ML20202G538
| ML20202G538 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/09/1986 |
| From: | Bauser D GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | THREE MILE ISLAND ALERT |
| References | |
| CON-#286-725 CH, NUDOCS 8604140418 | |
| Download: ML20202G538 (13) | |
Text
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. _ _... a v:wt.r4Gn bint April 9, 1986
'86 Agq.9 p4 3I hf'T r ~ -
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
('. y 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 FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO THREE MILE ISLAND ALERT GPU Nuclear Corporation ("GPUN"), a party in the above-captioned action, hereby submits its First Interrogato-ries and Request for Production of Documents to Three Mile Is-land Alert, pursuant to 10 C.F.R.
Sections 2.740, 2.740b, and 2.741.
I.
INSTRUCTIONS AND DEFINITIONS A.
These interrogatories are continuing in nature, up to and during the course of the hearing.
Information sought by these interrogatories that you obtain after you serve your an-swers must be disclosed to GPUN by supplementary answer or an-swers.
B.
If you cannot answer all or part of any interrogatory in full after exercising due diligence to secure the full 0604140410 060409 PDR ADOCK 0D000209
)
P' information to do so, so state and answer to the extent possi-ble, specifying your inability to answer the remainder; stating whatever information or knowledge you have concerning the unanswered portion; and detailing what you did in attempting to secure the unknown information.
C.
The word " document (s)" means all written, printed, recorded or graphic matter, photographic matter, sound repro-4 ductions, or other retrievable data (whether encarded, taped, i
or coded electrostatically, electromagnetically or otherwise),
from whatever source derived and however and by whomever pre-pared, produced, reproduced, disseminated or made; without lim-iting the generality of the foregoing, the word " document (s)"
includes the original and any nonidentical copy and also every
]
draft and proposed draft of all correspondence, memoranda, i
notes of meetings, telegrams, telexes, TWX's, reports, tran-
]
scripts or notes of telephone conversations, diaries, note-books, minutes, notes, reports, studies, testimony, speeches, worksheets, maps, charts, diagrams, computer printouts, and any i
i other writings or documentary material of any nature whatsoev-I l
er, together with any attachments thereto and enclosures there-
- with, i
D.
The words "you" or "your" mean Three Mile Island Alert ("TMIA") and all past or present directors, agents, rep-1 resentatives, attorneys, members, employees or other persons acting or purporting to act for, or on behalf of, TMIA.
_2
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E.
The term " person" means any natural person, business entity, or governmental entity or department, political subdi-vision, or agency.
F.
The term " identify" when used with respect to a per-son means to state:
(1) the full name of the person, (2) his or her current business address, (3) his or her position, and (4) a description of his or her responsibilities.
G.
The term " identify" when used with respect to a docu-l ment means to state:
(1) the type of document (e.g.,
- letter, article, photograph, computer printout), (2) its date or ap-proximate date, (3) its author or authors, (4) its recipient or recipients, including those individuals who received copies of the document, (5) its general subject matter, and (6) its present location or custodian (or the last known location or l
custodian).
H.
The term " identify" when used with respect to a ver-bal communication or meeting means to state:
(1) the type of communication or meeting (e.g.,
telephone conversation, face-to-face conversation, staff meeting), (2) its date or ap-proximate date, (3) the identity of its participants or at-tendees, and (4) its general subject matter.
I.
When an interrogatory requires you to " State fully and with particularity all facts which relate to your position whether or not such facts support or refute your position,"
identify in your answer each and every verbal communication, j
meeting, document, and person that you believe supports, refers l !
6 to or evidences such a position, or that you believe undermines or refutes such a position.
II.
INTERLvvATORIES Please answer each of the following interrogatories in accordance with the instructions and definitions contained in Part I above:
1(a).
State fully and with particularity your position as to whether Mr. Husted solicited an answer to an examination question from another operator during the April, 1981 senior reactor operator examination at Three Mile Island Nuclear Sta-tion, Unit 1 ("TMI-1").
(b).
State fully and with particularity all facts which relate to your position, whether or not such facts support or refute your position.
l l
2(a).
If you believe that Mr. Husted solicited an answer 1
from another operator, state fully and with particularity how such a solicitation relates to Mr. Husted's attitude and per-formance as an N.R.C.
licensed operator, licensed operator in-structor or training supervisor, or non-licensed training supervisor.
j i
(b).
State fully and with particularity all facts which l
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relate to your position, whether or not such facts support or refute your position.
3(a).
State fully and with particularity your position as to whether Mr. Husted cooperated with N.R.C. investigators l
during the July 29, 1981 interview.
>b (b).
State fully and with particularity all facts which relate to your position, whether or not such facts support or refute your position.
4(a).
State fully and with particularity your position as to whether Mr. Husted cooperated with N.R.C.
investigators dur-ing the September 18, 1981 interview.
(b).
State fully and with particularity all facts which relate to your position, whether or not such facts support or refute your position.
5(a).
If you contend that Mr. Husted's answers in the j
September 18, 1981 interview differed materially from his an-swers in the July 29, 1981 interview, state fully and with particularity each and every material difference.
(b).
As to each and every material difference identified f
in Interrogatory No. 5(a), state fully and with particularity each and every reason that you believe explains why the dif-ference occurred, e.g., Mr. Husted had better recollection, re-viewed documents, etc.
6(a).
State fully and with particularity your position as to whether Mr. Husted's testimony before the Special Master on December 10, 1981 in Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1), Docket No. 50-289, was forthright.
(b).
If you believe that Mr. Husted's testimony was not forthright, identify all statements that Mr. Husted made that you believe lacked forthrightness. l
h (c).
With respect to all those statements identified in response to Interrogatory No. 6(b), identify for each such statement all facts which support or refute your view that the statement was not. forthright.
(d).
With respect to each statement identified in re-1 sponse to Interrogatory No. 6(b), characterize the nature of f
Mr. Husted's lack of forthrightness, e.g.,
was the statement dishonest, vague, nonresponsive, or some other quality which your believe would indicate lack of forthrightness.
7(a).
State fully and with particularity your position as to how the forthrightness of Mr. Husted's testimony before the Special Master on December 10, 1981 in Metropolitar. Edison Company (Three Mile Island Nuclear Station, Unit No. 1), Docket No. 50-289, bears on his integrity and his performance as (i) an N.R.C.
licensed operator: (ii) a licensed operator instruc-tor or training supervisor; or (iii) a non-licensed training supervisor.
(b).
State fully and with particularity all facts which l
relate to your position, whether or not such facts support or refute your position.
8(a).
State fully and with particularity your position as to whether Mr. Husted possessed a poor attitude toward the hearing on December 10, 1981 in Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1), Docket No.
50-289.
i I
l 1,
6 (b).
State fully and with particularity your position as to whether Mr. Husted exhibited a poor attitude toward the hearing on December 10, 1981 in Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1), Docket No.
50-289.
(c).
If you believe that Mr. Husted possessed or exhib-ited a poor attitude, identify all of those statements that Mr.
Husted made which you believe evidence a poor attitude.
(d).
As to all of those statements identified in re-sponse to Interrogatory No. 8(c), identify for each such statement all facts which support or refute your view that Mr.
Husted possessed or exhibited a poor attitude.
(e).
With respect to each such statement identified in Interrogatory No. 8(c), characterize how the statement evi-dences a poor attitude, e.g.,
was the statement flippant, in-subordinate, etc.
9(a).
State fully and with particularity your position as to how Mr. Husted's attitude toward the hearing on December 10, 1981 in Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1), Docket No. 50-289, bears on his perfor-mance as (i) an N.R.C. licensed operator; (ii) a licensed oper--
ator instructor or training supervisor; or (iii) a non-licensed training supervisor.
(b).
State fully and with particularity all facts which i
relate to your position, whether or not such facts support or refute your position.
I 10(a).
State fully and with particularity your position l
as to how Mr. Husted's performance of his responsibilities as an employee of GPUN reflects upon his attitude and integrity.
(b).
State fully and with particularity all facts which l
relate to your position, whether or not such facts support or i
refute your position.
11(a).
State fully and with particularity your position as to what standards should be applied in determining whether i
Mr. Husted should be barred from serving as (i) an N.R.C.
licensed operator; (ii) a licensed operator instructors or 1
training supervisor; or (iii) a non-licensed training supervi-sor.
(b).
State fully and with particularity all facts which relate to your position, whether or not such facts support or refute your position.
12(a).
State fully and with particularity your position as to whether any remedial action is required with respect to Mr. Husted.
(b).
State fully and with particularity all facts relating to your position, whether or not such facts support or i
l refute your position.
13.
If you contend that Mr. Hunted should be the subject of remedial action, state fully and with particularity the re-medial action which ought to be undertaken.
14(a).
Identify every witness who will testify in this l
proceeding on your behalf or who hac been requested to testify, I
l I
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^
P will be requested to testify, or is likely to be requested to testify, regarciess of whether the' matter of the appearance be by subpoena or voluntary, s
(b).
State fully and with particularity the subject-area and substance on which each witness identified in Inter-rogatory No. 14(a) is expected to tentify.
III.
REQUEST FOR PRODUCTION OF DOCUMENTS You are hereby requested to produce the following docu -
ments to GPU Nuclear Corporation:
1.
All documents identified in your answers to the above interrogatories, other than the Special Master's Report of April 28, 1982, the Licensing Board July 27, 1982 decision, or hearing transcript pages.
2.
All documents related to your answers to the above in~
terrogatories, other than the Special Master's Report of April 28, 1982, the Licensing Board July 27, 1982 decision, or tran-script pages.
3.
All documents that TMIA intends to introduce during the course of the Husted hearing, other than the Special Mas-ter's Report of April 28, 1982, the Licensing Board July 27, 1982 decision, or transcript pages.
If you intend to decline to produce documents now, as re-quested on the basis of some objection, please list in your written response to this Request all such documents, setting forth as to each the following:
.g.
s (1)
Date (2)
Author (s)
(3)
Addressee (s)
(4)
Title (5)
Type of document (e.g.,
letter, report, memoran-dum, etc.)
(6)
Subject matter (without revealing the in-formation as to which the objection is made).
(7)
Basis for the claimed objection.
(8)
Identity of all persons to whom TMIA distributed or sent copies of such documents.
If TMIA dis-tributed or sent such documents to another per-son, provide copies of all correspondence re-lated to such distribution or delivery.
s
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If any documents responsive to this Request were, but no longer are, in your possession, custody or control, please fur-nish a description of each such document, state the manner and circumstances under which it left your possession, custody or control, and the document's present whereabouts, if known.
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:
April 9, 1986 l
l s
s April 9, 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)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "GPU Nuclear Corporation's First Interrogatories and Requests for Production of Documents to Three Mile Island Alert," dated April 9, 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 de-livery, or as indicated by two asterisks, by Federal Express, this 9th day of April, 1986.
- Morton B. Margulies, Esquire i
Administrative Law Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- George E. Johnson, Esquire I
i Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555
o Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Ms. Louis Bradford Three Mile Island Alert 1011 Green Street Harrisburg, PA 17102
- Michael Maupin, Esquire Hunton & Williams P. O.
Box 1535 Richmond, VA 23212 4
Swa /3.h Deborah B.
Bauser l.-
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