looking at the 9 raw data particularly anyway.
10 A (WITNESS STRATTON) That's correct.
11 O Dr. Margulies, describe to me your process.
12 What exactly do you do? Here lands on your desk this 13 morning from Stuart Treby, five more 300-page transcripts.
'- 14 What do you do?
15 A (WITNESS MARGULIES) Okay. Let me use a 16 deposition as an example.
17 Q A deposition or transcripts? I don't want to 18 use a term of art that you don't understand, but I want -
19 the report to be clear. Deposition is what took place in 20 Glen Rose. Transcript is what took place in Fort Worth.
21 A Right.
~
22 Q So what I want to do is use depositions as an 23 example?
24 A okay.
25 0 I'd rather that you use transcripts because
. ~ . . - . _ ..
~
20989.0 119 BRT 1 those are the ones I'm interested in. You have got the 2 transcript of September the 10th.
3 A The problem is I don't know -- I don't know 4 specifically, I can't recall -- I haven't read it all, so 5 I don't know what to use as an example.
6 Q Well, Mr. Tolson, for example, testified at 7 length about the T-shirt incident; his telephone calls to 8 his management, Mr. Cleraents ; the decision to make some 9 transfers from the safeguards building; the events of the 10 week in which the T-shirt incident occurred; whether he 11 did or did not know about the other people wearing the 12 T-shirts on Monday; what he did and why he did it on the 13 Thursday; an'B his eventual decision to be transferred from
~~'
14 this position that took' place on the Thursday as well.
15 Just think about that. That spanned a couple of days.
16 What are the mechanics of what you are doing with that 17 information?
18 A It's easier for me to describe first what I do- '
19 with the depositional data, because I just want you to 20 understand the mechanics of it.
21 Q But the question I want to know is: Exactly 22 what you have done with the other data? It's not 23 hypothetical, but go ahead and answer it as you feel 24 comfortable.
25 A What I do with the qualitative data is first of e
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20989.0 120 BRT 1 all I'm going to read it to see if it has any relevance 2 around the questions I'm concerned with, okay?
3 And basically there are three questions; okay? One is:
4 What's the nature of the management behavior that I might 5 classify as intimidating? That is, has the manager or 6 supervisor done anything explicitly that I would label.as 7 " intimidating"? Are there threats, negative sanctions, et 8 cetera? Or is there something in the manager's behavior 9 that may be implicitly interpreted as intimidating? So 10 I'm going to be looking for that.
11 Second,'I want to know what the perception is of the 12 person who is on the receiving end.
13 And thirdly, I want to know if there's any information 14 thit helps me determine whether or not the performance on 15 the job was, in fact, affected. So those are the things 16 I'm going to look for.
17 Now, what I would do is I'm going to read -- I read the 18- material. The first judgment, the first cut is, I want to '
19 decide whether the information presented is relevant to 20 any of those questions. And I have had material where 21 I've decided that there is nothing in here that's relevant.
22 It doesn't lend any insight or any addition or any 23 modification to data I already have. It's talking about 24 something entirely different. I will discard that.
25 If it is relevant, if it does shed some light on any of
~5
. - _ . , - -~. -
20989.0 121 BRT 1 those questions, I will make note exactly Which of those l 2 questions the information seems to reflect on, and what 3 has happened.
4 And then that gets processed into my sense of the 5 extent to which that information adds to the overall sense 6 of climate of intimidation, as I see it, around the three 7 questions. That's how I process the data.
8 Q Are you recording the new things in notes the ,
9 way I had recorded the other ones?
10 A That's why I have trouble -- that's right.
11 'That's why I have trouble answering specifically, because 12 I have been reading the transcripts but I haven't gotten 13 to the point of sorting out what that data is. There are.
( ..
14 times --
15 Q Is that something which you still it. tend to do?
16 A Yes; that's right.
17 0 or not?
18 A Yes. '
19 Q Okay.
20 A But I'm saying I can't -- what I really have to 21 do is read through several times to get a feel for what's i 22 there, even Whether it is relevant. So I'm more <
23 comfortable saying explicitly how I handled the 24 depositional data. I'm more comfortable -- that's a 25 completed process. But the new stuff, I'm still kind of T
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20989.0 ., 122 BRT 1 sorting, so I have a' lot of trouble being more explicit 2 about what I would do with it. But I'm going to look for 3 those kinds of indicators to see whether it changes the 4 conclusions.
5 Q Have you read the proposed findings of the 6 parties in the proceeding?
7 A No.
8 O Have any of you gentlemen read the proposed 9 findings?
10 A (WITNESS RICE) I have read some of them.
11 Q Dr. Stratton?
12 A (WITNESS STRATTON) Not yet.
13 O Mr. Kaplan?
14 A (WITNESS KAPLAN) No.
15 A (WITNESS RICE) I think I read 185 of yours and --
16 oh, skimmed perhaps is a better word, NRC's -- maybe half.
17 I have them with me, as a matter of fact. I just haven't 18 gotten around to it --
the utilities.
19 MR. WATKINS: What about the utilities?
20 MR. ROISMAN: He hasn't read them yet. He's 21 saving the best for the last.
22 MR. WATKINS: Oh.
23 BY MR. ROISMAN:
24 O Well, within the confines of this nonintimidating 25 atmocphere, I strongly urge you to read them all, only
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20989.0 123 CRT 1 because at l' east they will tell you what we -- all think 2 all of this may mean.
3 A (WITNESS MARGULIES) Sure.
4 A (WITNESS RICE) I know you asked this question of 5 Newt, but in this whole T-shirt incident, I was -- at 6 first I was very, very surprised at the extent of 7 que.stioning and so forth that proceeded, not only from the 8 lawyers but from the board itself.
9 When you tie the whole thing together, you've got the 10 transfer question, and there are a lot of open questions 11 on it.
12 Welsh moved into the job that day. Was it Bennettson 13 that he replaced -- was it Bennettson? I think he was the w -
14 one that put together the list that Welsh was now 15 responeible for processing up the line Vega's testimony 16 with respect to the investigation that he went into 17 afterwards.
18 I guess my feeling was pretty much called out by some 19 of the early testimony of Vega in that regard, which was 20 that he felt it was an overreaction on the part of 21 management to the situation.
22 This was modified, in my mind at least, in part, when 23 the -- I still feel that it was an overreaction, but the 24 destructive test situation, I have not -- I haven't got a 25 clear picture in my mind as to whether destructive testing e
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20989.0 .
124 BRT 1 had or had not been occurring.
2 It has occurred at other sites. It is not a unique 3 situation, of people destructively testing, especially as 4 you get toward the tag end of one of these projects.
5 So I -- I think what I'm saying is I really support 6 what Newt was saying, except from a different standpoint --
7 from one that says there are a whole bunch of variables in 8 this thing and it is virtually impossible to pull that out 9 and say: This is a fact here or it is a fact there.
10 Q My question was, because you realize the board ,
11 will have to sort that out, it will have to reach a 12 conclusion, so it's not irrelevant to know what role, 13 depending upon how the event is ultimately decided -- that
~.
14 is how -- whe're the " truth" lies, as to what its 15 implications are for the work that you are doing. Every
- i 16 party has a different theory about it and they are urging l 17 the board to come to some conclusion about it . ' I 18 I think that it's fair to say that the event is l r
19 legitimately rather pivotal, because Lt La fresh, 20 relatively new, less than a year old; it involves a post 21 eight-point. program activity; it involves management 22 response -- you have a chance to test that part of your 23 theory; it involves employee perceptionr it has had 24 visibility at the plant cite, covered in the press -- all l 25 that sort of stuff; and some of the major actors in the e
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20989.0 125 ERT 1, allegations of intimidation were directly involved in it, 2 like Tolson and Vega and Grant somewhere on the edges --
3 so a lot of your pieces.
4 I think that's why it has gotten all the attention it 5 has got, and that's why I was asking you: What does it do 6 to you if you assume our theory of it as opposed to 7 somebody else's and how have you dealt with it? And I 8 gather what you are telling me, doctor, is you have 9 haven't reached the point yet of dealing with that. You 10 have read it, you have some familiarity with it, and 11 that's a yet-to-be-done step by you?
12 A (WITNESS MARGULIES) Right.
13 Q Hays kny of the four of you had any >
14 communications from anybody who has any connection with 15 the utility or the NRC staff with regard to the study, ,
16 other than the people who were disclosed in these papers?
17 I know you have talked to some staff people -- at all?
18 A (WITNESS RICE) I have not.
19 A. (WL'rNERS MARGULIES) No.
20 A (WITNESS STRATTON) (Shakes head) 21 MR. ROISMAN: Let the record show that each 22 person one way or another indicated "no."
23 BY MR. ROISMAN:
24 Q I know you had some discussion with the 25 regulatory staff. When you met with the regulatory staff g o"~'
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20989.0 126 BRT 1 before you came to do the job, did they give you any sense 2 of what their or anybody else's theory of the case was?
3 Did you get any sense of what is the npture of the issue 4 in the case?
5 A (WITNESS MARGULIES) I haven't had any contact at 6 all.
7 0 okay. Mr. Kaplan, you might be the one who 8 would have been most likely to have contact?
9 A (WITNESS KAPLAN) I understand the --
10 0 Did you find out whether you were answering the 11 right question?
12 A I don't know how those equate. I thought I 13 understood what you were asking until you said that.
14 0 Well, if the parties' theories of the case are 15 all such that the question you are answering is not a 16 question that anybody cares about, then there's $100,000 17 down the tubes. So my question was: Did somebody tell
- 18 you what the theories of the parties were about this piece t
19 of the case, to enable you to make sure you were asking 2G the right question? '
21 A (WITNESS KAPLAN) I don't think I knew what ,
22 people's theories were. I understood that they had 23 defined " intimidation," that they were working with the 24 definition of what " intimidation" was.
25 0 Who gave you that?
/
200.99.0 127 ERT 1 A irom Ippoikto?
2 A (WITNESS RICE) And Stu Treby.
3 A (WITNESS KAPLAN) And Stu was there'.
4 Q Is that the do#inition that emerges ire the 5 report?
6 A We elaborated on that.
7 Q But it is consistent with that defittition? /
8 A Yes. Q3 yec. And that was one vay we knew we 9 wers on target. We spent a long time that day talking, to 10 get to the point of knowing that what they wanted was a 11 climate of intimidation which was a pattern of that kind 12 of behavior, rather than for us to assess individual 13 events end make a decisien if they were intimidatgd-or not, 14 So I'd say the answer is, "No,"
15 Bill, were you there too, and Chuck was there? I'm not 16 aware of having gotten anybody':s theory of the case, 17 A (WITNESS RICE) It was pretty much "Here's the i 18 charge. Here's the definition of intimidation. Go do it."
- 19 Q How did you all, whea you.did your colloquial 20 work, how did you resolve your disagreements? For 21 instance, I know that Mr. Rice added another question out 22 of the '79 survey that you felt was relevant and 23 Dr. Margulies did not. When you finally got down to the 24 final thing, did'you work on a consensus? How did you 25 decide what to do with the disagreements?
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20989.0 128 BRT l
1 A Well, we didn't -- Newt's analysis of the '79 2 survey begins on page 25, begins at the bottom of page 25. '
3 It runs through page, the top paragraph on page 28. I 4 My analysis begins on the second paragraph on page 28 5 and goes to where the two studies are summarized on page 6 29 as having basically independently, because we didn't 7 talk about which questions he was going to take and which 8 questions I was going to take or anything else, until we 9 had actually done the analysis.
10 0 And then, l's that where you, Dr. Stratton, and 11 Mr. Kaplan, that's where you took over? When these pieces 12 showed up from the others you started to integrate that 13 together into' a comprehensive report?
k.s 14 A (WITNESS STRATTON) I got the pieces and then put 15 them into this form. But it's basically using their --
16 using what they sent me to write this report.
17 Q Who did the first draft that contained in it the 18 ultimate conclusions about whether there was or was not a '
19 climate of intimidation at the site? Who first penned RO that part of the report?
21 A (WITNESS RICE) I think I probably did.
.22 O You think that was in your work. So your work 23 included not only the piece that dealt with the '79 24 surveys but making some of the overall conclusions? Or 25 the draf t of the overall conclusions?
m em. = * " ' * * ' "
- 20989.0 129 BRT 1 A Yes.
2 Q And what was the process of that? Did you all 3 come to a meeting, hash it out --
4 A (WITNE'SS MARGULIES) Yes. It was hard.
5 "
0 -- and then say, okay, you have heard what we 6 all said" and then say " Rice, you write this part; Kaplan, 7 you write this part - " or did you all come to each 8 . meeting with drafts of the different pieces and discuss it?
9 A (W'ITNESS MARGULIES) In the early going we 10 structured the task. In fact, the first meeting was 11 really kind of going over the definition and thrashing 12 that around.
13 0 A meeting before you would start.looking at data, 14 you mean?
15 A Oh, yes. Well -- no. We'd start doing some, 16 and some people had already had the data, and people were ,
17 looking, so there was some of that information available.
18 And it was really coming together to thrash out the '
19 definition and to structure the task.
20 Q Okay. But I'm talking about when you get down 21 to the report language --
22 A Right.
23 0 -- at some point you must have gone back and 24 started looking at the data, and then drawing from the i
25 data you were looking at your own conclusions based upon 1
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20989.0 130 CRT 1 the portion of the task that you had responsibility for?
2 A That's right.
3 O Did one "of you have a responsibility to come up 4 with some preliminary conclusions which would then be the
~
5 subject of a meeting? or did you have a meeting at which 6 you reached. preliminary conclusions and then start to 7 write?
8 A okay. My recollection -- and you guys are free 9 to add -- is that it wasn't quite as explicit as that 10 either. We would get together to discuss our analysis and 11 the conclusions began to emerge: "Well , does that mean 12 that?" "Yes. That means that."
13 .And so Bill would kind of mark that down. So, the k-
- 14 conclusions started to emerge through our discussions.
15 The question that you are asking about actually, then, who 16 finally -- I'm not exactly sure who might have drafted 17 that and Bill might have -- it was really --
18 A (WITNESS KAPLAN) They took the first shot out of '
19 it.
20 MR. ROISMAN: He won't get "they."
21 A (WITNESS KAPLAN) I'm sorry. Chuck Rice took the 22 first shot at it, I believe. Then I took that and wrote 23 another draft. I wrote another draft and worked on that '
24 which went into our management review. Then when Bill got 25 back --
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- 1 Q Management review, you mean the revi,ew for the 2 NRC?
3 A 'Have I gone too far? It's hard to keep the time 4 sorted out but basically my statement is that Rice wrote 5 conclusions once. I know I took a shot at writing them 6 cnce. And Bill Stratton did too.
7 A (WITNESS STRATTON) And after we had the first 8 couple of drafts, those were done while I was away. Then 9 we came back. Then after that, as we wrote successive --
10 I don't know hos many more real versions ther'e were --
11 there were clean up meetings and we finally had a meeting, 12 I believe it was the 26th, all day. And we went through 13 it line by line to see: "Do you agree with this? Should 14 we change it? How should we change it? What are you 15 basing it on?"'Et cetera.
16 That was -- basically I took extensive notes all over 17 the thing as we did that and then made alterations for the 18 final draft that everybody could sign off on. '
19 Q All right, my last question withLn the tima l
20 limits involves.a physical task on your part. I have here l 21 20 drafts of the' report, and I have no way of knowing l 22 whose draft I have or whose handwriting is on the draft.
23 So, what I would like you to do is to identify them for me.
24 Some of them have names written up in the corner.
25 MR. HIRSCHHORN: I don't think we have these.
i y .-. . - - . - . . - . - -
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20989.0 132 CRT 1 MR. TREBY: That's Appendix B --
2 (Discussion off the record.) .
3 BY MR. HIRSCHHORN:
4 Q Dr. Margulies, I wonder if you would be good 5 enough to, although you have done it once already in brief, 6 tell us a little bit about both your academic and 7 practical experience in both the fields of organizations 8 and organizational development, with particular attention '
9 to organizations that you have observed, actually, in 10 practice?
11 A (WIINESS MARGULIES) Sure. Let me do the 12 academic first. Would it be helpful to go over degrees 13 and stuff like that? Or would you just like,to know --
14 MR. HIRSCHHORN: Perhaps it would be useful if, 15 at this point we mark your vita as included in the 16 discovery from the NRC staff, as attachment C to their 17 f,irst response, part of their attachment C to their first 18 response.
19 (Discussion off tha record.)
20 (Exhibit 8 identified.)
21 DR. MARGULIES: If there's something additional --
22 all I can think of is just repeating what I said but 23 you'll lead me, I presume.
24 BY MR. HIRSCHHORN:
25 Q That's a bad word to use, but we'll ask you the D
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20989.0 133 .
BRT 1 questions.
2 A (WITNESS MARGULIES) That's what I mean. My 3 undergraduate is civil engineering from Brooklyn Polytech.
4 I worked both Cor the State of New York and City of New 5 York primarily in public works and bridge design and had 6 an opportunity, also, then to work closely and observe the 7 construction of some of the modifications of bridges, 8 particularly in the New York City area.
9 I worked in that occupation, that job, for 10 approximately three years and decided some educat. ion in 11 management would be useful. I had a scholarship to go to 12 MIT, and did a master's degree in industrial management.
13 And became especially inter'ested in organization theory 14 and organization behavior; and, from there, pursued a 15 doctorate at UCLA in the general area of organizational 16 behavior.
17 I went from UCLA to teach for several years at case 18 Institute in Cleveland.
L9 By the.way, I always pride myself as having been either 20 a student or faculty at some of the best engineering 21 schools in the country: Brooklyn Poly, MIT, _ Case, and 22 ultimately taught part-time at Cal Tech, as a matter of 23 fact. But in any event, I spent several years at Case 24 Institute in the Division of Organizational Sciences.
25 Then went to join a colleague who was at the University of
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20989.0 134 BRT 1
1 Miami in Florida.
2 Then left academia for several years in 1968, and I 3 really wanted more practical hands on experience in 4 organizations; and worked at TRW Systems in Redondo Beach 5 as an internal consultant.
6 I'm very fascinated with project organizations and 7 matrix structures, and just -- managemen't capabilities in '
8 general, particularly in complex organizational structures 9 . compared to simple pyramidal organizations, the ones we are most' comfortable with.
' ' ~
10 11 I then went to the University of California at Irvine 12 in late 1969 '70, academic year, as faculty; was associate 13 dean in that school between '72 and ',76, and I gave that 14 up and went back to full time teaching and writing and was 15 appointed dean just this past July.
16 My academic work, I think, involves a good deal of 17 research, basically on the impacts of organizational 18 cultures and I think I wrote some of the first material on '
19 what. is now cal l ed ors =4 utional. de.velopment.
20 ~Some of that, by the way, almost all of it, grew out of 21 my practical experience at TRW, when the field was 22 beginning to emerge, just beginning to try to identify and 23 conceptualize what organizational development is and how 24 do organizations change.
25 So, in a nutshell, that has been my major focus. As I
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20989.0 135 BRT 1 said earlier, I have written approximately five books on 2 the subject -- I don't know, 40 or 50 or 60 articles, 3 something like that.
4 Practical experience is that since my UCLA days, I 5 guess, is the best place I can identify -- and that is
-~
6 about the mid- '60s, I have engaged in a consulting 7 practice that is, I think, very exciting and very-8 challenging. I work with a variety of organizations. In 9 fact, one of the books I've written on organizational 10 ' development concerns change in the health care industry.
11 But basically, most of my work is in technical 12 organizations, which includes TRW, Northrop, Rockwell, 13 Western Digital, organizations like that.
v 14 I do a variety of consulting work, all the way from 15 worrying about productivity and efficiency of engineering 16 and technical personnel -- which is the project I'm doing 17 right now at TRW Space Park -- to management development, 18 both diagnosis and design, which I'm doing that currently 19 for TRW Information Services Division, and going onto the 20 implementation of new technology, which is a five-year 21 project I have been working on at Northrop. _
22 So, I think I have approximately 20 years of consulting 23 experience in a range of issues, I think, that are 24 pertinent to the practice of management and organizational 25 design.
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20989.0 136 l CRT 1 I can go on. I mean --
2 Q No, that's okay. I would like to go all the way 3 back, if I may, to your time in the field of bridge design 4 just for a minute or two?
5 A Sure.
6 And did it involve wbrk~
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Q What did that involve?
7 on-site?
8 A A good deal of it was reinforced concrete and 9 structural design and then some follow-up work out in the field, interfacing with construction sup'er' visors on the 10 11 modifications that we had designed that were being 12 implemented in New York City.
13 .That was kind of early in my career, but I think'I have 14 a feel for, if you will, for the construction culture, 15 what's that like. I understand very well the pressures of 16 schedules and costs. So, while I think it was brief, at 17 least I have some interface and some feel for what that 18 industry is about.
19 0 I take it there was something of a quality t
20 control function in that?
l 21 A Oh, absolutely. And I think the problems were 22 not unlike the problems today in a variety of l
23 organizations, between production and quality control.
24 So I have at least an understanding and some feel for 25 the problem.
r I
20989.0 137
' RT f
1 Q And do your responsibilities as dean -- and did 2 your responsibilities in the past as associate dean at the 3 School of Management, involve hands on management and, in 4 a sense, quality control of teaching and research?
5 A I think that was a good way to put it. I really 6 see myself as a hands-on manager. I manage a -
7 million-dollar budget in the school and I have 8 responsibility for fiscal management, facilities 9 management, research support, and academic personnel.
10 That's pretty much all of it.
11 I have five people who report to me and I think we -- a 12 part of my job as "the academic leader" is to worry about 13 the quality -- in fact these days we talk a lot about the N .. .
14 quality of our institution -- which, by the way, U.C.
15 Irvine is ranked 50th in the United States among quality 16 institutions, which is quite remarkable for an institution 17 that's 25 years old.
18 So I think the emphasis on quality is very much present, '
19 and. L'n axpected as the, ea^ami.c. leader of the uni.t, to 20 worry about it and, in a sense , to carry that banner.
21 It comes in a number of ways. It comes by my 22 supporting quality research and by being extremely active 23 in setting the standards for faculty evaluation.
24 0 You indicated that you have been consulting for 25 approximat.ely 20 years, outside of your academic
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20989.0 138 CRT 1 responsibilities; is that right?
2 s A That's right.
3 Q And it has been for a pretty wide variety of 4 organizations?
5 A correct. Right.
~
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6 Q Mostly large ones?
7 A Mostly large ones. Including the TRWs and the 8 Northrops. Some small percentage, I think, are small.
9 In the Orange County area there are a growing number of 10 small companies, Prin'tronics, for example, is a company I 11 started doing business with when they were at about a $10
. 12 million sales level.
g- 13 Well, they are just - ,the growth pattern for that 14 company is absolutely remarkable. The kind of consulting 15 that I would do is: Can you really help us plan for our 16 projected growth? What kind of changes in organizational 1
17 structure do we need to worry about; what is the 18 capability? Can you tell us about the capability of our 19 management now and are we talented enough and capable 20 enough to handle the growth patterns that we see coming?
21 What additional skills do we need to match those demands _
22 and expectations?
23 so, my work is with various organizations and various 24 size organizations. .
25 0 . When you look at -- and perhaps this is not
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20989.0 139 CRT 1 something you can describe in h typical fashion -- but 2 when you look at quality of management or competence of 4
3 management, what kind of things do you consider important'?
4 What kinds of things-do you look for?
~
5 A One of the things I think one needs to do is 6 assess the relative level'oI~ skill among the management 7 cadre, personnel, against the requirements, both current 8 and future needs.
9 So, when one says: What is the quality capability of 10 our managers'?' ihe first step is to take a look at what ~
11 are the relevant array of skills that are required to 12 manage this organization and manage it well; that is to 13 effectively do the job it needs to do.
14 Once that skill profile is developed, then to engage 15 with that organization in assessing the level of skill 16 that is present in that profile, as they see it, and 17 certainly I'm not a passive actor in that process.
18 But, against the kinds of skills that are required for 19 ef fectively managing this environment, this organization 20 now, how do we stack up and what do we need to be thinking 21 about as we go forward? I can give you a general sense of 22 the skills that we look at. I think there are three 23 general areas. I have my willing little model.
24 one is technical skills. Do these people know the
- 25 business they are in? Do they have the technical skills
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20989.0 140 BRT 1 to do the job? By the way, I find that 's not a problem, 2 generally.
3 The second area is management skills.
~
Do these people 4 have the capability to manage the enterprise? That means, 5 do they understand financial management? Do they
~
6 understand planning skills? Just the array of things that 7 manages the budget process -- the kinds of things managers 8 do.
9 And the third area is people skills. Do they have the 10 skiils to communicate, to motivate people, to provide 11 leadership, to counsel and coach subordinates? To manage 12 interfaces? Those are really " people" skills.
13 -
So I have, I.think, a fairly well accepted model, at 14 least in a broad sense, of the profile one might use to 15 make those judgments.
16 Q Have you had prior consulting experiences that 17 involved, either wholly or in part, concerns about 18 intimidation of one kind or another? '
19 A This is the f.irst e.xpl. oration. of that sort.. I.t.
20 doesn't mean that that's not present, but it certainly has 21 never come to my attention and I've never been asked to 22 investigate that -- to look at that.
23 O Have there been other consulting projects that 24 you've worked on, where there was the kind of -- I think 25 we have heard the described as innate or built in
2'0989.0 141 BRT 1 horizontal tension between an audit function and a program 2 function?
3 A Yes. I was saying earlier, in manufacturing
- 4 organization that are unsophisticated in how that 5 relationship between production and QA/QC ought to work,
~
6 there are The' kind of built-in adversarial perceptions of 7 the role of each. And it's not uncommon.
8 Q Is it, in fact, fair to say that you would be 9 more likely to draw a conclusion that the job was being
'1d ' done properly if there were such tension than if you did 11 , not find such tension?
12 A I'm not sure I'd conclude that at'all. Because
.13 there are instances where there is a smoother, almost w] '
14 collaborative relationship. And still permits the QA/QC 15 function to objectively do the job they have to do.
16 And, as a matter of fact, I was remarking earlier that 17 in the manufacturing sector the distinction -- I'm backing 18 up a moment -- the distinction, by the way, is an 19 artificial one. It was created out of what once was a 20 process orientation to producing products.
21 It goes through a sequence of design, manager, and 22 quality assurance.
23 The computer technologies these days are making those 24 boundaries less and less distinct. And so, more and more 25 because of rapid and more accurate generation of data the i
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20989.0 142 BRT 1 QA/QC and production methods are being forced together.
2 The computer is forcing very sophisticated and rapid 3 changes in the design of organizations and those functions.
4 So what I'm suggesting to you is that the distinctions 5 were artificial, based on old ideas of the process of m$NUfacturing that are now, really, becoming more and more
~
6-7 outdated.
8 That's a long winded response. But I don't think if 9 the tensions were absent, I would conclude that the 10 functions weren't being performed effectively.
11 Q Maybe I can put it another way. I take it that 12 you consider it perfectly normal to' find such tensions?
13 A In organizations that are structured based on-14 what I described as the manufacturing sector model, it 15 would not be uncommon; correct.
16 Q Nor, necessarily, a sign of ill health?
17 A Absolutely.
18 O Mr. Rice, I wonder if I could ask you a few 19 questions and preface that by marking your vitae as
' 20 included in attachment C to the first response of the NRC 21 staff as Exhibit 9.
22 (Exhibit 9 identified.)
23 BY MR. HIRSCHHORN:
24 0 I would like to ask you, as I asked 25 Dr. Margulies, to just tell us for a few minutes about
.=
_ _ _ _ __,y_ _ . .,
20989.0 143 ERT 1 your background with particular emphasis on your practical 2 experience, both in the nuclear area and in the 3 construction area, and' in the quality control area, to the 4 extent that's applicable.
5 A (WITNESS RICE) I'll skip over the educational
~~ 6 rather quickly. I got a BS and MS in physics, back in the 7 days when nuclear engineering was not yet declassified --
8 a declassified subject. I went to the Oak Ridge Reactor 9 School for the equivalent of another masters in nuclear 10 enginee' ring.
11 I taught, af ter the master's degree, for two years --
12 kind of the opposite of Newt's kind of experience; I went 13 to had the Atomic Energy. Commission immediately after that,
( 14 in Oak Ridge; worked for three or 3-1/2 years there, and 15 when I was there went to ORSORT.
16 Went into the private sector, then, as project engineer, 17 on some of the early -- in this case it happened to bow 18 the Army Package Power Reactor which was an early design
- 19 for a remote location for the Army.
20 I then went to an architect / engineer firm in Chicago as 21 head of their atomic power engineering group; found I 22 didn't fit into the A&E side of things very well, and went 23 back into the design and manufacturing construction side 24 of things.
25 Under my direction we built and installed a number of 0
-- - --- - -w ,, , n
20989.0 144 CRT 1 small training reactors in the United States and' overseas.
2 I continued in, up the line of project management, 3 became project manager for the Army Gas Cooled Program 4 which built the gas cooled reactor experiment in Idaho 5 Falls, the ML-1, which was a gas cooled gas turbine small 6 scale power plant and then, through a series of jobs, 7 became project manager for the nuclear rocket program, 8 so-called NERVA, which was a joint Atomic Energy 9 Commission and NASA.
10 As project manager it. involved the construction of 11 significant facilities', the maintenance of disassembly 12 areas for the test reactors and test engines; and the test 13 engine stand in Jackass Flats; both of them there.
14 From there I went to Idaho Falls as president of the 15 company that runs the national -- it was then the national 16 reactor testing station, it is now INEL, and was president 17 of the first Idaho nuclear, and then Aerojet nuclear 18 companies until 1972 when I started a consulting firm, 19 primarily for the purpose of spinning off the safety 20 programs that were being developed at the site and the 21 quality assurance programs. ,,,
22 I got started in the management consulting area as --
23 while I was still president of Energy Incorporated and it 24 was so much more interesting and, I think, satisfying to 25 me, that I dropped out of the company and -- actively --
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_ _ _ _ . _ ___ .__.._=u . . . . . _ . _ . . _ _ . ._. _
20989.0 145 BRT 1 in about 1978, and then totally -- '78 or '79, totally in 2 1981 -- to concentrate on management consulting in 3 manag'ement of nuclear power, both operating and 4 construction.
5 Q When you were project engineer for the Army 6 package power reactor program, what were your 7 responsibilities?
8 A Well, at that point the responsibility -- I 9 ought to clarify that. I'm sure I should.
10 The company I went with immediately after the Atomic 11 Energy Commission was one of probably a dozen or so 12 bidders on a -- on the APPR, Army Package Power Reactor.
13 And the contract actually went to another company. We 14 wound up in second place.
15 So, virtually all the time that I was at that company --
16 which was a division of the Sperry Corporation, was in the 17 preparation of the bid for the Army package power reactor.
18 Q And on the gas cooled reactor system program, 19 what were your responsibilities?
20 A I started off when I went there as project 21 engineer, project manager for the power con versions kit, 22 which was the non nuclear side of thing and then became 23 project manager for the ML-1 project, and then became --
24 what the terminology for it is, is supervising 25 representative for the Army gas schooled reactors systems 9
20989.0 146 BRT 1 program, which included all aspects of the program.
2 Q By "all aspects," what aspects -- what specific
'3 functions within the program were you responsible for?
4 A Design, fuel fabrication, analysis, construction, 5 fabrication, everything with respect to development --
6 Q Quality also?
7 A Quality -- yes.
8 O Were your responsibilities in the NERVA -- were 9 your responsibilities in the NERVA rocket program similar 10 to those?
11 A Yes.
12 BY MR. DU BOFF 13 Q Did that program ever get off the ground?
14 A No, it exceeded every technical objective that 15 was there and the mission went out the window somewhere in 16 the general vicinity of '68 or '69.
17 BY MR. HIRSCHHORN:
18 Q And your responsibilities there included quality
- 19 control as well as design and construction?
20 A No. Quality assurances was separated at -- on 21 the NERVA program, reported, at this point I recall 22 directly to the vice-president, who was in charge of the 23 whole program.
24 Q And let's jump ahead, if we may, to the recent 25 times with LRS Consultants and also with Energy
= _ _ _ _ l-. _ _ _ _ _ . _ _ . . _ . _ _ _ - . _ .
20989.0 147 BRT 1 Incorporated. You mentioned that in each case, safety and 2 safety analysis were significant aspects of your work in 3 those two -- both today, in LRS, and in the past in Energy 4 Incorporated. I wonder if you could elaborate on that a 5 little bit? Just What kinds of work you did -- had done?
6 A By that point in time, at Energy Incorporated, 7 obviously I had a key department that was made up of a 8 number of analysts and computer programmers, technicians, 9 the whole works. So my responsibility basically was for 10 management of the company.
11 Q And at LRS as well?
12 A At LRS we started off with a name that was the 13 Nuclear Management and Safety Review Group, three of us; J '
14 shortened that ultimately to Nuclear Review Group; and 15 basically worked as a team, Which may be three of us, and 16 maybe as many as fiv,e of us, in either one-shot-type 17 appraisals of the status of a project or of a company, to 18 do periodic appraisals.
- 19 Some of our clients, we go in four times a year and 20 take a look at what they are doing, what they have done in 21 the way of correcting management deficiencies that they 22 had, and make recommendations for further improvement.
23 Q About how many consulting jobs have you been 24 involved with in let's say the last 10 years, that 25 involved construction of nuclear facilities?
20989.0 148 ERT 1 A Four.
2 Q Four. And was safety a part of your charter on 3 any of them? All of them?
4 A , The ones that were heavily aimed at the near 5 term operating license stage, and were concerned, and 6 brought us in primarily to do what I would ter'm a readiness review audit, are the programs in place for 7
8 operational quality assurance for safety analysis, for 9 licensing, for training of operators, maintenance programs 10 in place -- all of the programs that, as you complete the 11 construction phase you need to get into to move into 12 operation.
13 Q About how many nuclear construction sites, would
, 14 you say, both -- well, let me take that back.
15 In the four construction sites that you reviewed in 16 recent years, did you have occasion or an opportunity to 17 observe "the relationships, or to learn about the 1
18 relationships between the quality assurance and quality 19 control side of the houso, as it were. and the craft side 20 or construction side?
21 A Yes.
22 O Can you generalize about your observations?
23 A Generalization is difficult. Each one of them 24 was unique.
25 Q Would you consider what you have learned about
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_ . _ _ . :: . :_ :- -: . _ ::~ ~ ~ ~~ T _
20989.0 149 ERT 1 the Comanche Peak plant to be typical of what you've seen 2 in these sites? Or atypical? And, if so, how?
3 Let me try to rephrase that.
4 A My problem is I've got a spectrum that goes from 5 one end of the scale to the other. And to say it was 6 typical is difficult.
7 Q Okay. Does the kind of tension that, at least 8 the report talks about, and presumably the data, in your 9 opinion reflect, both in type or in degree something ,that 10 you consider striking? Unusual? Any of those kinds of 11 things for such a plant?
12 A No. No.
13 ,
14 Q Would you consider it typical of nuclear power 15 plants at the construction phase?
16 A (WITNESS RICE) Again, I have a tougher time with 17 " typical."
18 From what I know, both from personal evaluations and --
19 as you are all well aware, the nuclear industry is a 20 pretty small, fairly tightly bound industry, and so those 21 of us who have been in it for as many years as we have 22 know a lot about plants by rumor and so forth. And by 23 reading about it, that may or may not have any direct 24 knowledge of it. And some of those are very, very bad 25 cases. Some of them are very good cases. That's wny I
~.'
_ ~
20989.0 150 BRT
, l' can't say " typical."
2 Q Dr. Margulies, you were going to say something?
3 A (WITNESS MARGULIES) I don't think it's unusual.
4 We said in the report -- I don't think it was unusual; 5 these kind of interface issues that seem to have been 6 identified.
7 A (WITNESS RICE) As a matter of fact, let me --
8 one of the questions you asked Newt, maybe you were going 9 to ask me ultimately anyway, a plant or operation in which 10 there is not a tension between an inspection auditing kind 11 of an organization and a fabricating constructing 12 manufacturing kind of an operation, I would suspect that 13 quality assurance was not doing its job. There needs to
~- -
14 be at least some tension. It can't be allowed to get out 15 of hand but there should be tension there or somebody is 16 not doing his job.
17 Q can you identify, either of you, either examples '
18 in an industrial organization where this tension is well 19 documented? Automobile manufacturing industry in any 20 industry at all where -- large scale industrial facilities?
21 A I'll have to bow to Newt on that. ..
22 A (WITNESS MARGULIES) I'm sure in aerospace, for 23 example, that it exists. I know in the Northrop. example, 24 or TRW, that those interface issues exist.
25 But I really need to footnote this. I don't think the
. _ _ _- . . _ . . . . ~ ____. _ _ _ . . .
20989.0 151 BRT ,
1 1 issue is so much whether this is usual or unusual. I i
2 don't think it's uncommon. But I think someplace one 3 needs to think about how these interfaces are managed and 4 how well they are managed.
5 So, while some tension is natural, those tensions need 6 to be managed. That's just another question. But I don't 7 think the existence is not necessarily a catastrophe, is 8 what I'm saying. It's the management of it.
9 A (WITNESS RICE) I think -- your mentioning 10 aerospace takes me back to Aerojet and the nuclear program, 11 For a reason, I think, that was associated with the fact 12 that there were going to be some astronauts flying around 13' . on top of engines that we were building, was something,
'14 that -- and those were days when QA/QC, beyond just.the 15 inspection -- line inspection function were really being 16 developed -- the. goal of both, of both parties were very 17 much the same. And that was to get the job done and to 18 get it done absolutely right. Zero defects were the name '
19 of the game. And that was the name of the game to the 20 engineer, to the fabricator, to the mechanic, to the QA/QC 21 people.
22 BY MR. HIRSCHHORN:
23 Q Dr. Stratton, I wonder if I could ask you to, 24 again, briefly speak to un about your experience and with 25 particular emphasis on either practigal experience
~~
,. , we g *+=.*e-e- ~*d***-
20989.0 152 ERT 1 actually in organizations, large scale organizations, or 2 as a student of large scale organizations?
3 A (WITNESS STRATTON) My academic training was in 4 mechanical engineering at Carnegie-Mellon. I got my -
5 master's degree in industrial administration from the same 6 school.
7 After that, I took a couple of years out from schooiing 8 and spent two years in South America in the Peace Corps; 9 came back and worked as a systems analyst for about a year, 10 a little more, for the City of Cleveland, in Ohio, and 11 about the end of that year went back to school in the 12 doctoral program, Case Western Reserve, in organizational 13 behavior, which I graduated from in 1974.
14 At that time I joined Idaho University and I have been 15 there since, serving first as an assistant professor, then 16 promoted to associate professor, where -- which is my 17 present rank, and I spent one year as the acting dean 18 while we had a search process for a. dean.
19 Practical experience in industry, I he$d a succasalon 20 of summer jobs in engineering capacities while I was in 21 engineering school and after, for B.F. Goodrich Company, 22 Eastman Kodak, Whirlpool Corporation. I guess that's it.
23 Two summers with Eastman Kodak.
24 Since I have boon an instructor, in teaching, been 25 involved in a consulting capacity with a number of e .-
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20989.0 153 BRT ,
1 companies,in -- engaged in various kinds of activities. I 2 have done some work in climate-type surveys, both with 3 EG&G, and also with two -- well, it was two hospitals 4 which merged into one hospital.
5 I have been involved in productivity improvement 6 program with one of the large potato processors in Idaho.
7 I have worked with some smaller organizations 'en the 8 structure of their organizations.
9 My dissertation was in the area of organization change 10 and how an organization perceives a threat, an 11 environmental threat, how they react to that and alter 12 themselves in some way to deal with its what they attend 13 to, what they don't' attend to.* Generally, how they 14 perceive a threat and adapt to it I don't know,'beyond ,
15 that -- maybe I ought to stop.
16 MR. HIRSCHHORN: Why don't we mark Dr. Stratton's 17 vitae now, we previously marked it as Exhibit 7.
18 (Exhibit 7 identified.)
19 BY MR. HIRSCIIHORN:
20 Q You mentioned as a consultant you were involved i 21 in a number of climate-type surveys. ,
Could you elaborate 22 a little bit on that please?
23 A (WITNESS STRATTON) One dealt with the hospital 1 24 mentioned, it was a case where two hospitals had merged.
25 They were quite different backgrounds in terms of their
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20989 0 154 BRT 1 origins and sponsoring orga'nizations and they were trying l 2 to put that together as a merged unit that would work 3 effectively. And, when a new manager, new hospital 4 admin'istrator took over there, he wanted to get some 5 reading in terms of how effectively that process had been 6 taking place. So, in conjunction with some people from
. 7 the hospital and another -- other individuals we 8 constructed a survey in questionnaire form and basically 9 surveyod the employees and ar,alyzed that data, then. And 10 gave them some need 'back in termu of where we saw problems 11 and what kinds of things they faight want to look at.
12 Q What kind.s of things about employees, either 13 perceptions or feelings or opinions were you trying to 14 ascertain in this hospital study?
15 A Let's see, as best as I can remember, we were 16 .looking at things like what they thought about their 17 supervisors, what they thought about the communications i
18 climate in the place -- I ean't remember them all new. We i
19 had a number of things we were interested in and asked i 20 questions aroynd both of them. And 1 believe, as I 21 remember it we as%ed questions in terms of how did people j 22 perceive the environment and what would be their druthers?
23 How would they like to see it if it was diffarent from the $
24 way it was, so we could do some kind of ideal versus )
25 actual analysis. '
,M
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20989.0 155 BRT 1 And then the other project I got involved with was a 2 similar climate kind of survey with EG&G. I worked with 3 Bruce on that. And that was in a couple of the units or 4 divisions within EG&G.
~
5 Q oh, within EG&G7 6 A Yes.
7 Q Were you looking for similar types of 8 information in that project?
9 A As I remember it was quite comparable.
10 ,
Q And you also designed the survey and began at -
11 the beginning, as it were, and went all the way through 12 with that?
f- -
13 A I'm not sure. I think that one was one -- we 14 may have purchased the survey; do you remember? I believe 15 we used the standard survey for that.
16 0 You also mentioned involvement in -- I thought 17 it was in the plural " productivity improvement studies or 18 programs"?
19 A Did a fair amount of work looking at 20 productivity improvement for a few years. Looked into the 21 whole quality circle movement, quality of working life 22 literature, and did get involved with most of -- most 23 extensively with one outfit where they actually mounted a 24 quality improvement program. It was intended to be 25 basically a precursor to the establishment of quality D +
- 20989.0 156 BRT . ,
1 circles. .It was a program basicalAy designed to attune l 2 their management personnel down through first line 3 supervision to the issues of quality and quality I
\
4 improvement, and to start building the culture and the t
5 climate in that organization that would allow them, in l i 6 successive steps, then, to move to the shop floor and E 7 maybe get involved somehow with production personnel in ,
8 quality circles or in some other similar design. '
9 Q Would you give us a brief definition of a ,
, 10 qu'ality circle, just for the record?
- 11 A Quality circle? Let's see, there's a standard 12 definition. It's a small group of typically volunteers, I
13 workers who volunteer to meet from time to time and work I
- q. ,
14 on quality issues dealing with their immediate work area. .
15 Q I assume you heard Dr. Margulies describe his ;
16 responsibilities as associate dean and dean at his 17 institution?
18 A Yes. i 19 Q Were your responsibilities during your year as ,
i t
20 acting dean at Idaho State similar?
21 A In general, similar. I think we were two \
22 different types of schools. To the extent that they have, ;
23 I believe, doctoral programs and more extensive research j 24 activities than we do, there would be some difference. l 25 But essentially as the dean I was the chief personnel f
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20989 0 157 BRT 1 officer in charge of the compensation and personnel 2 evaluation, hiring, and basically all of the activities of 3 the school. In the sense that I was acting, basically my 4 job was to kee, 4ne place running for a year until we got 5 a dean and not take too many initiatives. So, in that 6 sense I guess there were some differences. But by and 7 large what he.said was probably a good description of what 8 a dean does..
9 Q In your experience as a consultant looking into 10 behavior of organizations, have you had occasion to look 11 at organizations where there is both a program or 12 production function and a quality control function that 13 are not in the same individuals - that is to say two .
14 separate vertical lines within the. organization?
15 A Yes, I have seen that.
16 Q Can you give us a couple of examples of the 17 kinds of organization where you observed it?
18 A Again, where we ran the quality improvement 19 program, productivity improvements program -- in that 20 company they have quality control and they report to a 21 different manager than do the production people.
22 You know -- I don't know what your follow-up question 23 will be. There is the typical -- they work together, but 24 there's also the typical antagonism, production doesn't 25 always ljke to hear everything that quality tells them.
. s-
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20989.0 158 ERT .
1 Q Wall, you guessed it. Have you had other 2 occasions to look at construction sites or construction ,
3 operations or manufacturing operations that have both a 4 quality control and a production or a program function?
5 A I have done a lot of supervisory training, 6 particularly lower level supervisors -- first line t 7 supervisers and second line, with manufacturing-type 8 organizations: Fertilizer plants, a couple of large 9 phosphorus, elemental phosphorus plants in th'e region 10 there; a number of different firms engaged in potato 11 processing.
i 12 O So what someone --
l (' 13 A So I have been exposed to -- and a number of 14 these programs have been kind of in-house training 15 programs where the training takes place at the plant and I 16 interact fairly extensively with a number of their 17 supervisors. So got a feel for at least the climate in 18 some of those plants. That's not construction, if that's 19 what you have --
20 Q It's not construction but is it the kind that 21 would loosely be called " blue collar"?
22 A Yes. Definitely wculd be called blue collar.
23 Q And, would you say fron what you know of the 24 relations between the quality assurance people and the 25 crafts people at Comanche Peak, that it's an unusual m- ---e .-.m - -g,- - -m -e -g - w -- --, - + - -+ -
20989.0 159 BRT .
1 tension there, in your experience? ,
2 .A Well, given the magnitude of that project and 3 the fact that it's a construction project which is kind of 4 a huge job shop in a sense -- you build something once and 5 you are done -- that's really very different from my 6 comparable experience. So saying something is typical, 7 there, would really be out of line for me.
8 O Very well. Perhaps we should pass on it.
9 Last but not least, Mr. Kaplan, I will ask you once 10 again to open for this round'of questioning with a brief, 11 recap of your experience in the organizational field, both 12 practical and academic. And, also, if we may mark 13 Mr. Kaplan's resume simil'arly produced as Exhibit Number 6.
' 14 (Exhibit 6 identified.).
15 A (WITNESS KAPLAN) Well, I guess my interest in 16 organizations got started with my experiences starting a 17 couple of alternative schools. Even though that was a 1
18 small project, there weren't a lot of people to turn to or '
19 rely on, in terms of all the variables that need to be 20 looked at in terms of working with the universities, the ;
21 Board of Education, the teaching community, civic groups --
22 there was really quite a bit for some people who have been j 23 counselors and teachers to think about.
24 So, in getting involved in that I found the resources 25 of a community psychology institute in Cincinnati. It
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20989.0 160 CRT .
1 turned out what they were doing to help us get started is 2 very much in the field of organization development.
3 They helped us think about what the problems were in 4 starting a new institution; to help me personally in terms 5 of how I dealt with individuals and groups; how I 6 communicated. And I became an internal resource to them, 7 in terms of working with our school.
8 I had the experience of being codirector, then, of two 9 school programs over a period of about 2-1/2 years. I 10 worked in adult education, which I don't think was very 11 directly related to complex organizations but there was an 12 important theme developing for me, and that was my 13 continued interest in learning, in acalt learning. And 14 that turns out to be one of the very important things in 15 terms of organization effectiveness and certainly in terms ,
16 of managing and coping with change.
17 For graduate studies I decided to follow up on my 18 interest in organizational development. I also ended up 19 at Case Western Reserve in Cleveland in the Department of 20 Organizational Behavior, spent a year there. That program 21 is very much focused on complex systems and on change in 22 complex systems and levels of analysis, of understanding 23 individual's interpersonal relationships, group dynamics, 24 intergroup relationships, interorganizational 25 relationships, so that focus there became much more on
20989.0 161 BRT 1 large and complex systems.
2 After the year at Case, I took a summer job at EG&G in 3 Idaho with the intention of staying for 10 weeks. I liked 4 what I was learning and found it more valuable than being
~
5 a doctora1' student and certainly more validating of my 6 work as an individGil'. I decided to stay on for nine more 7 months and make it a one' year practical experience.
8 When I joined that organization my -- the rest of my 9 comments would be basically involved in the different-10 proj'ec'ts and responsibilities that I had at EG&G in Idaho.
11 They had never had an organization development function 12 there before, and that was an opportunity for me in 'some
, 13 ways to really learn a lot about the company. If there 14 were 50 basic interventions in organisr.tional development, 15 I probably got to try about 40 of them in the time that I 16 was there.
17 But I worked just -- I think it wo0ld be relevant here 18 to say something about the company. It's a -- something '
19 on the order of 3500 people. It has a large population of l 20 scientists and engineers as well as crafts people. It has 21 a large quality control organization. It's a complex 22 environment, in that we also deal with the NkC, the 23 Department of Energy, foreign governments, and those are 24 all customers, people and governments to be dealt with.
25 We also have the largest collection of nuclear test
r ..
20989.0 162 BRT 1 reactors in the worAd, I believe.
2 We have a 900 square mile chunk of the Idaho desert on 3 which these reactors are operating so dt any one time we 4 have responsibility for several operating reactors and 5 also as the prime contractor for the Department of Energy 6 there, wi'have~ site-wide services that we provide. So we 7 run a bus system of 10 people, we run several large 8 cafeterias, we run a laundry service for nuclear 9 contaminated materials, and a lot of the same kind of
'10' things that are involved in a commercial operation.
11 So I worked, I reported for four years to the general 12 manager there. I was very ckose to issues and problems 13 that were of concern on the full spectrum, I think, of L 14 management and organization.
15 0 You mentioned earlier that you had written your 16 thesis, I assume that's your master's thesis, in 17 organization climate?
18 A Yes.
19 Q Could you tell us a little about the thesis and 20 what you perceive as organization clima'te?
21 A Well, I checked that last night. I haven't 22 looked at it in some time.
23 Actually, my definition of organization climate was 24 very similar to the one that Newt had picked up and that 25 is in our report, basically defined it as the perceptual
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20989.0 163 BRT 1 phenomena, and I guess in contrast to the one that was in 2 our report, I picked it up as people's perception of the
^
3 human processes in the organisation. Newt also included
~
4 the technical processes as well.
5 Q Let us limit it to your experience with EG&G, 6 shich is six years now, is that right?
7 - A 5 -- over five years.
8- Q over five years. All right. Have you had 9 occasion to review or examine or study organizations of a, IO again put loosely, " blue collar" character? That is to 11 say, manufacturing or agricultural production or 12 construction.
13 A I worked in our nucle'ar programs and in the 14 operating reactors there would be situations that dealt 15 with an interface between crafts, quality, operations and 16 other management functions. I worked with the print shop.
17 Was involved -- at the time I got involved, was getting a 18 lot of grievances. That was certainly a blue collar 19 setting.
20 It has not been the bulk of my work. The bulk has been 21 closer to science, engineering, administration.
l l 22 Q Both in the blue collar and the other i 23 organizations that you've looked at in the last 5-1/2
! 24 years, have there been a substantial number that had a l 25 separate quality and construction program or production l +-
l
~
20989.0 164 CRT l
1 function?
2 A Well, the company has a separate quality 3 function. It reports to the large quality organization --
4 it reports in to the deputy manager --
5 O No, I meant -- I'm sorry. I meant the 6 organizations that you have looked at. Not the ones you 7 are a part --
8 A I believe you have some confusion. In my 9 consulting capacity I served as an internal consultant at 10 EG&G Idaho.
11 Q Right.
12 A When I'm speaking of organizations, they are 13 ' organizations that are parts of EG&'G.
O 14 O Okay. But, for example, in this instance you 15 have been involved in a study of an organization outside 16 EG&G7 17 A Right.
18 0 Have there been other such studies that you have 19 been involved in in the last 5-1/2 years?
20 A I worked at Three Mile Island on some interface 21 issues there, and a few other things.outside..of EG&G Idaho.
22 But I would say they did not involve interface between 23 crafts and quality control.
25 Q Was that for the Department of Energy?
=
-6
- ~ . = . _ . - . . -- - - - - ---- - --- - -
'20989.0 165 QRT 1 A Yes. <
2 Q At TMI?
- 3 A Yes.
4 MR. TREBY: Would this be an appropriate time 5 for about a two-minute stretch?
6 (Discussion off the record.)
7 BY MR. HIRSCHHORN:
8 Q There was some discussion earlier on about 9 whether, or to what extent intimidation or acts or 10' behavior of crafts people were looked at, not looked at, 11 including or not included in your work. Is it correct to 12 say that you, in~ fact, did look at craft behavior in your ,
, 13 study?
}
14 This is addressed to anyone who wants to answer it.
15 A (WITNESS KAPLAN) Yes.
16 O And is it also correct to say that you looked at, 17 where you found instances or possible instances of craft 18 misbehavior or intimidation, that you also asked whether .
19 management condoned or permitted them, either expressly or
, 20 implied?
21 A (WITNESS RICE) Yes . __
22 O Am I also correct to conclude, and there was 23 also some discussion back and forth about this, that for 24 purposes of your examination, if an employee -- if an 25 inspector felt intimidated, regardless of what you might 4
. , _ , . _ ~ .~. =
0 20989.0 166 BRT 1 have thought about the supervisor or cra'fts behavior in 2 question, if the inspector felt intimidated you basically 3 treated that as a intimidation for purposes of reaching 4 your conclusions?
5 A (WITNESS RICE) Yes .
6 Q Could someone say on the record 7 A (WITNESS MARGULIES) Gentlemen, I -- I'll 8 remember. Yes. -
9 Q You said if you started this from scratch you 10 might do it differently, you might look for more data, you 11 might either slightly or marginally or radically redesign 12 the approach -- maybe " radically" is the wrong word but 13 that you might redesign the approach.
14 Let me start with Dr. Margulies, because he's the 15 organization specialist, I guess the pri'cipal n 16 organization specialist here.
17 Presuming you had done the kind of study that you l
18 ideally would do, could you assign a probability as to 19 whether your conclusions would differ if you had done that 20 ideal study?
21 A Well, see, that's the same problem that I had 22 with a similar kind of questions from Tony. I just can't
{
23 do that. It's very difficult. l l
l 24 All -- I have no idea what would happen with the 1 25 conclusions. All it would do is, you know, raise somewhat i
l l
l
20989.0 167 CRT
~
l my confidence level in what I've done and at least satisfy, 2 A, my own curiosity; and, second, my own sense of 3 completeness and thoroughness.
4 Whether it would change, I'm guessing. It's purely 5 speculative.
6 Q Let me see if I can synthesize what I thought 7 you said on a couple of occasions during the discussion 8 with Tony, and see if you can tell me if I'm right, or if 9 I'm n'ot right, where I'm wrong.
10 Is it right to say that while you can't be certain that 11 additional. data wouldn't change your conclusions, that you 12 have a reasonable level of confidence -- I think that was 13 your phrase -- that the'results of this report reflect the
(# i 14 actual conditions at the plant?
15 A What I was saying over and over again that, 16 given the data pool, I'm confident with the conclusions 17 that we arrived at. And once you start changing my data 18 pool, then I don't really want to raise -- you know, I 19 don't want to attach any probabilities of what might 20 emerge. But given the data set which I don't -- you know, 21 I think wasn't ideal or perfect, but wasn't all that bad --
22 I have some confidence in what we did and, you know, the 23 conclusions that we reached.
25 Q Let me ask you this. You started to make a
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20989.0 168 BRT I l
1 statement this afternoon when you were each being asked a (
2 series of questions about the level of confidence in the 3 data, and in particular -- this was after Mr. Kaplan had 4 said that he would not -- does not feel that additional 5 study is necessary -- you began a sentence -- I hope 6 you'll recall it because I don't think you were able to 7 finish it. You said, "I don't see any triggers that raise 8 a - " and that's all I got down. Do you recall making 9 that statement? You used the term " triggers" and I don't 10 think you finished the thought. At least I didn't hear it?
11 A (WITNESS MARGULIES) Again, given the data pool, 12 the data we had to work with, I don't see anything that 13 would trigger --
uj 14 O The need for more data?
15 A -- would trigger my concern about the 16 conclusions that we reached. There's nothing that sort of 17 is poking me in the aye and saying: Well, wait a minute.
18 And, again, I would really like to reserve the right to 1
19 change. I don't feel like I'm absolutely wedded to this.
20 I'm wedded to it, given what we've done. But if you 21 change my data configuration, I'm perfectly, you know, _
22 free and open about changing what I've come up with. But 23 given what I've got, I feel okay about it.
24 Q In fact, you are getting more data and you are 25 continuing your evaluation?
'T p --. - _ - _ - _ _ __
~
20989.0 CRT 169 l
1 A Sure'. Absolutely. Absolutely.
2 BY MR. HIRSCHHORN:
3 0- There was some discussion earlier of the five 4 criteria that go into or are involved with defining or 5 ascertaining the presence of a climate of intimidation, 6 which appear on page 5 of your final report. And there 7 was, I think, particular focus on the first one, which had 8 to do with how widespread the allegations were.
9 Is it fair to say that each of those five criteria --
10 let me back up a minute.
11 A Okay.
12 O There was also some case, I think from 13 Dr. Margulies, that you thought it was important to look 14 at'the 5 criteria together rather than separately; is that 15 right?
16 A That's accurate.
17 O Is it fair to say, though, if you do look at 18 them individually, that each of them taken independently '
19 points away from a finding that there was a climate of 20 intimidation at the plant?
21 A (WITNESS KAPLAN) That sounds a little strong to 22 me. Some of them are just really hard to -- weren' t 23 indicators one way or the other.
24 0 Is it fair to say that none of them taken 25 independently points toward a finding that there was a
'T l __ ..
1 l
l 20989.0 BRT 170 1 climate of intimidation at the plant?
2 A Yes.
3 A (WITNESS RICE) There was one, I think it was 4 number 4, in which we didn't feel we had enough data to 5 determine Whether or not the company had terminated people l
6 for crying intimidation or had taken appropriate action.
8 0 You are referring to question 47 9 A The fourth bullet, 10 BY MR. HIRSCHHORN: '
11 Q That was the one in Which you said you had 12 incorrect evidence. That's why I reworded my question, to 13 say it does not point toward that finding.althoug'h perhaps
~
14 it doesn't point away from it?
15 A That's right.
16 O Would you consider each of the five points being 17 relatively the same value in reaching a conclusion? Or 18 can you not even make that kind of a cut?
19 A (WITNESS RICE) I'll say I would consider them to
! 20 be of essentially equal value. We did not try and make a 21 cut on it. We didn't list them:
This one is_the most 22 important, this one is next, and so forth.
23 O So the order of listing implies no opinion about l 24 importance?
25 A No.
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20989.0 171 BRT 1 Q Any other responses to that question? It's 2 really addressed to the entire panel?
3 A (WITNESS STRATTON) No, as I think about it, I 4 don't think we made any attempt to put those in any order.
5 As I remember it, we looked at them as possible indicators 6 of a climate and then, with the caveat at the bottom, or 7 the addition, that they wouldn't all have to be present.
8 And, in fact, if you saw enough with even one of them, 9 that could be enough. It, again, becomes a judgment call 10 looking at the pattern that you find.
11 A (WITNESS MARGULIES) I would agree. I would 12 agree with that.
13 O There was some discussion, I guess, both in 14 Dr. ' Goldstein's testimony and also here earlier today, 15 about learr.ing theory. and I guess what might be termed a 16 "rippic effect" of certain behavior, or potential ripple 17 effect.
18 Dr. Margulies, if there were such a learning or a 19 ripple effect in the Comanche Peak construction site, 20 would you not expect the surveys, either one or both of 21 them, to have reflected that?
22 A (WITNESS MARGULIES) Yes. I would have expected 23 that if the incidents were powerful enough and were being 24 widely communicated, that there would be some -- at least 25 greater concern than seemed to come up in the surveys
--er, . . . . .*e- wa s=
. - _ , . ._. . ~ - . . -- . -- -
20989.0 172 BRT 1 around " intimidation."
2 I would have expected it to show up a little bit more 3 profoundly than it did.
4 O There was also some discussion earlier about the 5 kind of people who might or might not come forward, and 6 some suggestion that that the -- that perhaps the people 7 who were most likely to be intimidated would be the least 8 likely to come forward.
9 Would you consider that true in the case where an 10 anonymous coming. forward can occur, as, for e'xample, the 11 hotline that was established by the Comanche Peak 12 management? That'.s addressed to the panel.
13 A (WITNESS MARGULIES) I think people who are less
'14 inclined to come forward publicly, might do so if they 15 felt that confidentiality and anonymity could be 16 maintained. But the very fact that you have hotlines or 17 ombudsmen doe'sn't necessarily insure that, so it's pretty 18 hard to predict. In general, I would say that people who 19 are likely to be intimidated for a variety of reasons --
20 as I said earlier economic security or psychologically or 21 whatever -- are probably not likely to come forward very, 22 very easily..
23 So, what we've got, really -- and again I think, given 24 the data pool -- what we've got are, A, the allegations 25 made by people who are willing to ecmc forwardt B, survey
=
-_ . . . - ~. -
20989.0 173 BRT 1 data, which I think is more global and I think, at least 2 to a greater degree, protects anonymity, but not 3 completely; and I can't speculate about how many people 4 there are who feel intimidated but who prefer not to come 5 forward or even to indicate it on the surveys. It's 6 pretty hard to predict.
7 A (WITNESS RICE) I've got a personal feeling. I 8 wasn't asked the question earlier when Mr. Roisman was 9 doing the questioning, but my feeling is -- and this is 10 based on looking at an awful lot ofo'rganizations -- that 11 the people who are most likely to come forward are, in 12 fact, the ones who are most likely to be intimidated.
13 So~ I think I would disagree with 'the fact that the Na-14 people who are intimidated are the ones who are least 15 likely to come forward. I don't think that's -- that does 16 not jibe with my experience.
17 Q Going back to the list of criteria on page 5 of 18 the final report -- and this may be a problem of my own 19 ability to understand what I'm reading -- but the 20 introductory line says that "
the existence of a climate of ,
21 intimidation could be evidenced by the following symptoms."
22 Is that to imply that there were other possible 23 evidences that didn' t make it onto this list or do you 24 consider this pretty much of an exhaustive list?
25 A (WITNESS KAPLAN) Could you repeat the question?
4
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i 20989.0 174 CRT e-1 Q Sure. Are these just the five major criteria or 2 just five typical criteria or are these what you consider 3 the universe of criteria of a climate of intimidation, 4 what,the team would consider the universe of criteria?
5 A (WITNESS RICE) I would say they were the only 6 'five that came to us that we could come up with. There 7 may be more, but we thrashed these around and argued them 8 back and forth long enough that I would say if there had 9 been other ones, we would have incorporated them also.
10 A (WITNESS MARGULIES) I think there could be more.
11 I want to go back and just -- a line or two about the 12 methodology.
13 I feel very strongly that the methodology was basically 14 inductive, so, in a sense you start out with a concept of 15 what it is we want to look at and then there's an overview.
16 of the data which gives you some hints at the kind of 17 dimensionality that one might apply looking at this 9
18 concept.
19 For example, if I said to you: You know what, if we 20 could actually measure each individual's choice of 21 conflict resolving mode, how people individually go about 22 handling conflicts in the organization, it really might be 23 an indicator of the level of intimidation; perceived 24 intimidation. Right? For example, if people tend not to 25 choose confrontation as a way of resolving conflicts and
'.~
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20989.0 175 BRT.
1 choose something else, like accommodation or something 2 else, it might give us some -- trigger some hint at the 3 nature of the climate.
4 So I really think what we did -- I would not see these 5 ,five as being exhaustive by any means. But I think they 6 do reflect some avenues that would give us some hints 7 about climate of intimidation, given the information that 8 we had to work with.
9 Obviously we are not going to develop criteria that we 10 had no chance of measuring. So I really-think it was '
'll inductive.
12 The criteria in part emerged from our understanding of 13 the information, in part, as well as the concept. That's ,
~
14 my view of it.
15 Q Okay. On page 6 there was a discussion of the 16 procedures that the team followed and the largely
-17 independent reviews of the raw material that I guess ,
18 Dr. Margulies, Dr. Bowers, and Mr. Rice conducted. '
19 There's a line that says, "both the organization 20 scientist" -- who is Dr. Margulies - "and the industry 21 experts" -- that's Dr. Rice -- " subjected the. data to 22 criteria they deemed pertinent from their particular 23 professional viewpoints." l 24 I wonder if both Mr. Rice and Dr. Margulies would
\
1 25 address that briefly, even if only to say that these are i
. .7
20989.0 176 BRT 1 criteria that you1have already discussed today.
- 2. A (WITNESS RICE) From my standpoint they were put 3 forth in the report, I'think, to the extent that they -- I 4 don't know what I could add to it, I guess. That's what 5 I'm saying.
6 A (WITNESS MARGULIES) What I'm saying, partly --
7 Chuck may process the data,'you know, somewhat differently.
8 I think what we did as a team was to continue to check 9 what was happening with the data, what we were doing with 10 the data,'what conclusions we were reaching. -
11 Now, the best example is that I think Chuck made the 12 decision that, in the '79 survey, there was a particular
, 13 set of questions that, in his opinion, with his' experience, 14 he felt were indicative of climate of intimidation.
15 While he and I had some overlap, I happened to choose 16 an additional question that I thought was relevant.
17 So, while our processes might have been slightly 18 different for handling the information, in part we thought 19 that was a positive, we thought that was a plus. Because 20 our slightly different and independent judgments were 21 leading us in the same direction. _
22 Then I would have worried. I mean if we were using 23 slightly different formats for looking at the data and we 24 were going in different directions, then I would have said:
25 Hey, wait a minute. Hold everything. Let's see if we are j -
1 I
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20989.0 177 CRT 1 going off in different directions.
2 Q So would it be correct to say that the reference 3 to criteria that you deem pertinent from your particular 4 professional viewpoints would,be similar to saying you 5 filtered it through the -- you put it through the filter 6 of your own experience?
7 A (WITNESS' RICE) Sure.
8 A (WITNESS MARGULIES) Sure.
9 .O No more than that.
10 The report states on page 14 that as a construcfion 11 effort approaches completion there tend to be " unconscious 12 or intentional" slowdowns on the part of both craft and 13 inspection personnel.
'u - .
14 Is this a thesis that's widely accepted in the 15 crganization and management field?
16 A ,
(WITNESS MARGULIES) I think Chuck can respond to 17 that.
18 A (WITNESS RICE) I don't know whether it's widely 19 accepted there but it's something that I have seen at i
20 other plants and in discussions -- I believe it's 21 something that is fairly common in o.ther plants.
22 A (WITNESS KAPLAN) It would seem to have face 23 validity for me. It would seem to make sense.
24 O I had one question, by the way, about the l
25 document that was marked as Exhibit 4, which I believe
(.
f -
20989.0 178 BRT ,
1 'Mr. Rice prepared; a table of 1979 survey.
2 A (WITNESS RICE) Yes.
3 Q In the left-hand column, on each line there is 4 sort ,of a denominator which is the question number -- a 5 numerator, which I guess is the question number.
6 For example, on the first line I think it is 1-D, 7 although I can't read it too well?
8 A 1-D22.
9 Q 1-D2. What is the meaning of the denominator, 10 the second figure in that column? -
11 A If you.tu'rn back to the survey itself, you will 12 see on the second page the quest' ion is 1, system adequacy, 13 and then D, how' comfortable do you feel with your job and
)
14 2 subs under that, 1 and 2. 1-D2 refers to that specific 15 question.
16 Q Oh, I see. Okay.
17 A "What makes you feel uncomfortable about your 18 job?"
19 O Got it. Okay.
20 On page 37 of the report, in the final two paragraphs, 21 there is a discussion that addresses.two types of 22 organizational environment and I think suggests a 23 preferable or a typical management style for each.
24 Let me find it on my own copy. !
25 A (WITNESS MARGULIES) What page?
__y----- -__--~
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20989.0 179 CRT .
1 Q Page 37. The last two paragraphs. Am I correct 2 in assuming that Comanche Peak is of the last type,
~3 relatively stable routine organizational structures or --
4 A My god. I wouldn't see it that way at all.
5 0 You'd see it as the former type?
6 A Oh, sure. Just walking through and 7 understanding the complexity of what goes into the design 8 and interfacing between the plumbing and electrical and 9 computer and -- I mean -- no. I would not list it at the 10 latter. -
11 The latter is relatively stable routine repetitive 12 organizational functions. If you ever were familiar with 13 a transit company that puts buses on the streets. That's .
14 -stable, routine, you get in the bus, you drive the put --
15 okay?
16 No, I would think it's the former, in my opinion.
18 O Mr. Kaplan, were you in charge of selecting the 19 team? Putting the team together, I should say.
! 20 A (WITNESS KAPLAN) I think it was my discussion, 21 ultimately, who to have on the team.. __
22 O And could you just give me some background on 23 the criteria for selecting the team members? What you 24 were looking for?
25 A Let me just elaborate on my first answer.
t - _. _ _ - . --__. - ..
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20989.0 180 BRT .
1 I don't know what would have happened if I had 2 recommended people that were unacceptable to the NRC. In 3 my role of trying to advise them and help them take a 4 position, I felt it was important to have people who would 5 be acceptable to them.
6 There's no point in hiring somebody as an adviser who --
7 if they had a conflict of interest in their mind or who 8 didn't have the basic credibility to do the job.
9 Q And what criteria were you looking for when you 10 began the process and as it evolved and you put together 11 the team?
12 A Well, when I first began the process, I had a 13 very brief description from, primarily from Mark Williams 14 and then from Carl obenchain, who had gotten his information 15 I think mostly from Mark.
16 And at that time I just had some of the words that 17 we've read here in terms of general atmosphere of 18 intimidation, discouraging people from doing their jobs l 19 properly.
20 And I also had a list of names that the NRC staff had 21 gathered up as possible people to consider. -
22 One of the reasons I got involved in this project was, 23 of the people they were considering, there were about 15 24 names on the list -- you have the list --
and I think I 25 knew about a third of them either from having -- or knew 6
- v. ---a
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20989.0 181 '
BRT .
1 of about a third of them in terms of their work. And they 2 were people who were in my field. That's one of the 3 reasons that I got involved.
4 To further define what and who we needed, I made a trip 5 to Comanche Peak. I had the feeling that I needed someone 6 from the field of management and organization, but who 7 also understood the issues of the nuclear power plant, or 8 at least of a large construction -- large complex 9 construction project.
10 I decided that, early on, that was going to be very 11 difficult to find all in one package and there might be 12- some advantages to having a small group of people to do 13 the job. , ,
14 A (WITNESS MARGULIES) Scott, can I interrupt for a 15 moment? I need to clarify what I had said about page 37.
16 I just don't want any misunderstandings about it.
17 The question was, given the last two paragraphs, how 18 did I see comanche Peak. And I said I -- my evaluation is, 19 in terms of the technical requirements, I think it's --
20 that the first of those two paragraphs. Right? Did you 21 understand me to say that? --
22 BY MR. HIRSCHHORN:
23 Q I did.
24 A Okay. I just want you to understand that on the 25 following pages is at least.my own sense of how it stacks
?
O
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I 20989.0 182 BRT 1 up against that. Okay? So the paragraph on page 37, is , I 2 think, the kind of organization that's required with that 3 kind of technical environment. Bur. , as you see en the 4 next p' age or so, there are some real problems in how well ,
5 it does that. I just wanted to clarify that.
6 Q Of course your conclusions on pages 38 and 7 following, like your other conclusions, are based solely 8 on the data you saw?
9 A of course. ,
11 Q This is a question that's really directed to 12 each of you. And, please, I would like to hear -- to the 13 ex' tent -- maybe we could start with Mr. Rice and then 14 Dr. Margulies, and then you can add what additional 15 thoughts you have.
16 Very early in the report, I think it's page 3, you make 17 it clear -- it's made clear throughout -- that you were 18 focusing on the question gf the overall climate and 19 looking for a pattern of intimidation.
20 I take it from what I've read that in a project of this 21 magnitude, that individual cases of intimidation are 22 difficult to avoid. Is that a fair statement?
23 A (WITNESS RICE) I think that's a fair statement.
24 O Dr. Margulies?
25 A (WITNESS MARGULIES) I would expect to find some
.~
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20989.0 183 BRT 1 isolated instarces in situations like this.' And, as I 2 think you well articulated, we were only concerned about 3 how that fit into the pattern. So we didn't necessarily 4 want to focus and isolate those. We were more interested 5 in the sort of general pattern that seemed to emerge.
6 Q Now, while I'm thinking of it, earlier in the 7 afternoon -- this came up a number.of times, but just so 8 it's clear in my mind, maybe for the record, the -- when 9 you evaluated data, you did not make any attempt to assess 10 its veracity; you accepted all that you were given for 11 what it said and then you treated all data equally in 12 terms of -- you didn't make any distinction based on what
(, 13 you thought might or might not be truthful or untruthful; 14 is that correct?
15 A (WITNESS RICE) Fundamentally. Modified, at 16 least in part, at least in my case -- the comment that I 17 made. You put five people in a meeting and the perception ,
18 of what occurred in that meeting comes out of those five 19 people, maybe diametrically opposed on each of them, if 20 there were that many degrees in a circle.
21 But when you put that into the context of--corroborating 22 evidence, what you are forced to wind up with is this 23 person's perception may have been less accurate than some 24 of the other people involved in it.
25 ,
O But you didn't discount any of the data? You
.=
S
20989.0 184 BRT 1 treated all of these instances in the record, the 2 depositions and the trial transcript --
3 A In my case, from the standpoint that I felt, to 4 the best of that individual's perception and knowledge, 5 that's what he thought happened or she thought happened.
6 Q And you accepted it as such?
7 A Yes.
+
8 O Okay. Dr. Margulies?
9 A (WITNESS MARGULIES) I made a judgment, 10 particularly with the depositions, which, in my opinion, 11 were not relevant to the questions that I was interested 12 in. .
. 13 Q Well, that's a different matter. .
x.
14 A Okay. So that I did.
15 O That's a different matter.
16 A The other judgment -- I tried very hard not to 17 make a judgment. And in most instances as I remember, -
18 there were differences of perceptions. Yes, you did. No ,
19 I didn't. We had that three month meeting. No, we didn't 20 have that three month meeting.
21 I tried not to make any judgments about who was right 22 or wrong. I was more interested in number of people 23 involved -- the kinds of data that I have, essentially, on 24 the chart.
25 I was more interested in simply charting instances
.~
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20989.0 185 ERT 1 rather than making judgments. Personally -- I said this --
2 but, personally, I felt that was really the job of the 3 attorneys.
4 If the data begins to change it would obviously change 5 what I might conclude. But at that point, as a colleague 6 of mine used to say: In the dark all the cats look alike.
7 And that's how I treated it.
8 Q On page four of the report it is stated that --
9 I should say the report distinguishes between a climate of 10 intimidation and what might be described as an autocratic 11 and rigid management style.
12 Mr. Rice and Dr. Margulias, could you each, perhaps, 13 elaborate on that? Dr. Margulies,' would you start?
14 A (WITNESS MARGULIES) Well, I felt that as long as 15 we were.in the realm of style, the issue of climate of 16 intimidation is a matter of individual interpretation.
17 And there are instances, then, where a particular piece of ,
18 behavior that might be classified as a particular style, 19 might very well be interpreted by one person as 20 intimidating and another person as not.
21 I wanted to at least try to distinguish between 22 stylistic behavior that -- in which there are wide 23 latitudes of interpretation vis-a-vis intimidation, versus 24 specific and explicit behaviors that are easier to 25 classify and that increase the probability of the creation
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20989.0 186 BRT 1 of an intimidating climate. And that kind of behavior 2 would have attached to it threats, and the potential use 3 of negative sanctions. And I just wanted to make that 4 distinction.
5 , So, what people often might interpret and respond to an 6 aggressive hard autocratic style, and yet there's no 7 threat attached to it except it's aggressive and 8 autocratic.
- 9. They may not like it. They may feel intimidated. But 10 I want to distinguish between what goes on in the 11 perception and interpretation of the respondent versus the 12 explicit attempt on the part of the other person tx) coerce
( 13 and intimidate.
14 A (WITNESS RICE) I don't have anything to add to 15 it.
16 O Thank you.
17 on page 6 of the report there's reference to meetings ,
18 over the period -- I should say July 18 and 19, where 19 members of the study team met with Mr. Ippolito and Treby.
20 Could you describe -- maybe I should direct this to you, 21 Mr. Kaplan, could you describe whatever outlines or 22 guidelines were given to you by the staff as you set out 23 on your task here? This study?
24 A (WITNESS KAPLAN) Outline in what sense?
25 0 what guidance was given to you at that meeting,
.=
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- i. -- - - -
- .: -- = = -
20989.0 187 BRT 1 over the two-day period?
- 2 Perhaps it is the documents that we referred to earlier 3 in the afternoon, the exchange of letters and so forth?
4 A Maybe -- we have a couple of other people. I'm
~
5 not connecting with what you were trying to do. We were 6 there to try to get some sense of what the situation was, 7 what the needs -- what the situation was, what the NRC 8 needs were. We went down, for example, thinking that they
. 9 might,want us to determine'if.there had been cases of 10 intimidation. Once we got'there and talked with Ippolito 11 and Treby, it was made clear to us that, no, we were not 12 needed to. determine if there'had been individual cases of
() 13 intimidation. In fact, there was a group of attorneys 14 working on that and it was not something for us to do.
15 What they did need was some help in. determining if 16 there had been a climate, a pattern of intimidation.
17 I guess I'd have to check my notes to see if there were ,
18 other things. We talked about a -- a little bit about 19 what a report worli ;m. that things it could cover; what 20 findings -- you know, what kind of things would or 21 wouldn't be covered in a consideration of findings.
22 .Q Okay. Thank you.
23 A And I tested, incidentally -- Bill and Chuck 24 could tell you -- did a lot of testing to find out what 5 really were the bounds on this thing.
.=
4
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20989.0 188 BRT 1 O on page 6, in the third paragraph, there's a 2 reference to " direct and indirect evidence of intimidation."
3 , Dr. Margulies, could you just qualify that for me, what 4 is meant there by direct versus indirect?
5 A (WITNESS MARGULIES) Well, I think direct 6 evidence would consist of very specific content. An 7 example would be if we look at the '79 interview -- the '79 8 survey, and we get a lot of responses of people saying:
9 Boy, the biggest problem we have around here is fear of 10 retaliation, or the fear factor; then I think that would 11 be pretty direct evidence.
12 . The indirect evidence, I think, refers more to the '83
(' 13 survey, where not only was there a content analysis --
14 that is direct information -- but there was another level 15 of analysis that you might pursue with David Bowers, where 16 instead -- in addition to looking at the substantive 17 comments made by people on that survey, he looked simply ,
18 at the pattern of responses. Not the content but the 19 pattern. And that was an indirect indication -- indirect 20 evidence, we thought, of the existence of a climate of 21 intimidation. -
22 So, the specific methodology for doing that, I think, 23 is something you may want to talk to David about. But 24 that's indirect evidence.
25 A (WITNESS RICE) The kind of direct evidence that
- 7 e
a __ . . . *
~ ~ . . _ _ _ . ..__ s 20989.0 189 BRT 1 I was expecting to see was the kind that might -- might be 2 on either side of the fence. ,
3 For instance -- and we saw some of each of it --
4 terminations of people who had intimidated craft personnel.
5 And we saw evidence of that. I would' consider that direct 6 evidence that intimidation -- that a climate of 7 intimidation did not exist. Because that was done 8 promptly.
9 Termination such as possibility of Chuck Atcheson, 10 because he had allegated (sic) would perhaps be considered 11 another piece of direct evidence that a climate did exist.
. 12 Indirect evidence -- and I'm not disagreeing with Newt 13 because I think the answer is in the '79 survey. I didn't 14 even look at the '83 survey. I had no idea what was in 15 that. But the indirect evidence are -- direct evidence in 16 those studies. The indirect evidences are claims and 17 counterclaims and suggestions and fears and: Well, I was 18 uncomfortable; without really using the term or the phrase 19 " intimidation." Harassment as a general subject would be 20 an indirect evidence of the possibility that a climate 21 existed. That would be my -- --
22 I would say one other thing, and that is that this was 23 a goal of the study. So this was done before we knew 24 anybody had been fired or not fired or anything else.
25 This was what we were going to be looking for, direct and
.=
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6 20989.0 190 CRT 1 indirect evidence. I don't thi'nk we very competently, at 2 that point in time, knew what would fall in either one of 3 the categories.
4 Q Dr. Stratton?
5 A (WITNESS STRATTON) I dont think I have anything 6 to add to what has been said.
7 Q Just clarification. I believe you said earlier 8 that the depositions were reviewed 1ar you, Dr. Margulies, 9 as well as by you, Mr. Rice. Was -- did -- Mr. Kaplan, 10 did you review any of the depositions?
11 A (WITNESS KAPLAN) I'd say no. I have looked some 12 over but I wouldn't -- but I haven't -- and I've made a 13 few notes on some things that I have seen. But I don't 14 feel like it constitutes a review or a reading. I have 15 looked some things over, more to,get a flavor of what was 16 being said and how.
17 Basically, I'd say the answer is "no." ,
18 0 Okay. On page 8 of the report, in paragraph 2.2 19 -- under section 2.2, your report states that the survey 20 data are significant because among other things they 21 represent the opinions of most of the QA/QC personnel.
22 Is it fair to say that the 1979 and 1983 surveys were 23 representative of the QA/QC employee groups underlying the 24 two surveys? The employee groups whose members were among 25 the persons surveyed, or included in the survey?
se
1
- =
l 20989.0 191 BRT 1 A (WITNESS MARGULIES) Gee, I'm not sure if I know 2 what you are asking me. Let me see -- I couldn't tell 3 whether, at least some sample of the same people took both 4 surveys. Was that what you were asking?
5 Q No. No.
6 A I'm sorry. ,
7 Q Were they representative?
8 A (WITNESS KAPLAN) Were they representative 9 samples in both cases?
10 Q Yes.
11 A (WITNESS MARGULIES) I think it was -- was it the 12 total sample was 1217 It was almost -- it was not a 13 sample.
(sl It was the total population.
14 Q It was the total populations as defined?
15 A That's what I assumed.
16 A (WITNESS KAPLAN) One had like a 93 percent 17 response rate. Everyone was' interviewed. ,
18 A (WITNESS STRATTON) In that case they are 19 representative by definition.
20 A (WITNESS MARGULIES) Okay. It wasn't a 21 representative sample chosen. It was the total population.
22 A (WITNESS STRATTON) It wasn't a sample.
23 O Again on page 6, in the last paragraph, it 24 states "the individual findings of the team members were 25 ;cviewed and discussed by the team and integrated into
.=
~
20989.0 192 BRT 1 this final report. Certain data including perceptions of 2 a representative cross section of CPSES employees with 3 regard to the specific issue of intimidation were not 4 available." .
5 A (WITNESS RICE) Somebody hand me a copy of the 6 report -- okay. Sorry.
7 Q Where you refer there to the absence of a 8 representative cross section of CPSES employees you are 9 not, of course, referring to the employee groups that were 10 included in these two surveys? That's my question.
11 A (WITNESS STRATTON) No. What we are saying there 12 is what was not available to us. We are saying a 13 representative cross,section of CPSES employees with 14 regard to the. specific issue of intimidation --
15 perceptions of a representative cross section with regard 16 to the specific issue of intimidation were not available 17 to us.
18 Q . You are not making any reference there to the 19 groups that were included in these two surveys?
20 A (WITNESS MARGULIES) No.
21 A (WITNESS RICE) This is the information that 22 wasn't there. ,
23 A (WITNESS KAPLAN) No.
24 A (WITNESS MARGULIES) This statement, if I might, 25 is. simply our cwn honesty about what we had to work with
6
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20989 0 193 CRT 1 to be very clear about the nature of the data we worked; 2 that's all.
3 Q On page 13, actually a carryover paragraph from 4 page 12, the last sentence of the paragraph that carries 5 over from page 12. In referring to the limitations in the 6 data base underlying the report it is stated that ""a 7 survey of an accurate sample of individuals randomly 8 ' selected would result in more representative data which 9 would permit more definitive conclusi'ons to be drawn.".
10 Was the data that you had available to you sufficiently 11 representative to form the basis for the report's 12 conclusions?
13 A (WITNESS RICE) We believe it is; yes.
14 Q Dr. Margulies?
15 A (WITNESS MARGULIES) Yes. I believe so.
16 Q On page 15, the last paragraph, as well as the 17 table 1 on page 16, the report concludes that the number ,
a 18 of allegations is relatively small and that a small number 19 of allegers and few management personnel have been accused 20 of intimidation.
21 Considering the magnitude of Comanche Peak, the 22 construction project, the nuclear power plant under 23 construction there, and the size and complexity of the 24 workforce, I take it that your conclusion is that to 25 reflect a climate of intimidation, the numbers on page 16 l
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20989.0 194 CRT 1 would be significantly greater. Is that a fair statement?
2 A (WITNESS RICE) That's correct. .
3 Q Is that a fair statement, Dr. Margulies?.
4 A (WITNESS MARGULIES) I would agree.
5 A (WITNESS KAPLAN) Would you make that statement 6 again? I'm not so sure I agree.
7 Q I'll be happy to. My question: Considering the 8 project, its magnitude, the complexity of the. task, the 9 complexity of the workforce, if a climate of intimidation 10 had existe'd or exists now, you would expect the numbers on 11 page 16 to be of a significantly different magnitude; is 12 that correct?
13 A (WITNESS KAPLAN) I'd say not necessarily. We've 14 tried to say that there might be circumstances under which 15 these numbers could be small. But it depends on what the 16 cases of intimidation were; you know what those -- that 17 few number of cases were. So we are not saying that they ,
18 just had to be a greater number for there to be 19 intimidation.
20 A (WITNESS STRATTON) A good example is, if you had 21 perfect intlmidation you'd have no allegers.- But -- so 22 none at all doesn't necessarily mean there's no climate.
23 0 okay.
24 A What we said here is there doesn't seem to be a 25 large number. And if we are looking at that one aspect,.
. -- ~-. - - - - . - - -
20989.0 195 CRT
, I we don't see a large indication. But we are not willing 2 to say based on these numbers alone there's a case there, 3 prima facie or, you-know --
4 MR. TREBY: No legal terms. .
5 DR. STRATTON: Or open and closed.
7 Q On page 19, section entitled, " promptness of 8 reaction to allegations."
9 Pardon me, the next section, under " independent of 10 investigators." You state -- the report states that -- a 11 finding of a strong interest of concern on the part of the 12 management to deter any intimidating behavior and to try
[
s-13 'to resolve such issues." I'm sorry, it is the first 14 section that begins at the top of that page.
15 Could you elaborate, Dr. Margulies, on that finding l
16 there? I 17 A (WITNESS HARGULIES) Do you want to? ,
18 A (WITNESS RICE) Which sentence are you on? I.
19 think the ball is in my court.
20 MR. HIRSCHHORN: The second half of that 21 sentence. --
22 A (WITNESS RICE) The second half of the third 23 paragraph beginning "in addition inspectors noted feelings 24 about losing credibility"?
25 MR. HIRSCHHORN: The last sentence?
~
20989.0 196 BRT 1 A " Interviews were extensive, documented and 2 indicated a strong interest and concern on the part of the '
3 management - "
5 Q That's right.
6 A Let me tell you what basically was behind that.
7 A concern was raised about pay and policies of that type.
8 At the same time the NRC had indicated that they had 9 gotten some concerns brought to them, as I recall, related 10 to the morale problems within the QA/QC organization.
11 As soon as this came to them, as I recall, Billy 12 Clements said: All right, let's puts together -- let's go 13 take a look at this and find out.what the problem is.
14 It appeared to be a very prompt reaction, to us.
15 The questions were put together, whether they met all 16 the criteria that Mr. Goldstein would like to see, or I 17 suspect Newt might like to see, too. They were a ,
18 reasonable set of questions and an independent team was 19 put together, sent out to interview people and to get
- 20 responses to the concerns.
21 Q I would like to refer for just a moment to the 22 question of the independence of investigators, which is on 23 that same page and continues on to page 20 as well.
24 I take it that the study concluded, based again on the 25 data that you had presented to you, that the persons
_ . . _ _ _ . _ _ _ . . . _ . _1 ._ - - - - - - - -
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20989.0 197
[RT 1 investigating intimidation claims had been given, by s
2 management, the independence to complete their work in an 3 objective manner; is that a fair statement? Dr. Margulies?
4 A (WITNESS MARGULIES) Yes.
5 Q Mr. Rice? -
6 A (WITNESS RICE) Yes.
7 Q Thank you. On page 20, the ne,xt to the last 8 paragraph, the sentence reads: "It appears that the 9 report is thorough and detailed, indicating the serious 10 attempt on the part of management to deal with the issues 11 at hand."
12 Without the clause "it appears that," would the 13 sentence have the same intended meaning? Maybe I should 14 direct that to Dr. Stratton?
15 A (WITNESS STRATTON) I don't know if you should.
16 I don't think it's my piece of work so -- I didn't draw 17 that conclusion by looking at the original data so I don't ,
18 know that you should ask me that question,
- 19 A (WITNESS MARGULIES) It's the kind of thing that 20 I know I would say.
l 21 A (WITNESS RICE) In this case, I think I was the 22 one who said it. .
23 Without going through it yourself and and interviewing 24 people and so forth and so on, it is very difficult to say 25 that it was completely thorough or completely detailed.
O w
20989.0 198 CRT 1 It's a little bit of a weasel word, I admit. But in the 2 absence of all the supporting background it was the best I 3 felt I could say.
4 A (WITNESS MARGULIES) Sure. I agreed with that. -
5 I agree with it.
6 A (WITNESS RICE) I put on my theoretical hat for 7 you.
8 A (WITNESS MARGULIES) I like that. Nothing is 9 black or white; that's the thing.
10 MR. TREBY:, Would now be an appropriate time for 11 a two-minute stretch? ,
12 (Discussion of f the record. ) ,
(f 13 *
.MR. DU BOFF: I have just a couple of more 14 questions. It was a useful break. It served the useful 15 purpose of eliminating several questions.
16 DR. STRATTON: Let's have another' break.
17 (Laughter.) ,
19 Q Could you describe, Dr. Stratton, the continuing 20 process of evaluating data for us briefly again?
21 Elaborate on that, perhaps, for me what you 5re doing now,
~
22 what you expect to be doing in the next few months, for 23 example, with any additional data that is submitted to you 24 by staff?
25 A (WITNESS STRATTON) Essentially what I see is
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20989.0 199 ERT 1 happening is that all of this data that comes in, Newt and 2 Chuck are reading through it, since they are the people 3 who read all of the data before, they are continuing to 4 read through it. Newt is updating his for example -- for 5 example that chart on page 16 which enumerated his 6 findings based upon, I think at that point, 65 depositions 7 and some reports -- that's continuing to be updated, s 8 A (WITNESS MARGULIES) Right.
9 A (WITNESS STRATTON) So that essentially, my 10 expectation is, my personal expectation is that so far we 9
11 have had another slug of depositions come in. The numbers 12 haven't changed appreciably. My expectation is that they
() 13 probably won't. But they are reading all of that stuff to 14 just see that, you know. A big surprise could come in, I 15 suppose.
16 Q Now, not only have the numbers not changed but 17 your qualitative response to the data has not changed ,
18 either; is that correct?
19 A (WITNESS MARGULIES) Let me tell you where I am, 20 because it's what I was saying to Tony earlier. I hedged 21 on the question because I really can't -- I don't have 22 enough to say. But I have almost completed the updating 23 of the data on page 16. Okay? I'm very close to that.
24 That's number 1. And I should have that completed fairly 25 quickly.
9
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! 20989.0 200 BRT 1 While I have started reading the testimony, I have not,
! 2 and will soon, get into some kind of categorization of 3 that information and see how that's going to affect the 4 basic conclusions in this report. And I will just keep, 5 you know, working on that and feeding that to Bill.
6 So the survey data is intact. The depositional data is 7 very close. I have the testimony data to look at plus, l
8 Stu has now promised me a whole new stack of OI reports, 9 which I'm not too happy about. We might divide up some of 10 that work between Chuck. But'we will just continue to 11 update this and feed that in as we go.
12 Q Okay. At page 27 of your report -- actually l
l q 13 pages 26 through 28, your analysis of the -- content 14 analysis of the 1979 survey --
15 A (WITNESS MARGULIES) Got you.
16 Q I'm referring to the questions in particular 17 that you focus on'in that discussion. ,
18 A Right.
19 0 You conclude there that the data did not -- and 20 I'm directing this to both Mr. Rice and Dr. Margulies --
21 A (WITNESS RICE) Actually you are referring here 22 to Newt's analysis.
23 A (WITNESS MARGULIES) That was mine.
24 Q Okay. Fine. Thank you. Your conclusion is 25 that the responses did not show a pervasive climate of O
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20989.0 201 BRT 1 intimidation?
2 A That's correct.
3 Q Were the -- were the questions themselves an 4 appropriate means of eliciting data in connection with 5 that -- the question, the underlying question?
6 A Well, I felt comfortable with the questions 7 .themselves. I'm not totally 100 percent comfortable with 8 the survey -- with how the data was generated. But I'm 9 totally comfortable with the questions.
10 The survey -- other experts might have a different 11 opinion -- that wasn't a supersophisticated survey. But 12 it wasn't a bad survey. I mean it was moderately good.
13 The questions from an organizational point of view that I 14 thought were relevant -- there were questions about what 15 makes you uncomfortable about your job?
1 16 I would expect if someone was uncomfortable about the l 17 kind of pressures, intimidating kinds of pressures, that ,
18 they would say some things that would even hint -- hint at 19 that.
20 There was a question about supervisory support. I 21 thought that was important. -
22 And there was a question, number 5, that was really 23 more open-ended, that said: What kinds of problems do you 24 see at Comanche Peak? List them out. Tell us what the 25 problems are.
e'
20989.0 202 BRT 1 So I felt there was a lot of opportunity in those 2 questions to hint at intimidation. And, indeed, as I 3 indicated earlier today, one item was, in fact -- one 4 person said " fear. factor."
5 But, as I said, I didn't see a predominant amount of 6 that stuff as I analyzed those questions.
7 Now, as I say, I'm comfortable with the questions. I 8 think they are ope *-ended enough that they would have 9 generated the right kinds of information or hints or 10 inferences about that. I didn't see it in here.
11 Now, whether the data would c'hange if information was 12 more anonymous or confidential or whatever, I can't
(, 13 predict. I dont know.
14 But given this data set, I like the questions and -- by 15 the way, also I said this afternoon, people were not 16 bashful. I mean I got a lot of data. They were not 17 bashful about the problems.
18 But given what I had I thought they were very good 19 questions.
20 Q They were very good questions?
21 A I thought so. - -
22 O You were shaking your head?
23 A (WITNESS RICE) I was nedding my head.
24 0 Pardon me. Nodding.
25 Did you have anything you wanted to add?
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20989.0 203 BRT 1 A I agree with Newt. I think I said earlier we 2 took a slightly different set of questions. There was 3 sufficient amount of overlap. And Newt and I discussed 4 when we were trying to reconcile the report: Why did he 5 take this one and why didn't I take that one and why did I 6 take this other one. And I think from our perspectives 7 there were very good reasons to have taken different 8 questions. And our conclusion was exactly the same, that 9 we didn't see a pervasive intimidating climate as a result 10 of it.
11 As a matter of fact,' when you talk about the openness 12 aspect of it, at least one inspector in that particular
~
(_ 1,3, one said a craft person had grabbed her and said: You 14 will do something, caught her by the lapels and shook her, 15 and they asked would she carry that up the line? And she ,
16 did. And they were on the verge of terminating the guy.
17 I'm not sure why she talked them out of it but ,
18 apparently, according to the testimony, she talked them 19 out of firing the guy that had attempted to intimidate her.
20 They were perfectly willing to, as Newt says, they were 21 perfectly willing to say what they had on their minds as 22 far as I could tell from the survey.
23 MR. HIRSCHHORN: Thank you. That's it.
24 MR. TREBY: Fine. We will convene tomorrow '
25 morning at 9:00 in this room. Dr. Bowers will be 9
9
20989.0 204 BRT 1 available at that time. And, as I underst$nd it, we'll 2 have an hour per party with regard to Dr. Bowers and then 3 we'll have an hour with each party with regard to'anybody 4 they want.
5 If any party decides they don't need an hour with 6 Dr. Bowers, you can save that time for whoever you want.
7 MR. ROISMANi Do I understand the order tomorrow i 8 will be the reverse of today?
9 MR. WATKINS: That's correct. We go first. I 10 guosc we go first twice.
11 MR. TREBY: You go first.
12 (Whereupon, at 7:50 p.m., the hearing was
' i (j 13 adjourned, to reconvene at 9:00 a.m., Friday, November'9, 14 1984.) T 15 1
16 17 j 18 19 20 21 --
22 23 24 25 S
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CERTIFICATE OF OFFICIAL REPORTER This is to certify, that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of: .
NAME OF PROCEEDING: TEXAS UTILITIES GENERATING COMPANY, et al.
(Comanche Peak Steam Electric Station, Units 1 and 2)
DOCKET NO,: 50-445-OL2; 5 0-4 4 6 -OL2-PLACE ' BETHESDA, MARYLAND
- k.
- DATE: THURSDAY, NOVEMBER.8, 1984 ,
were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
_(siet)
(TYPED)
JOEL ' BREITNEli' Official Reporter ACE-FEDERAL REPORTERS, INC.
Reporter's Affiliation eeem O
O
bec: B. L. Barnds E.qKapIa7 C7F'. ObenchainC B. P. Warner g
g EGsG .
Central File L. P. Leach File P C. SCX 1625, loAHO FALLS. toAMO a3415 August 28, 1984 ~I -
lP4 W -
Mr. F. L. Sims, Director Reactor Research and Technology Division .
Idaho Operations Office - 00E Idaho Falls, ID 83401
- TRANSMITTAL CF LETTER REPORT " COMANCHE PEAX STEAM ELECTRIC STATION:
ALLEGED CLIMATE OF INTIMIDATION" (A6819) - LPL-373-84 Ref: G. E. Marx ltr to S. B. Milam,.". Transmittal of Revised NRC Form 189 For Evaluation of Selected NRC Ocen Items Before Plant Fuel Load (A6819) ar.d Evaluation of Selected Open NRC Activities at NTOL Sites _Needing Action Before Plant Fuel Lead (A6821)" -Marx-E62-34, August 16, 1984
(
Dear Mr. Sims:
The attachment documents EG&G Idaho's investigation of the management climate with respect to employee intimidation at the Cemanche Peak Steam.
Electric Statien (CPSES). -
EG3G Idaho assembled a team of individuals with broad experience in the nuclear industry and specific knowledge and skill in management and organ-
~
ization to conduct this study. An additional researcher with expertise .
in rurveying organization climates and analyzing survey cuestiennaires was selected to perform an independent arjalysis of a set of relevant survey data. The team established a working definition for a climate of intimi-id,at,ica and, than assessed the reports,' depositions, survey data, and ether infcrmation available. Key findings were that the extent of alleged intimidation was limited, and that people did feel free to express their cpinions. CPSES showed a strong concern abcut intimidati,ng behavice, and generally followed with corrective action. Specific management problems were identified and judged significant; however, these factors cid not con-stitute a climate of intimidation. The study team concluded that a climate of intimidation did not exist at CPSES.
i 4
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July 25, 1984
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Dr. David Bowers .
. Institute for Social Research . . .
426 Thompson .
University of Michigan -
Ann Arbor, Michigan 48109
Dear Dr. Bowers:
I as writing to you on behalf of 3ruce Kaplan who is on vacation for the next week. He wanted me to express his pleasure at your accepting a role in our current project with the Nuclear Regulatory Commission. We tre especially appreciative of your willingness to respond within our rather tight time constraints.
First, by way of introduction, I would like to give you some background information regarding the project. At a nuclear power plant nearing completion, allegations
'tava been put forward by a number of individuals involved in the QA/QC area (Quality
' Assurance / Quality Control) that management created an atmosphere of hetimidation during construction of the plant which inhibited QC inspectors from perfor=ing their duties according to written standards and regulations, to the extent that the safety of the plant might be compromised. In the context of issuing an operating license to this plant the NRC 1s taking depositions from those alleging irregularities and from the applicant conpany in anticipation of a formal hearing.
These depositions are being reviewed by a team of experts from both the nuclear
' industry and academia to make a judgment, as to the accuracy of the allegations.
. . s=*
As part of their own management of the situation, the applicant company conducted ,
a survey of its QA/QC personnel in an attempt to deter =ine the atmosphere / climate in which they perceived themselves to be operating. A copy of the set of returned questionnaires has been sent to you for analysis. It is =y understanding that you and your staff will undertake an analysis of the responses and draw whatever conclusions you can reasonably make from them. This study will include a statistical analysis of the checked responses and also analysis of.the open-ended remarks that respondents made on the survey forms. *
- The basic ' question you are to attempt to answer ist Did manage =ent by its actions create an atmosphere of intimidation for the QA/QC inspectors such that they perfomed their duties in such a voy that there is seme likelihood that the plane may be unsafe. This is distinct from intimidation that some inspectors may have f elt from actions on the part of gaig personnel. The intent.is to establish if -
a pattern of intimidation existed, as opposed to whether certain individuals were in fact intimidated. There is also some distinction to be made in terms of what is really a climate of intimidation compared to what might be described as a fairly hard-nosed management style in the planc. .
This issue of a definitica of " intimidation" should be considered. Naturally the applicant co=pany tends to see all its actions as canagement style. The allegators tend to see all these sa=a =anage=ent behaviors as inti=idation. A third view is to define intimidation an involving some violation of written procedures for construction, inspecting, or testing due to some incident, action, or state =ent on the part of management. It is this th(id view that is probably the =ost useful and applicable dtfinition. In any case, an explicit definition of climate of <
intinidation should be included in your report.
- 8
., t a.-
Mr. F. L. Sims August 28, 1984 LPL-373-84 -
Page 2
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This work was funded under FIN A6819 (Reference). -
Very truly yours, C%ej~;_
.' hL.P. Leach, Manager NRC Technical Programs Division CF0/act
Attachment:
As Stated ,
cc: T. A. Ippolito, NRC
- 5. A. Treby, NRC M. H. Williams, NRC J. O. Zane, EGaG Idaho (w/o Attachment)
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4 Mt. F. L. Sims August 28, 1984 LPL-373-84 Page 2 I
This work was funded under FIN A6819 (Reference)
Very truly yours,
.O $ h c / o _* _
L. P. Leach, Manager NRC Technical Prcgrams Division CF0/acf
Attachment:
i ,
As Stated . .
cc: T. A. Ippolito. NRC ,
S. A. Treby, HRC M. H. Williams, NRC J. O. Zane, EG&G Idaho (w/o Attachment) *
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7:q W. Stratton Central Files A..
L. P. Leach File July 31, 1984 y ps v 17 Mr. F. L. Sims, Director Reactor Research and Technology Division Idaho Operations Office - 00E Idaho ' Falls, 10 83401 TRANSMITTAL OF TASX TEAM DESCRIPTION AND QUALIFICATIONS, AND TASK SCHEDULE FOR COMANCHE PEAK MANAGEMENT ISSUES TEAM - LPL-339-84 Cear Mr. Sims:
Pursuant to a verbal request frem the NRC, Divisien of Licensing, the subject information is transmitted herewith. The attachments include a summary of the bt.ckground of the task,. a description of the task team assemoled, resume's of the principal task team members, and the task schedule.
, Very truly yours, c /
L. P. Leach, Manager NRC Technical Programs Division CFO:eb Attachments:
- As Stated cc: M. H. Williams, NRC-OL J. O. Zane, EG8G Idaho, w/o Attach.
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LPL-339-84 Pa 31 of 34 SACKGROUND, TAsr TEAM OESCRIPTION AND QUALIFICATICNS, AND TASK SCHEDUL The Overall Task ,
This project team has been assemoled to investigate and form an opinien regarding allegations of intimidation of inspection personnel on the part of management at the Cemanche Peak power plant. Allegations have been put forward by a numcer of individuals involved in the QA/QC area that management createo an atmosphere of intimidation during construction of the plant which innibited QC inspectors in the performance of their duties according to written standards and regulations, to the extent that the safety.cf the plant might be compromised.
In the centext of issuing an operating license to this plant the NRC is taking depositions frem those alleging irregularities and from the-applicant utility in anticipation of a formal ASLS hearing. These cepositions, plus several NRC Office of Investigations rescrts, a Cemanche Peak Special Review Team Repert and other recorts and data seen as relevant to making a judgement concerning charges of management intimidation constitute the data to be reviewed by ne pro,%ct team.
(. *
' As'part of its own management of the situation tne applicant conducted a survey of its QA/QC personnel in an attempt to determine the atmosphere er climate in which they perceived themselves to be operating. These survey responses are aeditional data to ce reviewed by the project team.
The basic question the team must attempt to answer is: Die management by its actions create an atmosphere of intimidation for the QA/QC inspectors such that they performed their cuties in a way that there is scme likelihood of impact en the safety and quality of the plant. The intent is
'to estabitsn if a pattern of intimidation by management existed. This is distinct from whether certain individuals were in f act intimidated, or frem any intimidation that seme inspector may have felt frem actions on the part of craf ts persennel. A climate of intimidation must be considered also as distinct from what might be described as a fairly, hard-nosed management style in the plant.
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The Team Assemeled .
Bruce Kaplan is the task team l'eader in charge of overall coordination of this project. Bruce has a masters degree in Organization Development and has been involved with management issues as an internal consultant for EGM Idaho, for a period of 'six years.
William Stratton, an associate professor of management.at Idaho State Universi*,y and who has worked previously with EGM Idaho as a consultant, will be involved as an interim coordinator while Bruce Xaplan is unavailable and will contribute to pulling the separate parts of the review together for the final integrated report to be submitted.
The project coordinators in consultation with NRC personnel reached the conclusion that tne individual (s) selected to review all the data to cetermine whetner a climate of intimidation existed at Comanche Peak snould possess expertise in organizational behavior and the functioning of large and complex organizations and also have expertise it the particular milieu (f of the nuclear power industry. As a result it was decided to recruit one nationally prominent ceganization behaviorist with consulting and research experience in large-scale organizations and, in addition, to recruit another expert with broad experience in the nuclear industry.
A review of a list of organization specialists suggested by HRC personnel, colleagues of Bruce Kaplan working in the field, and prominent scholars in
, the area of organization behavior, coupled with the specific time availability' of those suqqested specialists who excressed interes,t. in the, project, was conducted. The individual's chosen for the project are Newton Margulies, Dean of the Graduate Schcol of Management at the University of California at Irvine, and Charles Rice of LRS Consultants of Idaho Falls.
Idaho. Dean Margulies is especially well qualified for the project in terms of his past research and consulting experience. Charles Rice has had extensive experience in the industry. A resume for each of tne consultants 1
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. 4 .
is enclosed as' an attachment. As mentioned above, part of the data to be analyzed by tne team is survey data collected by the acclicant from their QA/QC perso'nnel regarding the climate within which they worked. An active .
expert was sought to render an independent analysis of the survey response. Dr. David Bowers of the Institute for Social Research at the University of Michigan, a nationally recognized expert in both the surveying of organizational cliimate and survey questionnaire analysis was-selected to perform this analysis. A copy of his resume is also attached.
The project Schedule The seneduling of project tasks is highly constra'ined by, the f act that depositions from those alleging irregularities and from the applicant will be taken througn August 3,1984, and a final report.for submission te the hearing board must be complete on August 20, 1984 The schedule in further compressed.by the need for NRC to receive a draf t report on August 10, 1984. Copies of the data on han'd are being distributed to the expert
( ,
, consultants and copies of the depositions in progress are to be forwarded as received. The project has been divided into tasks wi.th fixed dates for their etmpletion. A copy of the project task schedule is attached.
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. .., SCHEDULE KEY
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- 1. EGar tdaho work plan approved. ,
- 2. Depositions. received by team members and review initiated. .
- 3. NRC Staff decision on plan.
- 4. ' NRC Staff agreement to implement plan.
- 5. Final set of depositions received by' task, team.
- 6. Task team completes review of all depositions received.
. 7. Begin writing draft report on team evaluation (atmosphere of intimidation). .
- 8. First draft of " atmosphere of intimidation" received by the NRC from team ( August 10). .
,9 . Utility surveys received by consultant, Dr. Bewers.
(,, TO. Bowers analysis of survey received by EG1G Icaho.
- 11. Final NRC legal comments on draft report received by EG&G Idaho.
- 12. Final report submitted by EG&G Idaho to NRC Project Director (Ippolito).
- 13. Team begins review of prefiled testimony ( ASLS hearing).
- 14. Team completes review of pre-filed testimony. ,
- 15. EG&G Idaho provides team commen'ts on pre-filed testimony to NRC.
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- 16. ASLB hearing begins.
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BRUCE KAPLAN
\s.
P.O. Box 198, Williamsburg, MA 01096 4T3/268-3564 SumARY :
Broadly experienced, professionally educated, consultant to orgrai-zations, worked creatively in private and public sectors. Skilleo i
in' full range of organizational development technologies, including, but not Timited to strategic planning, organization design and trans-sition management,, human resource planning and management developme
. fnterpersonal and intergroupL Con [liCt management, team DUi} ding, ,
survey feedback and business research. Enables. people in organizations to increase productivttyyhile improving quality of working life. ,
WORK EG&G, Idaho, Inc., Idaho Falls, ID 8340T EXPERIENCE : ORGANIZATIONAL SPECIALIST 6/78 - 6/82 Estab11shed'first internal consulting function in high technology firm (4000 employees) conducting engineering development activities in areas including nuclear, solar, hydroelectric, alcohol', and fusion technology.
Earned confidence of managers and employees. at all levels of administra- ,
of sensitive informatfort.tive, technicai and. scientific organizations throu Assur'ed that key people identify and -
develop specific skills. for becoming more effective in their roles and -
impact organizational performance.innovatively apply these skills
,. CurrentTy. introducing results oriented pfTot program. management systecr quality of work Tife pro,iect,. and. =*=ted s .
Case Westerrr Reserve University, Clevelantt OH-INmuCTOR - ORGANIZATluNAL PSYCHOLOGY g/77 - 5/73 Designeddegree graduate anit conducted programs. training progs m for engineers and managers irr By their creating fresh solutions to actual i organizationni problems,. participants gained insights into practical application of Behaviorat Science thacry. *!'
Indtana state Board of Ecucation. Wtanacolts, D6-SIAE GEMELOPP.EW CO 4RDINATOR.
- T0/75 - 5/77 Southeastern Indtane Vocational ~ Schools (SIVS) VersaiT1es, IN9/76 - 5/77 Consultant to professional and para-professional sta,ffs in three
! counties concerning individualized program design,. enrichment of i traditional curricula, effective use of all resources. Assured i successful . practtcal application of program's learnings for all l students enrolled. l COMMUNITY AGENT f/76 - 5/77 Consultant for numerous business and social service agencies establishing an effective referral / communication system between SI*.'S and these organi:ations. Developed a synergy betweert business education and social service institutions, whereby human resource p,otential of I
.j-
- employees. and clients were better identified and utili
- :ed. Promoted -
to Staff Development Co-ordinator (above). ,
i j
_ _ _ _ _ . _ _ _ _ _ _ _ - _ _ _ if _ _ __ _ _ _ _ , .
=
q, ADULT EDUCATION PROPESSICiML
~
10/75 - 5/77 Recruited, trained and counseled adult education clientel from wide range of ages, educational backgrounds, social strata and nationalities.
Enabled some to gain high school diplomas, others to learn practical skills such as home budget balancing and business report writing.
Promoted to Community Agent (above). .
!!ew Morning : a learning community, Cincinnaci, OH 6/71 - 5/75 CD-DIRECTOR & COUMSELOR
. General managh of this independent education institution which used the city as a learning environment for 70 students who shared in designing their bwn study programs. My joti was to set-up mechanisms for the individualized learning program (simitar to M.B.O.) and facilitate achievement of these objectives in accord with state standards of performance. Insured high quality policy decisions and broad based coumittment to success through use of " town-meeting" design, in which al.1 members (parents, ' students, faculty, and com-munity resources) could express their views and reach consensus decisions. Also facilitated merger between laree segment of this institution and the Cincinnati Public Schools (CPS), an action which
, gave CPS its first a.lternative progrant.
PRIOR Prior to 197T,. I was employed as teacher of Science Health with the
,, EXPERIENCE . Cincinnati. PubTic Schools y Cincinna.ti. Ohic.
EDUCATION : UNIVERSITY OF CINCINNATI, B.A.
s 1969 Pre-medical pwgram with major irr Cheeristry, with minor in Gennan.
Vfee-President, Young Friends of the Arts. Deans List,. Honors
. Chemistry . Academic Schelarship For Work.-Study in Hamburg, Germany.
CASE-WESTERN RESERVE UNIVERSITY 1978 Graduate Studier trr Department of Organizational Behavior,, School of '
Management Courses included Organizational Sys'es, Personality .
Theory, Interpersonal Analyrir, Sectal AnsTysis and Inquiry patroductta M beer *h , ,
PEPPERDINE UNIVERSITY, M.A
- 1981 l
Degree awarded August 1981'.. Courses included Consultation Skills, Organizational Systems Otagncsis, and Accion Strategies, including Management Development and Human Resourca Planning.
PERSO,NAL : Married Excellent Health
- Available for Travei Agressive . ,. . Flexible . . . Energetic . . . Rescurceful i
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,, / Vo v/Y l
- s. . WILLIAM E. STP.ATION, Ph.D.
CURRO!T POSITION Assoctate Professcr College of Business Idaho State Undyersity Pocatello, Idaho 83209 Phone: 208/235-3535 '
Personal Daa:
Birth Dater March 5, 1941 Ecme Address: Birthplace: Akren, Ohio 17 Columbia Marital Status: Married, 3 children Pocatells,. Idaho 83201 9 4mi Security No.: 297-34-9506 Phone:.208/232-6093 Health: Excellent EDUCATION
- Case Western Reserve University, School of Manage =ent, Cleveland, Chio 44106 1974, Ph.D. in 0 ganidatien Behavier, H.E.W. Felicw 1969-1973 l
Carnegie Hellon University, Pittsburgh, Pennsylvania 15213 1965, M.S. in Industrial L**Mation 1963, B.S in Mechanical Engineering, with hcnors, Westinghouse Scholar P;ur miuNAL Ar - m%'" IONS.
,. Tne Acacemy of ManagM .-
American Sociclogical A"?d stic:t . ,'
7(, '
Ameriesn Society' for 1~.ue.l. W~+ Men s American Society for Training aM Develo;; ment Tau Beta Pi'- Natic::al Engineering Hee -y -
Pi Tau.Sig== - Naticnal Mechanical Engineering Hencrary Beta Ga:::::a Sis =a - Nati:nal Business Ecncrary ACADD{IC r.J e.:u :.; ICE Idaho State Universityt (1974-present) c:.:rrently te:n ed as an Associate Professor teaching in the- Ma:uigement area 4*1 -
t uing courses in Individual and Organiza-H==1 Sebavier, Organizatien Theery,. Industrial Reistiens, and Organization Develc; ment, at both the gre=% a:rd undergraduate levels. 17p 2.-M - A<Tw 4 sad Chse Festern Teserve Universdtyr (T959' 1974) f. aught ces:rses in group dyru=:ics, interperscr:al behavier, and. u gd a'Md behavice en both the undergracuate ard graduate Iev+4 as a. grad = ate- fellcw Cleveland State University: (1972-1973) taughtPerspectivesenF3cialProcesses in the Depart =ent cf' Sos-N Services.
NON-ACADD'.IC DL" CYMDii' 1969-1970 City of Cleveland, Department of C-J.ty Development, Cleveland, Ohio. Wcrked as a syste=s analyst with c:anagers within :ne department to im-p ve the efficiency and effectiveness of their divisiens.
.C- 1966-1969 Peace Corps Volunteer. Served as a volunteer in Colcchia, South America, working in rural agricultural and c::cmunity development projects,
( primarily the establish =ent of cooperatives for the selling of consumer goods and the production of agricultural products n uency in Spanish achieved during this time.
'UELICATIONS .
1983 " Program. Ev=1r=Mm: ne State of the Art", currently submitted for publication.
198T
" Moral Development and Decision Making: A Study cf Student Ethics,'" Jeurnal of Enterprise Management, Vol. 3,. No. T (7981), pp. 35-47, (with George A.
Jonnsen anc. W. 2ancolph n ynn) .
"M=9g Pr21em E=ployees," Hu=arr Rescuree Manarecent, Vol. 20, No. 2 (Sucmer 1981), pp. 28-32. . (with W. Rancolpn Flynn) 1980
" Managing Turnover in High Technology Industry," ne American Society of Hechanical Engineers, 345 E. 47th Street, New York, NY 10017, ASME Publicatierr Nu=ber 80-WA/Mgt-7 (presented at. the ASME Winter Annual Meeting, Nove=ber 1980), (with W. R. Flynn)
- Ecciogical teory and Organi=ation Develc;: ment," Chapter 13 in Syste=s Thecev fer Orranization Deve1cceent, h= G. Cumings (Ed.), Jchn Wiley & Sens,
, Ltc., 19eo, pp. 307-323. (with Warren R. Flynn)
'-[K- d "N&.g VoL.an Ineffective Ecss into a..Model Manager," Suoerviserv Management,
.M, No 7 (July 1979), pp.14-20, (with W Ranec1pn Flynn) s 1978 "The R*1=Mm*4ps k:ccg Teaching Style, Student Learning Style, and Perfor-mance,." h dirr.cr,. Tenttr Arn:al Meeting of" the American Institute for DeH *d e:r Sciences (AIDS), October 30 - Nove=ber 1,1978, St Louis, Missou-1 Vol. T, pp. 137-139 (with.Gecrge A. Johnson and W. Randolph Flynn)
' "The Need for Management Development in Health Care Institutions," Hescital Tecies, Vol. 56, No. F (September / October 1978), pp. 25-31, (wita W. Ran '
colpn Flyr:n) l "Learnin2; S::yle and Perfer=ance,.5 pr 186-192, irr hcIcrinz Erne-tential t m t
,Qig. Ne% se:t Dee:-icrrht hereises, Dartzel C. 2.wm1 anct Sa=uel C Certe (ecs ), hm%ss cf une. Fifth An:nial Conference of the A*S~ 4 ed m fcr Eusiness ht1=tien and Experiential Learnirs (ABSEL), April T2-14, 1978, Denver, Colcrade. P 91 M ed by the. Bureau of. Business and Ecccc=ic Research, Cellege of Business Ad=inist ation, Ari ena State Univer-sity, Tempe, Art:cna- 85231. (with George A. Johnsen) 1
', " Dealing with Ag.ressive E=ployee Behavier," he ?e sennel A :inistrater, Vol.
23, No. 2 (February 1978), pp. 53-53, (witn Warren A. Flynn) 1974 "he
~ Devele ent cf Interagency Cooperation," Social Service Review, Vol. 48, Nc. 3 (Septe=be- 1974), pp. 412-421, (with Joca L. A a=)
l l
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\ . _ _ _ _ _ - - --
ed 14 N
.A Universa.ty Ccemittees:
( Faculty Council - 1977-1980 , M F4 -
Member - Execut'.ve Ccamittee - 1979 Chairman - Elections C:cuittee - 1979-1980 University Advising r***ee - 198T-1982 University', Budget ree41 - 1982-present ,
College of Business Dean Search Ccumittee 1981-1983 College of Business Cccmittees: ,
Research Ccanittee - 1974-present .
Currir"'1'= Ccazittee - 1974-present MBA Program Ccanittee - 1976-present Workshops, Seminars, and. Short Courses Ccucittee - 1974-present Prtzmotiorr and Tenure Camd.ttee - 1976-1977, 1983-pres e Advisor to Alpha Kappa Psi - T977-1982 -
CONFERENCE PRESENTATIONS .
1983
" Change irr Business Schools-Past Predictions and Future Expectations," Mountain Plains Management Conference, Grand Canycn, Arizona, Oc*wber 2C-22,1983.
1982
" Making Sense af Training Evaluatierr,* American Society for Trair.ing and Develo;nent, 2fi,. 1982. Regiorr VIII Conference, San Francisco, California, October 22-
" Effective r-le**m* and " Management Tools-Goals, Priorities, and Plan-
,'~'t ning,.* tus presen**+e, at the 1982 Annual Cww. lon,. Idaha Health Care A=~"=tierz, Pe= Ic,. Idaho, July 18-21, 1982.
"^'"**y s
Circles-Buyer BewareT* p mm.i.ed at the American %f =*y for Per-
- sonnel.
1982. AN %,1982 Idaba Corrferecce,. Twin Falls,. Idahc, May 17-18, "The Evaluation of' Trainirg Efforts," presented at the Twenty-Third Annual meeting, Colorado.
Western Academy of Management, Apt-il T-3,1982, Colcrado Springs, 198T "S'e tting Realistic Management Ob,1ectives," presented at the 70th An=ual Conven-tion of the Idaba Nurse: A**~:,. October 15-TB,.1961, Pocatello, Idaho.
' "14Akis Evalua s,*;7.wted at the Sbutheaster:1 Tdaho. Chapter, American Society for Training and Develop =cnt, conference on Improvirui; Pro-ducti.vity Thrcuh;h Training, Septecioer 29-30,1961, Pocatello, Idaho..
" Quality Circles. for PrtvhMvity I+ ovement," presented at the Treasure Val-ley Chapter, Anerican Society for Training and Develepcent, centerence en Improving Productivity: The Eu=an Potential, Septec:ber 16-18, 1981, Scise, Idaho.
"Evolutien of a Successful Preductivity I.~,n ove=ent Prog a=," p esented at the f ,Monterey, 22nd Annual Meeting of the- Western Acade=y cf Management, April 9-11, 1981, California. (with W. Randolph Flynn) l 9
w.
1980 " Managing Turnover in High Technology Industry," presented at the 101st Winter
!^ Annual Meeting, American Society of Mechanical Engineers, Novettber 16-21, 1980, Conrad Hilton Hotel, Chicago, Illineis, (with W. Randolph nynn) l \~ .
" Evaluation of a Management Skills Develo;x=ent Prov ." presented at the 22nd Annual Mountain-Plains Conference, Octcber 9-11, 1980r Fair::x:mt Hot Springs, Montana. (with. W. Randolph nym:)
~
"An Overview'of Productivity Issues and Answers," presented at the Idaho Ecspi-tal Associaticnr 47th Annual Convention, September 26-October 1, 1980, Sun Valley, Idaho. (with W. Randolph M ynn) .
"One Approach to Training Prograar Evaluatic::," presented at the Idaho Hu=an Resource Develo; ment Conference,. Septac:ber 26-27,.1980, Idaho State Univer-sity, Pocatello, Tda M _ (with W. RandoTnh R ynn)
American Society for Pauiel Ad=instratica (ASPA), Annual Ccnvention, June 17-20, 1980, Salt Lake City,. Utah. (Attended - No Presentation)
Westert Academy of Management, Twenty-First Annual Meeting, Phoenix, Ari cna, March 27-30, 1980. CAttended - No Presenution) 1979 "Edical Standards A=cng Ecsiness=e:T and Students: Pedagogical I= plication,"
presented at the Twenty-first Annual Meeting, Mountain-Plains Manage =en:
Conference,. Octcber 1T-73,1979 Jchnson and W Randolph n ynn) , Albuquerque, New Merico. (with Gecrge A.
" Supervise: 7 Develc; ment: A Elve Year Longi'*1 Study of Perceived Needs,"
presente:1 at the Twenty-first. An=ual Me 4ng,. Mm =in-Plains Manage =ent (s Conference,. O::teber 17-13, 1979, Albuquerque, New Mexico. (with W. Ran 4 yz .
'%:ral Devele;c:ent a=d Decision Making: A Study of Student E dies,* presentcd at the Twentieth. Annual Meeting of the Western Divisica cf the Academy of Manssm., Pcrtland. Cregen,. Apt-il 5-7,. 1979.(with W. Randcidph n ynn and George 1. Jchnson)
. 1978 "The Relationships M Tn+':g Style, Student Lea n.dng Style, and Perfor-
. mance," presented. at. the Tenth A=nual Cbnvention, A=erican Institute for '
Ded % Sciences,. October 3C-Nove=ber T,.1978, St. Louis, Missouri. (with George- A Jh4 and W RmbIph. Hymd "Superviscry Thrining Needs:: A Study of Interincustry- c%. city," presented at. the Twentieth A=nual Meeting, Mcum.ain Plzins Management Cenference, Oc-tober T2-14,.197Er Estes Park,. Colcrado. (with W. P.andolph Flynn) *
" Learning Style and Perfw m;ce,. presented at the Fifth AnmdCenterence of the As:cciatic:r fcr .tus:Lness- mmh +r an:1 Experiential Learning (ASSEL),
April 12-14, 1978, Denver, Colcrado. (with George A. Jchnsen)
"Ecciogical necry and Organi=2tien Develop =ent," sy=pesiu= ,~. esentatien at the
- Ma ch 16-18, 1978, Annual Meeting of the Western Divisica of the Aca1_ y
' cf Management, Sacra = ento, California. (with Warren R. Flynn) m -
" Alienation From Work and Administrative Policies: An M irical Study " pres-ented at the March 16-18, 1978, Annual Meeting of the Western Division of f /, the Academy of Management, Sacramento, California. (with Warren R. Flynn) s 377 " Supervisory Devele;xnent- A New Look At An Old Topic," presented at the l Mountain-Plains Manage C::nference, Octcber 13-15, 1977, Omaha, Nebraska, :
and, abstracted in the Proceedings, Nineteenth Annual Meetir4, MPMC, p. 9, l (with Warren R. Flynn) '
Western Academy of Management, March 31-April 2,1977, Sun Valley, Idaho.
Served as member of the Arrangements Ca:::ittee for the host institution.
1976 M3untau-Plains Management Conference,. Octobe- 14-16, 1976, Boise, Idaho.
i Served a.s Ph of session on Business Policy.
"A Survey of Management Devel%4. Needs for Esalth Care Institutions," pres-ented at the April. 5-10,1976, A-1 Meeting of the Western Divisics of the '
W- y of' Manage::e=t, Santa Barbara, California (with Warren R. Flynn)
BOCK RE'GS 1982 Persennel Ad=inist ation, for' West Publishing Campany, Review of fcur chapters, Fe=ruary 22, 1982. ~
1981 Student Act4.vities Mar..:al to may Hu=an Relations Skills
- ext, for Rand:m nouse, Inc., June 21, 1987.
N eele at Werie: An Introduction ta'Hu=an Relations, by Paul R. Ti::m and Brent 1,
D., Peterson, Brigna= Xoung Un2.versi.,y, for 'n' esc Pubishing Campany, April 17, s ' 1981 (Chapte s 4-14.),. May 22, T981 (Chapters 15-22)..
1950 Humarr Relations. Skills, for Randar House, Inc., February 22, 1980 (Chapters 1-M. June 6,1980 (Chapters 9-17).
1977 The Human Side of Orcanizations by Stan Kessen, fer Canfield P ess of Harper anc. Row, Puolisners, Inc., February 4,.1977. ~
PRFSIONAUCON.*ULTING At u.gg '
I Superviscry DeveL.,4 In***w I & II These are *.m-c.ar scrksb=;:s dealing with. basic. supsrviscry Me and. tha man agement of stressful interactions. whica are effered a. nu=be cf times each year through the- Cente- fc:- Business Research ard Se vices at Idaho State University for local representatives. ft:x: industry, business, and govern:nental organiza-tiens. These r vs.ca have also been tailcred for in-house presentatien duridg the past five years for a nu=ber of clients, inrluding Mensanto Cw ,,w 4.icn, the J.R. Si= plot Ca:pany, La=b--Westen, Inc., Cre-Ida Feeds, Garrett Freight-lines Inc., EG&G Idaho, Inc , 'the Idaho Depart =ent of Health & Welfare, and the A=erican Society for Persennel Ad=inistration.
1982 Spnset S;:cres, Pocatam, Idaho, Werked w:.th :::anager and graduate students as part of an W study dam *ng with survey research and feedback of c=ployee
, atti*'ades.
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Sales & Marketing Executives, Inc., Speech on " Theory I: Lessons from the Japanese," Pocatello, Idaho, April 13, 1982, 10 attendees at the Eilton Inn.
' Intermountain Health Care, Inc., Ncrthern Regiert Ad=ini.v. aters' Retreat, Elkhcrn at Sun Yan ey, Idaho, July 9, 1982, presentatica on "Cente=perary Management Iheory."
Bannock Memorial Hcspital Scard, Pocateno,: Idaho, August 14,1982,. consulting -
presentation to the board en effective decision =aking and c:x: =.=ication Western Associatierr of Conegiate Schools of Business (WAC33), Deans' Meeting in Scottsdale, Ari=cna, October 13-15, 1982.
Americart Potato Campany, mmMoct,. Idaho, censulted with top =anagement team in a meeting to evaluate progress of their Quality I=provement Prcy sa November 3, 1982.
Idaho State Tax Institute, Pocatello, Idaho, Nove=ber 5-6, 1982, served as gen-eral on-site coordinator and host for the conference. Coordinated planning.
for the 1983 ccnference.
ISU College of Business Advisory Council, served as convenor and hest fer. this armual meeting on the ISU cm, Novh- 6,1982.
National AccetW.ng Associat5xr, Eastern Idaho Chapter, speech en "The Quality Circle )bvement." Nev e r 17, 1982, to a group of about 30 people.
Hilton I=:r, pen, Idahc Qweing with: =armgement group ts improve overan. cperations.
s (' rarx Berem Insurance,. P~--tmm Idaba Progracr err conflict resolutterr 9, edeett at their annual meeting.
Idahn Fans Censolidated Hospitals, Idaho Fans,. Idaho Aided in develc;eene and analysis of a survey of supervisory pe-sonnel.
Ei-Rite /Supersave Drug Stores l Pocatelle, Idaho Consulted with cwner/=anager en issues of" org?nization structm e/
management. , ,
198G American Society for Training and. Devele;rment, P~ et-TTo, Idaho j L 4 am presentati.m en "Leveloping a Managcce ~ ~ Training Pics a=.* l l
. 1 l Naticnal Acccunting Associaticn,. Eastern Idaho Chapter-
, One-day shar in L,.. sing supe viscry p actices. {
1 l Idaha Pcue:- C% 4ay, Ecise, Idaho Two hi s c a presentations en @oyee counseling and perfor=mee i i= prove =ent.
' La=b-4eston, Inc. , Portland, Oregon
- Design and i=plementation of a productivity i=p ovemen
- p-i:: gram in six plants.
l l .9 American Scciety of Mechanical Enginee: s, Idah: Fans, Idaho Presentation en. " Managing Turnove:- in High Teology Industr y."
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Idaho Department of Health & Welfare, Scise, Idaho e- Supervisory develo;xnent program focusing on group develo;xnent and behavior. .
American Potato C g ny, Blackfoot, Idaho Develcanent of a perfer=ance appraisal syste:n for selected production werkers. -
Southeast Idaho C:c=:'.'dty Action Agency (STCCCA), Pocatello, Ida.%
Workshop on Time Management .
EG&G Idaho, Inc., Idaho Falls, Idaho Worked with internal corsultant. cn design and conduct of attuude survey.
Franklin and Oneida County Hospita.1 Boards One-day Wnars. on problem solving 1978 La=b-Westen, Inc., American Falls, h b Management develo;r.ent worksL~p 1977 Sales & Marketing T.xecutves, Inc., Pocatello, Idaho Presentation on "Crganiza* h Behavior Modification."
1976 Southeastern Idaho Center for Health Resources (SIC'G), PocateN, Idaho Semin2r en Performance Evaluatierr
' '4 Ame-ican Society for Pers6nnel AM"4*t ati=rr, Pocatelle, Idaho Panel me=ber fer g cp - en Interviewing Techniques.
k.:.-us;CES FurM
- bad en request.
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s VITA NSWTON MARGULIES Home Address ,
Business Address 1734 Plaza del Norte Graduate School of Management Newport Beach, CA 92661 University of California Irvine, CA 92717 ,
EDUCTJr0N B.A. Civil Engineering,' Brooklyn Polytechnic Institute,1958 M.S. Industrial Management, Massachusetts Institute of _
Technology 1960 Ph.D. University of California. Los Angel es,1965.
Major Fleid: Behavioral Science for Management; specta.1 emphasts on organizational behavior.
(, POSITr0NS.HELT1 .
~
Graduate Research Asststant, UCU.,. Institute of Industrial Relations:
September 1960 - January 1962 H= san Factors Speciaitst, System Development Corporation, Santa Moni,ca, CA: June. 1961 - 1962 Teaching Fellow,. UCLA,. Industrial Psychology,. Management Theory
- and Personnel Mnagemenb September 1961 - September 1963.
Assistar;t. Professor c[O'rriarwirattonaT Sehavior, San Fernanda Valley State CaTiege, Northridge,. CA: September 1962. 1g64.
Director,. Sensitivity T(aining Labs for business community of San Fernando Valley, San Ternando Valley State College, Spring 1964.
Assistant Professor of Organizational Behavior, Case Institute of Technology.. Cleveland, Ohio: Juna 1964 - 1966. ..
Visiting Professor, UCLA, Organizational Behavior, Su=ner 1965.
,p,qsociate P'rofessor in Management, University of Miami, Coral
. Gabi es, FL: September 1966 - June 1963..
Fart-time Faculty, Cornell University, NY State School of Industrial and. Labor Relations, Ext. Div... October 1966 - 1967.
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- p. Newton Margulies, p. 2 POSITIONS HELD, c'ontinued .
Organizational Development Consultant, TRW Systems Group, Redondo Beach, CA: June 1968 - October 1969.
Lecturer in Psychology, California Institute of Technology, Pasadena,
, CA: Spring - Fall,1969.
Adjunct Professor, Union for Experimenting Colleges and Universities.
Anttoch College: 1969 - Present. .
Lecturer in Graduate School of Administration, University of Califor-nia, Irvine: September 1.969 - 1972.
Director, Executive Program, l*~iversity of California, Irvine,1970.
Associate Professor and. Associate' Dean, Graduate School of Admints-tration, Univers.ity of California, Irvine 1972 - 1977. (Acting Dean, April - October,1975). .
' Professor, Graduate School of Management, Uniyersity of California, Irvine,1977 - present. (Acttn9 neart,, June 1983 - ).
/ .
e PROFESSIONAL ACTIVITIES . .
Chat r, Organirational DeveTopment Dtvision, Academy of Management,.1978
' Editor, Psychological Recorts, T978 - 1979. ,
. Adyf ser,. University, of Calf forni a, Irvine, Medical. Center, Department of Radiology,1979 Consulting Editor, Group and Organizattonal Studies,1978 - present. ,
Cortsuiting' Ed.itar,. Academy of Macagement Review,.1981.
FelTow,. Di'vistion of App 1 f ed Eeh'avforzi Sctencr,. UCLA.
INVITED ADDRESSES _
UCI Executive. Progran, 1972 - 1974 .
Organizational Development Workshop, University of California, Riverside,1974.
iiisociation of California School Administrators, January 1974
" Innovations in Educational Organizations" International PersonneT Managers Association, April 1974.
"Organi::attonal Develepnent and the Personnel Function"
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s.
INVITED EDDRESSES, continued <
l
. Address at Regional Meeting of American Soci ety of Public Admin-istrator.s, Fresno, California,1974 College and Universt,ty Personnel Association, June 1975.
"Use of Organizational nevelopment on University Campuses" ,,
- Daniel Freeman Memorial Hespttal .1976
", "Nanaging Heelth Care Organizations" Universtty of Californi a, Davis Executive Program,1976.
University of California,l.os Angeles Executive Program, 1976-1977.
" Organizational Change and Development" _
University of California Management Institute, July 1976, 1977.
. "OrganizationaT Change and Development" Western Electrical Manu.faccuring Association (WEMA),1977.
., " Making Management Teams. Work" Untted States Department of Justice, July 1777.
(
'" Workshop on . Team Developmerrt" -- .
- s. .
Caitforitta Conference on Horte Health. Agency, Internal Management, September 1977. " Effective Management Tools and, Techniques" Californta Conference on Home. Health Agencies, September 1977- -
" Future of Health Care. Delivery Teams" University of Califcenta, Management Institute, 1978, 1979,.1980.
Organt:ationa.l. Behavior Teaching Conf erence, University of'. Southern Carolina,.1978'. " Teaching- Organizational Development: Cognitt ve and Dyrertenttai- Apr. mh."
American Public Health Association Meetings, Los Angeles,1976.
Building Health Care Teams" Academy of Management Annual Meetings, San Francisco 1978 ~
. " Workshop on Conflict Resolution" California Emergency Physicians, Los Angeles, February 1980.
"Comunicat; ion in Emergency Teams"
" 'IACE, UCt.A, Mexico City, Monterey , Mexico, September 1980.
" Workshop on Organizational Development"
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- Newton Marguli es, p. 4
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INVITED ADDRESSES, continued
(
' 00 Nefwork, San Francisco, October 1980. I
" Workshop on Organizational Development" Hernstein Hanagement Center, Vienna, Austria, March 1981.
" Workshop on Team Development" INVITED PAPERS . .
. Western Meettngs of the Academy of Management,1974.
"New Frontiers for Organizational Development" National Academy of Management, Seattl e,1974.
" Current Issues in Organizational Development" Second Annual International Conference on Progress and Prospects in Health Care Systems,1975.
" Organizational Deve.Topment in Health Care Settings" Organizational Development Network Meetings,1975.
"The Cetsis in Organt:attonal Development" CACUHO Conf erence, Tg77.
( "Initiattng Change irr the University" CSUC EOF Workshop, T977. .
Presentatton on Teams and Te'am Development ,
~
Western _ MeetiAg of Academy of Management,1977
" Guerilla. Strategies for- Organizational Change" l '
National Academy of Management,. Orlando,. Florida,1977.
l Workshop orr Organf rational Development ,
. Amerfcan Institute of Aeronautics and Astronau' tics.. Los Angeles and Washington, D.C. T9ET
" Human e actors in the Implementation cf Nw Technology'
" Managing the'Workforce in the 80's*
I NationaT Academy of Managrnent,.1981,. --
, . " Teaching Consulting Skills: A Critical Work" ,
"A Critique of Research Methods in Organization.a1 Development" Advanced Management Institute, UC Berkel ey,1981.
"The Use of Teams and Team Development in High
, j;_ , Technology Organizations" Eational Organizational Development Network,1982.
"Using the Socio-Technical Framework to Design and Implement CAD / CAM Systems" ,
" Organizational Diagnosis: Core Processes and Issues" .-
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. . . . . ... u Newton Marguli es, p. 5 e
f VISITING ASSIGNMENTS Visiting faculty in Organizational Development Program for ,
International Public Officials, University of Southern Cal t forni a, 1975, 1977.
- Adjunct Professor in Master's Program in Organizational Develop- * *
. ment, Pepperdine Unf versity,1975-present. ~
CONSULTING ACTIVITIES .
UCLA and UCSD, area of Management and Organizational Development.
. UCLA Department of Counseling -
City of Laguna Beach Orange County Transit Otstrict -
SheT1011 Company
- .- liepartment of Consumer- Affa. irs .
s
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Department. of Wat'er Resources .
Sart Dtesc State University .
TRW Systems Group '
Northrop Corporation UCI Campus - Personnel Office
- HER Grocery Cenpany,. Texas Emergency Medical Systers, Washington, D.C..
UCI Medical Center j PUBLICATIONS -
BOOKS: .
. , ~ - - Manua'. for General Management Theory (co-author), UCLA Separtment 7 of Puolications, Fali 1961.
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Newton. Margulies, p. 6 PUBLICATidNS, continued BOOKS:
Organiza'tional Develoceent: Values, Process, and Technolo'gy, (co-autnor), McGraw-Hi ll , hew t orr , 19 7 2. ,
Organizational Change: Technicues _and Acolicati' ens (co-author),
- Scott, Foresman 1: Co., 1973.
, Conceotual Foundations of' Organizational Develcoment, McGraw-Hill, 1978.
Organizational Develocment for Health Cara Orpanf rations, (coauthor),
Acci sen. West ey,,1982. _ ,
Managing Organirational Change and_ Oevetoonvent, Academic Press, in press ARTICLES:
The Parable of Management Science (c:autho;-), Busines: Hoci: ens,
- - Fall , 1.965 N L Some Factors. in E:::ployee Assimilation, Busin tss Pers:ectives, "
Spri ng,1966 -
A Study of' Organizational Culture and Self-Actualization.* in The . .
Proceedings of the 8th Middest Conference of the AcadeTmof .
Management, Apn 1 IMi, 8cdoley uni 7ersity, Peoria, IL Also:
Worting Paper No.1, Orani:stional Behavior Group, Case Institute .
of Technology Cl eveland, Ohio, Spring 1965. ,
. 5~cientists, Engineert, and: Technological Obsolescence, (ccactho:-)
California Hanagement Review, i4foter '1367.
Force Losses at S:uthern BeTT, Proceedings of the 19th Midwest Meeting
- . of Management, Bureau of Susines.i Researen, ~5cutnern 111intos l Uni versity,. 6 967.,
- People in Organizations: A Case for Team Training, ($oauthor), ASTD-Tra_ining and Deve1coment Journal, Vol . 22, 8, August,19M.
A: tion Research in A :,ien, (coauthor), Atlanti Economic Review, Fall,
.. 196a.
- Action Tsescarch and the Consultative Process, (coauthor), Business
' Persoectives , Fall 1963.
t , The Applicatien of Schavioral Science Research, (coauthor), Southern l" Journal of Businesl, October 1968. g-L -- e .m. _'...
1
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( PUBl.ICATIONS, continued ARTICLESy The Malt.iple Impacts of Organizational Climate and Individual .
Value Systems on Job Satisfaction, (coauthor), Personnel Psychology, Vol. 22, 2,, 1969. ,
'~
Pef sonntil Turnover in a Bureaucratic Organization, (coauthor),
. Synoosis, Belgium,. July 1969.
Organizational Culture and Psychological Growth', Journal of - -
Apolied Behadoral Sciences, Vol. 5, 4,1969 An Integrated. Approach to Superivosry Training for Hiring the Hard Core, ASTD Training and Development Journal,_Vol .
, 24, 3. August 69/0.
A Sensitivity Training Design for Organizational Development, Social Change: Theory and Acolication, Vol . 1, 1,1971.
Implementing Organizaticnal Change Through the Use of an Internal Consulting Team, Training and neveicoment Journal July 1971. "
Work and' the Uttitration of Self, Experiences in Being, Bernice Marshall, Ed Brooks / Cole,1971. -
Coping. with- Organfrational Change, Synoosis , January-February,1972.
The Myth and Magic of Consulting'in Or5anizational Development, -
, Business Horizons, August 1972
{' '
00 in a. University Setting: Some Problems of Initiating Change, Ecuational Technology, October,1972. ,
OrganizationaT. DeveTopment and Changes in Organizational Climate, Public Personnel Managenent, March-April,1973.
Impact of ManageriaT Ortentation on Orsanizational Climate, Jo'srnal -
of Industrial and Organizational Psychology, Spring 1973.
. The Effects of an Organizational Sensitivity' Training Program on a
. Measure of Self-Actualization, Studies in. Personnel Psychology, Sumer 1973.
Organizational Change in Perspective, (coauthor), Thrust, November, .
1974.
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j Newton Margulies, p. 8
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PU3LICATIONS, continued ARTIC!.ES:
Managing Change in Hea.lth Care Organizations, Medical Care, ,
Vol .15,1, August 1977. ,
Notes of the Margina.itty of the Censultant's Rote, Social Change, Fall 1977.
Organt:ational Developmenti Techniques: Their Impact on Change, Group and Oceanizational Studies, Vol. 2, 4, Dece:::ber 1977.
organizational change and Development, Organizational Behavior, Steven Xerr, Ed , Grid Publishing, Inc.,1978.
Perspectives on the Marginality of the Consultant's Role, Proceedings of CD,.1978, University Associates, Fali,1978.
The Marginality cf the Censultant's Role, The Cutting Edge, -
W. Warnes- Burke, Ed.,1:niversity Associatas,197a.
~
u . Toward .a. Core TypoTogy of Service Organizations, (coauthor), The ,
- Academy of Manzament Review, Vol. 5, 2, April 1980.
^
Organizational Politics and Crganizational Develepment, (coauthor)
The Academy of Vanagement Review, Vol . 6 ,1,, January 1981. ,
facie-Technica.1 Appfcach to Planning and Implementing New Te:hnology, -(ccauthor),. Training & Develocment Journal, Cecetaber 1952 ,
'. An Organize.tten&T Development Approach to the Imple=entation of Naw Technategy Current pemnettve.s. of Crgantz.ttiona_1 Develocmen,. D.D. wrrrrer, Ee., Asia,1983 Flexiforn Organizations, (ccauthor), Gecue and Organi:etion
- Stu:Mes, January 1981. ___
Values, Crgani:tional St.~acture and Technology in . Service
. Organfretiens, (coauthor), Groue and Crganization Studies, -
January 1983.
. Motiva-ing the Client /E=;1cyee Sis .am as a service Production, (coau%or} , Tne Academy cf Nanagement Review, Vol . 8, 2,
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April 1923.
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PUBLICATfNT, continued ARTICLES: * .
An OrganizationaT DeveTopment Framework for Managemen't Development, (ccauthor), Training and Develoament Journal,1983. .,
". REVIEWS Management: Task.s, Roles, and Responsibiliti es, Druck er, P.F.,
appeared in Executive Guarterly,1974.
Interactf ve Skill Development, Rackha:n, Honey and Colbert, appeared in Contemocracy Psychology,1974.
. To Be That Self Which One Truly Es, review of Authentic Management, A Gestait Orientation to Organf rations and Their nevelopment, Herman, Stani ey M. and Michael Karenich, appeared in
., Contemocrarf Psychology,1977
- Leada ship Revisited, review of Leadership in Organizations, Yuki,
, Gary A in Academy of~ Management Revi ew, January 1982.
x, .
Managing Change in Health Care, review of Icaroving Health Care
. Management,. GE.Wi eland,. Ed. in Contemporary Prychology, 1982. .
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November, 1981.
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A 08/07/84 WCS Doc 6262E Disk 0909E Job 23476 Proof 2 _ cla
,r Charles M. Rice hp 7 President, LRS Consultants, Inc.
]pavMf Thirty bree years nuclear experience, initially in technical areas of shielding, criticality, radiation damage, and reactor design. Since 1957, in project engineering, program management and then general management including the following specific responsibilities:
- 1. President of LRS Consultants, Inc. since its founding in 1981.
This company and. Mr. Rice provide consulting services to a number of nuclear utilities, state agencies, industrial firms and federal contractors in areas of reactor safety, quality assurance, radioactive waste management, radiation protection, energy n1ternatives, and both program and general management.
Z. Principal founder in.1972, President for six years and then Chair =an of the Board untiT early 1981. of Energy Incorporated, a consulting firm specializing in safety ana. lysis,. q'uality assurance amt nuclear planc startup
- 3. Served for three and one half. years as President and Geraral -
Manager of Idaho Nuclear Corporation and Aerojet Nuclear Company with responsibility for management of the National Reactor -
. Testing. Station (now the Idaho Nationa T Engine?Hng Laboratory),
the: USAEC's. principa.T site for water raw sa:faty rasaa.-ch; and test reacter operatfo.T.
4.
Program Manager for the AEC/ NASA iiERVA nuclear rocketJevelopme:tt program. Also :;erved as i'rujact hansgar for the first successful r,uclear rocket engine NRX/EST and the flight prototype XE-1.
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A 08/07/84 WCB Doc 6262E Disk 0909E Job 23476 Proof 2 _ c1m r-
- 5. Program Manager for the Army Gas Cooled Reactor System Program including design and fabrication of the ML-L, (the first complete system prototype), the Gas Cooled Re' actor Experimerrt, the closed cycle gas turbine power plant and al'1 related research and development.
- 6. Reactor Engineering Department Manager responsible for development and irrstt11ation of several university training reactors, cortsulting contract support to the AEC for cerrtral station power plants, marttime applications of nuclear power, metallurgical research and food irradiation applications.
Patented a VartabTe Moderator Controlled Boiling Water Reactor.
- 7. Head of the Atomic Power Engineering Group for an architect engineering fir::r responsible for the design of the first boiling water nuclear power piarrt.
'~
- 8. For four years served as a Physicist with the Oak Ridge ,
Operations Office of the U.S. Atomic Energy Commission.
AB Physics MS Physics Oak Ridge School of Reactor Technology Fellow and Charter Member, American Nuclear Society .
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