ML20197C193

Answers to TMI Alert,Inc 860501 Supplemental Interrogatories.Certificate of Svc Encl.Related Correspondence

ML20197C193
Person / Time
Site:	Three Mile Island
Issue date:	05/08/1986
From:	Barat S GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
Shared Package
ML20197C178	List: ML20197C176 ML20197C193
References
CH, NUDOCS 8605130257
Download: ML20197C193 (5)

Text

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May 8, 1986 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE In the. Matter of )

)

GENERAL PUBLIC UTILITIES ) Docket No. 50-289 (CH)

NUCLEAR CORPORATION )

)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

GPU NUCLEAR CORPORATION'S ANSWERS TO TMIA'S SUPPLEMENTAL INTERROGATORIES OF MAY 1, 1986 In a May 1, 1986 telephone conversation, TMIA asked GPU Nuclear Corporation to respond to three additional follow-up questions and one document production request that relate to documents previously produced by GPU Nuclear. GPU Nuclear's answers to these interrogatories and document request are pro-vided below.

INTERROGATORIES SUPPLEMENTAL INTERROGATORY NO. 1: Who wrote the two anon-ymous and undated performance reviews of Mr. Husted that were produced during discovery?

ANSWER TO SUPPLEMENTAL INTERROGATORY NO. 1: Both of the anonymous performance reviews of Mr. Husted are drafts written by Nelson Brown, who formerly was the Supervisor of Licensed Operator Training and Mr. Husted's supervisor.

8605130257 860508 PDR ADOCK 05000289 g PDR

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3 SUPPLEMENTAL INTERROGATORY NO. 2: Why was there an entry in several of Mr. Husted's performance reviews for the special assignment entitled "ASLB hearings"?

ANSWER TO SUPPLEMENTAL INTERROGATORY NO. 2: To the best of Mr. Brown's recollection, this entry was made because mem-bers of the Training Department, including Mr. Husted, were having to spend considerable time reorganizing and refiling large quantities of training documents that had been requested by and produced to parties to the TMI-l restart proceeding.

SUPPLEMENTARY INTERROGATORY NO. 3: How frequently were performance reviews conducted?

ANSWER TO SUPPLEMENTAL INTERROGATORY NO. 3: GPU Nuclear performance reviews routinely are required for each employee annually, and when an employee is promoted or is recommended for a salary increase other than in association with his annual review.

PRODUCTION OF DOCUMENTS REQUEST NO. 1: Please produce the original (handwritten) edition of Mr. Christman's notes of the interview of Mr. Husted by the NRC in July, 1982.

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s RESPONSE TO REQUEST NO. 1: GPU Nuclear Corporation has been unable to locate of Mr. Christman's original notes of the

' July, 1982 Husted interview.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By: .

Deborah B. Bauser Scott E. Barat Counsel for GPU Nuclear Corporation 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Dated: May 8, 1986

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i May 8, 1986 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE In the Matter of )

)

GENERAL PUBLIC UTILITIES )

NUCLEAR CORPORATION ) Docket No. 50-289 (CH)

)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of "GPU Nuclear Corporation's Answers to TMIA's Supplemental Interrogatories of May 1, 1986" were served on the following by deposit in the U.S. mail, first class, postage prepaid, or, as indicated by one asterisk, by hand delivery, or as indicated by two asterisks, by Federal Express, this 8th day of May, 1986.

Morton B. Margulies, Esquire Administrative Law Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• George E. Johnson, Esquire Office of Executive Legal Director 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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Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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

• • ' Michael Maupin, Esquire Hunton & Williams P..O. Box 1535 Richmond, VA 23212 Scott E. Barat