ML20062M619

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Motion to Compel NRC & Licensee to Provide All Documents Re IE 810918 Interview of C Husted by R Matakas.Documents May Provide Info on Alleged Solicitation of Info During Apr 1981 Exam.Svc List Encl.Related Correspondence
ML20062M619
Person / Time
Site: Crane Constellation icon.png
Issue date: 12/11/1981
From: Aamodt M
AAMODTS
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8112170359
Download: ML20062M619 (3)


Text

{{#Wiki_filter:. AAM - 12/11/51 t L Fr..a c:r:'::=== ]', [ "'" . UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION C'f. hjD -{ BEFORE THE-SPECIAL MASTER TO THE ASLB '81 DEC 14 P4:28 In the Matter of' ) gj gg Metropolitan Edison Co. ) Docket 50-2895Re IC ~ Three Mile Island ) ~ Nuclear Generating Station ) .I b A Unit 1 D JLJ j[ DEC16198tm. 8% mese % i-AAMODT MOTION TO COMPEL STAFF AND LICENSEE TO 8 8 *

  • 1888 PROVIDE ALL DOCUMENTS y

RELATED TO I&E INTERVIEW OF C. HUSTED-4 0F SEPTEMBER 18, 1981 G3 N The Aamodts motion that the Staff and Licensee be compelled to provide all notes, statements, recordings and any other information made at the time and subsequent to the time of the I&E interview of C. Husted by R. Matakas on September 18, 1981. d'C Ghese documents are to be accompanied by an affidavit executed by R. Matakas asserting the authenticity and completeness of such records. All parties are to respond orally during a conference, c o *- call alrendy-scheduled for Monday, December-14 to commence :- concerning other matters at 2 p.

m. -This 'otion is to be hand 4 - '

m delivered to the parties on December 11, 19 81-or served-by ~ T5rst (l4ss /))<if. Express Mail or Feder:1 Exprecs. The Aamodts had no way of knowing prior to December 10' that the documents described above and requested during Discov'ery had not been serviced. Aamodt Discovery of the Staff and Licensee on October 2, 1981 requested all documents relating to cheating and. investigations of cheating. On December 10, by way of_the testimony of C.

Husted, it became known.that C.

Husted had prepared and signed a written 8112170359 01121 ~ during an 9/18/81 interview by;the NRC. 40 'I statement -k $ I l PDR ADOCK 05000 g PDR.

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c [,, the statement-prepared by C. Husted was not' included 'n any.I&E. reports. Although the Licensee provided attorney i notes for'other interviews conducted at this time, noncLwere provided for..the'Husted_ interview. The statement and the other documents requested-.may she'd some light en_the alleged Husted --P ~ incident which does not appear in any reports. (Tr. 25416). 'There is good cause for the motion to be granted. The documents.may provide _information on the alleged solicitation of~information during the NRC examination in April the.t involved C. Husted and Operator P. This alleged incident may have signi-ficance concerning management involvement in cheating, since C. Husted is.an instructor in the TMI Training Department. As long as the major discrepancies in evidence exist undisturbed, 3 a question of management involvement, and its extent,.' exists. Some-of the questions that remain are .jP7; -Did C. Husted solicite Operator P?

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-Did the Staff know anything about the alleged incident (k prior to the I&E interview of Operatcr P7- -Why did Staff have different standards for the alleged Husted solicitation as compared-to the solicitation of WW? -What other information, not yet on the record, can. be provided by the documents? ,u. ~ -How serious, materially, is the NRC and Licensee withholding of in f o rma t ion ?- Respectfully submitted, lL.- AA) 41UWD Marjorie M. Aamodt' December 11', 1981

o, ---= m. _j 1. r.u. m cc = n c:a r cs .) ,,,y. t t t t1 u UNITED STATES OF. A'GRICA- ~ '.K 9 c ~ NUCLEAR AEGULAf0KY COM.MISSICN ~ ATOMIC SAFETY AND LICENSING-3 CARD: '81 :DEC 14 P4:28 W Before-Administrative Judge Gary L. Milho111n 1 <;t';F.ETAD -as Special Master NG & SERVICE. ,c n. BRANCH- 'in the Matter of ) ) .IGTBOPOLITAN EDISON COMPANY ' ') Locket No.'50-289 ) .(Restart) (Three Mile Island Nuclear -) (Eeopened Proceeding) Station, Unit 1) ) SERVICE LIST Administrative Judge Gary L. Milhollin Robert Adler, Esquire Atomic Safety and Licensing Board Xarin W. Carter, Esquire .1815 Jefferson Street Assistant Attorney. General - Macison, Wisconsin 53711 505 Executive House P.O. Box 2357 Afrinistrative Judge Ivan W. S..ith (2) Harrisburg, Pennsylvania'17120 - 'hai rr.an Atcmic Safety and Licensing scard Ms. Louise Bradford. t U.S. Nuclear -Regulatory Corrission Three ?ji3e Island. Alert: Washington, D.C. 20555 1011 Green Street Harrisburg, Pennsylvania 17102 m Ad.inistrative Judge Waltei~E. Jordan

  • Ato-ic Safety and Licensing 3 card

. George F. Trodoridge, Esquire-881 ':est Guter Driva C aw, Pittrar., Potts & Trovaridge Cak Ridge, Tennessee 37830 1800'M S reet, N.W. Washington, D,.C. 20036 Administrative Judge Linda W. Little Atomic Safety and Licensing Board Docketing and Service Section-- 5000 Hermitage Drive-Office of the Secretary Raleigh, North Carolina 27612 U.S. Nucicar Regulatcry Ccroission Washington, D.C. 20555' Jares R..Tourtelotte, Esquire Office of Executive Legal Director .U.S. ..uclear.seculatc:y serrission Richard Llovd, Escuire a Three Mlle Island Nuclear Plant ..a s..nasten,.D.C. .e O.c,:>5 c. Middletown,-Pennsylvania 17057 e ')t 4 l -2.-.., i~ - - ~ ' ~ ~~}}