Rohr

I. BACKGROUND

A. Rohr’s Job at Salt River

From May 1981 to June 14, 2004, Rohr worked as a weld- ing metallurgy specialist in the Plant Technical Support Group at Salt River, which provides utility services to homes in Arizona. [ER 2, 3.] The Plant Technical Support Group was composed of specialists in various fields, including weld- ing metallurgy, turbines, boilers and cathodic protection, as well as the quality assurance staff. [ER 16.] The group’s objective was to address problems that Salt River’s power plants could not solve on their own. [ER 16.] For example, if a power plant requested a new welding procedure, the special- ists in the Plant Technical Support Group would design it. [ER 17.] The Plant Technical Support Group performed audits, reviewed paperwork on the plants to determine whether any applicable code had been violated and responded to third-party inspections. Rohr characterizes the group’s work as mostly “engineering-type support.” [ER 17-18.]

As a metallurgy specialist, Rohr was primarily responsible for overseeing all aspects of Salt River’s welding procedures, maintaining Salt River’s welding manual, training all welding personnel, reviewing and…