ML20137N212

Response of C Husted Supporting Util Suppl to Petition to Intervene.Util Contention That NRC Should Not Disqualify Husted as NRC-licensed Operator Admissible.Certificate of Svc Encl

ML20137N212
Person / Time
Site:	Three Mile Island
Issue date:	01/24/1986
From:	Maupin M GENERAL PUBLIC UTILITIES CORP., HUNTON & WILLIAMS
To:	Atomic Safety and Licensing Board Panel
References
CON-#186-864 CH, NUDOCS 8601290197
Download: ML20137N212 (4)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE ,

In the Matter of )

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General Public Utilities ) Docket No. 50-289(CH)

Nuclear )

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(Three Mile Island Nuclear )

Station, Unit No. 1) )

MR. HUSTED'S ANSWER TO GPU NUCLEAR CORPORATION'S SUPPLEMENT TO ITS PETITION TO INTERVENE Pursuant to the Administrative Law Judge's Memorandum and Order of December 6, 1985, Mr. Husted files this Answer to GPU Nuclear Corporation's Supplement to its Petition to Intervene.

GPU Nuclear Corporation (GPU) seeks to have a single contention litigated in this proceeding. The contention is:

The conduct and attitude of Charles Husted with which GPU Nuclear is familiar indicates that the NRC should not disqualify Mr. Husted from serving as an NRC-licensed operator, an instructor of licensed or non-licensed

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operators, or a supervisor of operator training personnel.

GPU has set out its basis for its proposed contention with reasonable specificity, and so Mr. Husted concludes that the contention is admissible and that GPU should be per-mitted to participate as a party in this proceeding.

Respectfully submitted, CHARLES HUSTED Michael W. Maupin, Counsel 01' Counsel Michael W. Maupin Maria C. Hensley HUNTON & WILLIAMS P.O. Box 1535 Richmond, Virginia 23212

January 24, 1986 Dated:

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1 l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE In the Matter of )

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2 General Public Utilities ) Docket No. 50-28 9 (CH)

Nuclear )

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(Three Mile Island Nuclear )

Station, Unit No. 1) )

CERTIFICATE OF SERVICE I certify that copies of Mr. Husted's Answer to GPU Nuclear Corporation's Supplement to Its Petition to Inter-vene, dated January 24, 1986, were served upon the following persons by deposit in the U.S. Mail, first class, postage prepaid, or, as indicated by one asterisk, by Federal Express, today:

Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTENTION: Chief, Docketing and Service Section

• The Honorable Morton B. Margulies Adminictrative Law Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 4

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• George E. Johnson, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Ms. Louise Bradford Three Mile Island Alert 1011 Green Street Harrisburg, Pennsylvania 17102

• Deborah B. Bauser, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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Michael W. Maupin Counsel for Charles Husted i

Dated: January 24, 1986 l

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