ML20199E252
| ML20199E252 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/21/1986 |
| From: | Johnson G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Husted C HUSTED, C.A. |
| References | |
| CON-#186-519 CH, NUDOCS 8603250454 | |
| Download: ML20199E252 (6) | |
Text
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March 21, 1986 k
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION f-
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_BEFORE THE ADMINISTRATIVE LAW JUDGE Dxrmna s STAv;c % cu
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In the Matter of
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GENERAL PUBLIC UTILITIES NUCLEAR )
Docket No. 50-289 (CH)
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(Three f.lile Island Nuclear Station,
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Unit No.1)
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NRC STAFF'S FIRST INTERROGATORIES AND REOUEST FOR PRODUCTION OF
_DOCUf1ENTS TO CIIARLES IIUSTED In accordance with 10 C.F.R. Sections 2.740, 2.740b and 2.741, the NFC staff hereby serves Charles Husted, a party in the above-ceptioned proceedir.g, with NRC Staff's First Set of Interrogatories and Document Requests to Charles Husted.
These interrogatories and document re-quests relate to the seven factual issues admitted for litigation in this proceeding by the Presiding Officer in his Report and Order On Initial Prehearing Conference
(" Order") dated February 27, 1986.
Answers to the interrogatories and production of documents requested below are due within 14 days after service, in accordance with 10 C.F.R. I 2.740b and the Presiding Officer's Order, at 13.
You are requested to answer each interrogatory separately and fully in writing under oath or affirmation, and to incluce all pertinent informa-tion avellable to you, your agents, advisors, or counsel, based on the personal knowledge of the person answering.
By caen request for production of documents, the NRC Staff seeks to inspect and copy pertinent documents which are in your possession, 9501 8603250454 860321 PDR AWCM 05000289 O
r pe.>,<} custody or control, or in the possession, custody or control' of your advisors, agents, or counsel.
As used herein,
"you" and "you r" refers to Charles Ilusted;
" Charles Husted" includes Charles liusted, his advisors, agents, employ-ees, and counsel; " documents" refers to and includes any writings, draw-ings, graphs, charts, and schedules wherever located and however prepared, produced, transmitted, or stored; photographs or other picto-rial representations; recordings and tapes, whether sound or visual; and data compilations of whatever form.
'In answering ecch interrogatory:
(1) Fully identify any documents which form the basis for your answer, or which relate to the subject of the interrogatory and upon which you intend to rely in establishing your position at hearing; (2) Give the name, address, occupation, and employ-er of the person or persons answering the interrogatory; (3). Identify each person, including his or her name, address, occupation and employ-er, whom you expect to call as a witness to testify as to the matter ad-dressed in the pertinent interrogatory, together v'ith the subject matter and substance of the testimony; (4) If the answer is based on oral or written communications with one or more individuals, identify each such individual, including his or her name, address, occupation, employer and professional background, describe the information received and its rela-tion to the answer, and fully identify each writing'or record documenting such communication.
You are also requested +o supplement 'each interrogatory. answer as necessary or appropriate in accordance with 10 C.F.R. I 2.740(e).
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. Interrogatories 1.
Please fully state your position on the first issue admitted for litiga-tion in this proceeding -- your " alleged solicitation of an answer to an exam question from another operator during the April 1981 NRC written examination" at Three Mile Island Nuclear Station.
Please.
. include each and every fact on which you base your position on this issue.
2.
Please fully state your position on the second issue admitted for liti-
'gation in this proceeding -- the alleged " lack of forthrightness of
[your]
testimony before the Special Master" in Metropolitan Edison Company (Three Plile Island Nuclear Station, Unit No. 1),
Docket No. 50-289, u necember 10, 1981.
Please include each and every fact 'on which you <ase your position on this issue.
3.
Please fully state your position on the third issue _ admitted for litiga-tion in this proceeding -- the question as to whether you exhibited a
" poor attitude toward the hearing [before the Special Blaster) on the i
cheating incidents."
Please include each and every fact on which you base your position on this issue.
l 4.
Pleese fully state your position on the fourth issue admitted for liti-gation in this proceeding -- your alleged " lack of cooperation with NRC investigators" in interviews conducted on July 29, 1981, and September 18, 1981.
Please include cach and every fact on which you base your position on this issue.
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h 5.
With regard to the two admitted contentions of TMIA and the admit-ted contention of GPU, please fully state your position as, to how your performance of your responsibilities with GPU and Metropolitan Edison Company reflect on your attitude and integrity.
Please in-clude each and every fact on which you base your position.
~C.
With regard to the two admitted contentions of TMIA and the admit-ted contention of GPU, please state your position as to whether any remedial action with respect to you is required.
Please include each and every fact on which you base your position.
7.
If, in response to Interrogatory 6, you believe that remedial action is warranted, please state the remedial action, and each and every fact on which you base your position.
8.
With regard to the two admitted contentions of TMIA and the admit-ted contention of GPU, please describe any other information con-cerning your attitude, honesty, integrity, character, personality traits, activities, habits or reputation on which you intend to rely in addressing how considerations as to your attitude or integrity bear on your employment as an NRC-licensed operator, licensed-operator instructor or training supervisor, or supervisor of training of non-licensed personnel.
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e k Documents Requests Please make available for inspection and copying, at a time and location. to be designated, any and all documents of whatever description identified in your answers to the above Staff interrogatories.
If you maintain that some documents should not be made available for inspection, you should identify the document as to date, title, author, recipient, and subject matter, and explain why such documents are not being made available.
For e NRC Staff, J' g-
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George E. Johnsen Counsel for NRC Staff Dated at Bethesda, Maryland ~
this 21st day of March,1980
00(xftro UNITED STATES OF ' AMERICA USNRC NUCLEAR REGULATORY COMMISSION
% HAR 24 p3.g4 BEFORE TIIE ADMINISTRATIVE LAV JUDGE TIYG] g,g OC In the Matter of
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BRANCH
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GENERAL PUBLIC UTILITIES
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Docket No. 50-289 (Cil)
NUCLEAR
)
)
(Three f.lile Island Nuclear Station,
)
Unit No.1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO TMIA'S REOUEST FOR AN EXTENSION OF TIME AND FOR A DELAY OF DISCOVERY" and "NRC STAFF'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO CHARLES HUSTED" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Com-mission's internal mail system, this 21st day of March,1986:
- Morton B. Margulics
- Atomic Safety and Licensing Board Administrative Law Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board.
Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555
- Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Louise Bradford Washington, DC 20555 Three Mile Island Alert 1011 Green Street
- Docketing and Service Section Ilarrisburg, PA 17120 Office of the Secretary U.S. Nuclear Regulatory Commission f.llchael W. Maupin, Esq.
Washington, DC 20555 l
Maria C. Hensley, Esq.
l Hunton & Williams l
P.O. Box 1535 Richmond, VA 23212 Deborah B. Bauser, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M Street, NW Washington, DC 20036 0
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