ML20203L601
| ML20203L601 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 04/28/1986 |
| From: | Johnson G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| CON-#286-965 CH, NUDOCS 8605010311 | |
| Download: ML20203L601 (46) | |
Text
{{#Wiki_filter:F ,~ geo coResronWSA F UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION h
*g BEFORE TIIE ADMINISTRATIVE LAW JUDGE O
$$[!ffly .
In the Matter of ) jlj4CMN'/Q'
)
GENERAL PUBLIC UTILITIES NUCLEAR ) Docket No. 50-289 (CH)
)
(Three Mile Island Nuclear Station, ) Unit No.1) ) NRC STAFF RESPONSES TO TMIA'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS AND FIRST INTERROGATORIES TO THE NUCLEAR REGULATORY COMMISSION STAFF I. INTRODUCTION The NRC Staff hereby serves its responses to "TMIA's First Request for Production of Documents and First Interrogatories to the Nuclear Reg-ulatory Commission Staff." 1,/ II. ANSWERS TO INTERROGATORIES INTERROGATORY 1 Identify th'c Office of Inspection and Enforcement (OIE) investigator (s) who interviewed Charles Husted on July 29, 1981.
~1/
At the prehearing conference of February 19, 1986, the staff agreed to provide discovery responses voluntarily, according to the sched-ule initially agreed upon by the parties, and ratified in the Report and Order of February 27, 1986. Record Transcript at 64-65. ^ Thus, while 10 C.F.R. 52.720(h)(2)(ii), rather than 10 C.F.R. 52.740(b), applies to interrogatories to the Staff, the Staff has agreed to provide responses to interrogatories as if it were subject to the latter provision. Similarly, without waiving the applicability of 10 C.F.R. 52.741(e), the Staff has agreed to voluntarily respond to document requests not subject to objection on other grounds. k* PDR 3so7
s 0
RESPONSE
Raymond H. Smith Currently: Emergency Preparedness Specialist - At time of interview: NRC Investigator Nuclear Regulatory Commission, Region I 631 Park Avenue King of Prussia, PA 19406 215-337-5392 Robert K. Christopher Currently: Assistant to Regional Administrator At time of interview: NRC Investi ator F Nuclear Regulatory Commission, Region I 631 Park Avenue King of Prussia, PA 19406 215-337-5138 Response provided by Raymond H. Smith. - INTERROGATORY 2 Identify all persons present during Ilusted's interview.
RESPONSE
See response to Interrogatory 1. After reviewing pages 39 and 16 of the Reports df Investigation, dated August 11, 1986 and October 13, 1981, respectively, and a memorandum from P.G. Christman to John F. Wilson, dated July 29, 1981, Raymond Smith has no present recollection of either the interview he participated in with Charles Husted on July 29, 1981, whether he took notes, or the circumstances surrounding the writ-2_/ Individuals providing responses are hereinafter designated by their last name, enclosed in parentheses. For detailed information con-cerning these individuals, consult attached affidavita and qualifica-tion statements.
s ing of the Report of Interview. He has conferred with Robert K. Chris-topher who informed Mr. Smith that he similarly has no present recollection of t,hese matters. Mr. Smith has no notes or other documentation that might be used to refresh his recollection independent of the above cited documents. He has conferred with Robert K. Christopher, who informed him that Mr. Christopher has no notes or other documentation relative to this matter. As an investigator / inspector, Mr. Smith has conducted approximately 100 interviews per year since 1973. These interviews have ranged from formal documented interviews to less formal oral exchanges. He does not recall anything specific concerning the interview in question . Mr. Christopher's duties have required him to conduct a similar number of interviews since 1980. (Fmith) Because the Staff's investigators involved in the July 29,1981 inter-view of Charles Husted have no present recollection of the interview or of the preparation of the Report of Interview and we are aware of no docu-ments on the interview other than that noted above and the testimony in the restart proceeding, the Staff has little or no information responsive to this interrogatory or the series of interrogatories below which seek infor-mation about the details and responses of the July 29, 1981 Husted inter-view and Report of Interview. (Dick) INTERROGATORY 3 Where did the interview take place?
~
s 9
RESPONSE
See response to Interrogratory 2. (Smith) . The Staff has no fur-ther information responsive to this interrogatory. (Dick) . INTERROGATORY 4 How long did the interview last?
RESPONSE
See response to Interrogatory 2. (Smith). The Staff has no fur-ther information responsive to this interrogatory. (Dick) . INTERROGATORY S Did the investigator (s) who interviewed Husted take notes of the interview?
RESPONSE
See response to Interrogatory 2. (Smith) . The Staff has no fur-ther information iesponsive to this interrogatory. (Dick) . INTERROGATORY 6 Was the interview taped?
RESPONSE
See response to Interrogatory 2. (Smith). The Staff has no fur-ther information responsive to this interrogatory. (Dick) .
INTERROGATORY 7 Did the investigator (s) who interviewed Husted prepare the report which appears at Page 39 of the Report of Investigation dated August 11, 1981? ,
- a. If the answer to Interrogatory No. 7 is no, identify the person (s) who prepared the report.
RESPONSE
See response to Interrogatory 2. (Smith) William Ward has informed the Staff that neither he nor Edward Gilbert remembers who prepared the information on page 39 of the referenced report. The Staff has no fur-ther information responsive to this interrogatory. (Dick) INTERROGATORY 8 Were drafts of the Report of Investigation submitted for comment or editing prior to the issuance of the final report?
- a. If the answer to Interrogatory No. 8 is yes, identify all persons who commented on or who edited drafts of the report.
RESPONSE
See response to Interrogatories 2 and 7. The Staff has no further information responsive to this interrogatory. (Smith, Dick) INTERROGATORY 9 Was any portion of the investigator (s) initial draft of the Husted interview omitted from the final report? If your answer is yes;
- a. What was omitted from the final report?
- b. Identify the person (s) who authorized the omissions.
- c. State the reasons for the omissions.
e
RESPONSE
See response to Interrogatories 2 and 7. The Staff has no further information responsive to this interrogatory. (Smith, Dick) INTERROGATORY 10 After the July 29, 1981 interview of Husted and prior to drafting the report of the interview, did the investigator (s) consult with other OIE staff or with NRC legal staff concerning what information should be in-cluded in the report? If your answer is yes;
- a. With whom did the investigator (s) consult?
- b. What advice was provided?
.c. How was the report changed as a result of the consultation?
RESPONSE
See response to Interrogatory 2. (Smith) William Ward has informed the Staff that neither he nor Mr. Gilbert remembers whether they con-sulted with others concerning preparation of the referenced report . (Dick) INTERROGATORY ' 11
.Sta.te specifically the questions that were put to Husted during the July 29, 1981 interview,
RESPONSE
See response to Interrogatory 2. (Smith) . The Staff has no fur-ther information responsive to this interrogatory. (Dick) .
s-o- INTERROGATORY 12 State . specifically his answers to the questions asked in the interview .
RESPONSE
See response to Interrogatory 2. ( Smith) . The Staff has no fur-ther information responsive to this interrogatory. (Dick) . INTERROGATORY 13 During the July 29, 1981 interview, did Husted appear to be con-fused by the investigator (s)' questions?
RESPONSE
See response to Interrogatory 2. (Smith) . The Staff has no fur-ther information responsive to this interrogatory. (Dick) . INTERROGATORY 14 Did Husted request clarification of any of the questions put to him?
RESPONSE
See response to Interrosratory 2. (Smith) . The Staff has no fur-ther information responsive to this interrogatory. (Dick) . INTERROGATORY 15 If Husted requested clarification , did the investigator (s) supply clarification?
RESPONSE
See response to Interrogatory 2. (Smith) . The Staff has no fur-ther information respone've to this interrogatory. (Dick) . INTERROGATORY 16 Did Husted appear to understand the questions as clarified?
RESPONSE
See response to Interrogatory 2. (Smith) . The Staff has no fur-ther information responsive to this interrogatory. (Dick) . INTERROGATORY 17 Did Husted request permission not to respond to the investigator (s)' questions?
RESPONSE
See response to Interrogatory 2. (Smith) See also Answer to
~
Interrogatory 4 of Mr. Husted's Answers to NRC Staff's First Interrogato-ries and Request for Production of Documents. (Dick) INTERROGATORY 18 Did Husted offer an explanation for not responding to it.iestigator(s)' questions?
a
RESPONSE
See response to Interrogatory 2. (Smith) See also, notes of Richard A. Matakas, from the September 18, 1981 interview, attached, the draft report of that interv'7w by Pir. Matakas, attached, and p.16 of former Staff Exhibit 27, Report of Investigation, dated October 13, 1981. (Dick) . INTERROGATORY 19 If you have answered yes to Interrogatory No.18, state Ilusted's explanation.
RESPONSE
The explanation of which the Staff is aware is contained in the docu-ments referenced in response to Interrogatory 18. (Dick). INTERROGATORY 20 Which questi,ons caused Ilusted to be confused?
RESPONSE
See response to Interrogatory 2. (Smith) . The Staff has no fur-ther information responsive to this interrogatory. (Dick) . INTERROGATORY 21 Which questions did Husted decline to answer?
O
RESPONSE
See response to Interrogatory 2. (Smith) See also, response to Interrogatory 18 and former Staff Exhibit 26, Report of Investigation,
~
dated August 11, 1981, at 39. Responsive information may also be found in Mr. Husted's Answers to NRC Staff's First Interrogatories and Re-quests for Production of Documents, response to Interrogatory 4, at 8-9. (Dick) . INTERROGATORY 22 If liusted requested permission to not respond to investigator (s)' questions, explain why that information did not appear in tne final report of the interview.
RESPONSE
See response to Interrogatory 2. (Smith) . The Staff has no fur-ther information responsive to this interrogatory. (Dick) . INTERROGATORY 23 Did the investigator (s) take notes during the interview?
RESPONSE
See response to Interrogatory 2. (Smith) INTERROGATORY 24 If you have answered ves to Interrogatory No. 23, how extensive were the investigator (s)' notes?
6
RESPONSE
N.A. (Smith) INTERROGATORY 25 How soon after the July 29, 1981 interview of Husted was the first draft of the report written?
RESPONSE
See response to Interrogatory 2. (Smith) Mr. William Ward has informed the Staff that neither he nor Mr. Gilbert remembers the circum-stances of preparation of the report of the July 29, 1981 interview. (Dick) INTERROGATORY 26 Did Husted request that Paul G. Christman be present during the July 29, 1981 interview? RESPONSE . See response to Interrogatory 2. (Smith) See also, Answer to Inter-rogatory No.1 (indicating an affirmative answer), Response of GPU Nu-clear Corporation to TMIA's First Request for Production of Documents and First Interrogatories to General Public Utilities Nuclear. (Dick) INTERROGATORY 27 If you have answered yes to Interrogatory No. 26, when did Husted make the request?
_ RESPONSE See response to Interrogatory 2. (Smith) The Staff has no informa- , tion responsive ,to this interrogatory. (Dick) INTERROGATORY 28 If you have answered yes to Interrogatory No. 26, did Husted ex-plain why he wanted Christman present during the interview?
RESPONSE
See response to Interrogatory 26. (Smith) The Staff has no infor-mation responsive to this interrogatory. (Dick) INTERROGATORY 29 If you have answered yes to Interrogatory No. 28, state Ilusted's reason for wanting Christman present.
RESPONSE
See response to Interrogatory 28. (Dick) INTERROGATORY 30 Did Christman say anything during the interview?
RESPONSE
See response to Interrogatory 7. (Smith). The Staff has no fur-ther information responsive to this interrogatory. (Dick) .
INTERROGATORY 31 If you have answered yes to Interrogatory No. 30, what did Christman say?
RESPONSE
N. A. (Smith) INTERROGATORY 32 Did the investigator (s) inform ilusted of his right to have counsel present during his interview?
RESPONSE
See response to Interrogatory 2. (Smith) INTERROGATORY 33 Describe Husted's demeanor during the interview.
RESPONSE
See response to Interrogatory 2. (Smith) INTERROGATORY 34 Did the investigators agree that the report of Husted's July 29, 1981 interview , which appears at Page 39 of the August 11, 1981 Report of Investigation, was accurate and complete?
RESPONSE
See response to Interrogatory 2. (Smith) . The Staff has no further information responsive to this interrogatory. (Dick) . INTERROGATORY 35 If you have answered no to Interrogatory No. 34, state the name of the person (s) who disagree.
RESPONSE
N. A. (Smith) INTERROGATORY 35 If you have answered no to Interrogatory No. 34, state the areas of disagreement.
RESPONSE
N. A. (Smith) INTERROGATORY 37 Identify all persons involved in the decision to re-interview Husted.
RESPONSE
Mr. Matakas does not recall who instructed him to interview Mr. Husted on September 18, 1981. He does not know whose decision it was to interview Mr. Husted. (Matakas) The Staff has requested re-sponsive information from Messrs. Ward and Gilbert , at Headquarters ,
NRC Office of Investigations. Messrs. Ward and Gilbert have no recollection of who decided to re-interview Mr. Husted. (Dick) . INTERROCATORY 38 Identify all persons present during the September 18, 1981 interview of Husted.
RESPONSE
To the best of Mr. Matakas' recollection, only Mr. Husted and Mr. Platakas were present during the September 18, 1981, interview. (Matakas) . i j INTERROGATORY 39 ,' Identify the investigator (s) who conducted the September 18, 1981 l interview of flusted.
RESPONSE
Richard A. Matakas. Investigator, U.S. NRC, 631 Park Avenue, j King of Prussia, PA 19406, 215-337-5338. (Matakas), i INTERROGATORY 40 How long did the September 18, 1981 interview last?
RESPONSE
To the best of Mr. Matakas' recollection, the September 18, 1981 interview lasted approximately thirty minutes. (Matakas).
INTERFOGATORY 41 Was the September 18, 1981 interview taped? RESDONSE a To the best of Mr. Matakas' recollection, the September 18, 1981, intervitw was not taped. (Matakas) . INTERROGATORY 42 Did the investigator (s) who interviewed flusted on September 18, 1981 take notes of the interview?
RESPONSE
Richard A. Matakae did take notes of the September 18, 1981 inter-view . A copy of said notes is attached to this response. The notes (3 pages) are in Mr. Matakas' handwriting and the first page of these notes are dated "9-18-81" with his inlitals " RAM," next to the date. To the best of Mr. Matakas' recollection, within a day or two of the September 18, 1981 interview, he typed a draft report based on notes and subsequently pro'vided both his notes and draft report to Peter Baci, who at the time was an NRC investigator for the Office of Inspection and En-forcement, Bethesda, Maryland. Mr. Matakas' typed dra't report is attached to this response. The typed draft report is one page, titled: " Charles E. HUSTED, Instructor for License Operator Training." Mr. Matakas' initials " RAM" and the date of the interview, "9-18-81," are noted at the top of the page. Mr. Daci was the case agent, who left the NRC a couple of years ago to work for the Defense Criminal Investigative Service (DCIS) in the DC area.
Mr. Matakas' notes and draft report are being held by George E. Johnson , Counsel for the NRC staff, Bethesda, Maryland. (Matakas) INTERROGATORY 43 Did the investigator (s) who interviewed Husted on September 18, 1981 prepare the report which appears at Page 16 of the investigative report designated Staff Exhibit 27 in the reopened hearing on cheating?
RESPONSE
To the best of Mr. Matakas' recollection, he did not prepare the report in question, but it appears to have been prepared based on the draft report of the interview. Mr. Matakas consulted with Edward Gil-bert, who told him Mr. Gilbert did not remember whether Mr. Baci or Mr. Gilbert prepared the final report. (Matakes). INTERROGATORY 44 If the answer to Interrogatory No. 43 is no, identify the person (s) who prepared the. report.
RESPONSE
See response to Interrogatory 43. (Matakas). The Staff has no further information responsive to this interrogatory. (Dick) . INTERROGATORY 45 Were drafts of Staff Exhibit 27 submitted for comment or editing pri-or to the issuance of the nnal report? i i
RESPONSE
See response to Interrogatory 43. (Matakas). The Staff has no further information responsive to this interrogatory. (Dick) . INTERROGATORY 46 If the answer to Interrogatory No. 45 is yes, identify all persons who commented on or who edited drafts of Staff Exhibit 27.
RESPONSE
See response to Interrogatory 43. (Matakas) . The Staff has no further information responsive to this" interrogatory. (Dick) . INTERROGATORY 47 Was any portion of the investigator (s)' initial draft of the September 10, 1981 Husted interview omitted from the final report? If your answer is yes;
- a. What was omitted from the final report?
- b. Identify the person (s) who authorized the omissions,
- c. State the reasons for the omissions.
RESPONSE
No. See draft report of interview prepared by Mr. Matakas de-scribed in response to Interrogatory 42. (Matakas) INTERROGATORY 48 After the September 18, 1981 interview of Ilusted and prior to draft-ing the report of that interview, did the investigator (s) consult with oth-
er OIE staff or with NRC legal staff concerning what information should be included in the report? If your answer is y7s;
- a. With whom did the investigator (s) consult?
- b. What advice was provided?
- c. How was the report changed as a result of the consultation? :.
RESPONSE
Mr. Matakas' draft report of the September 18, 1981, interview is attached to this response. He did not consult with anyone concerning what information should be included in the draft Report of Interview (at-tached as stated). (Matakas) INTERROGATORY 49 State specifically the ouestions that were put to Husted during the September 18, 1981 interview .
RESPONSE
Mr. Matakas cannot specifically recollect the exact questions that he asked Mr. liusted on September 18, 1981. (Matakas) INTERROGATORY SO State specifically his answers to the questions asked in the September 18, 1981 interview,
RESPONSE
To the best of Mr. Matakas's recollection, Mr. Husted's answers to his questions are recorded in the attached draft Report of Interview and handwritten notes previously identified. (Matakas)
c, INTERROGATORY 51 Did Ilusted volunteer the information about " passing papers during the exam"?
RESPONSE
Mr. Matakas does not specifically recall Mr. Husted " volunteering" any information durinF the September 18, 1981, interview. As he recalls, the information Husted provided was in response to Mr. Matakas' ques-tions. (Matakas) 4
- INTERROGATORY 52 Did Husted state why he had not supplied the information concerning passing papers during his July 29, 1981 interview?
RESPONSE
1 Based on a review of Mr. Matakas' notes taken during the September 18, 1981, interview Mr. Husted did give his reason el to why he did not supply the information concerning the " passing" of " papers" during his July 29, 1981 interview. (Matakas) l INTERROGATORY 53
> If the answer to No. 52 is yes, state the explanation llusted gave for not supplying the information during the earlier interview.
RESPONSE
Based on a review of Mr. Matakas' notes taken during the September 18, 1981, interview, Mr. Husted said the reason that he did
-. ,-- -e-- a - , - - , , _ - , - ~ - , , ,,, _ , . - , . , ,,e. ,-w--7<, n-, -, -.,--,,-..+,,r,
not provide the " passing papers" information to the investigators during his earlier interview was because the questions he was asked were so broad that he just could not give a specific answer. (Matakas) INTERROGATORY 54 Did the investigator (s) share Husted's opinion that the questions asked by investigator (s) during the July 29, 1981 interview were too broad to be answered specifically?
RESPONSE
Mr. Matakas does not know. (Matakas) . See also response to Interrogatory 2. (Smith) . The Staff has no further information responsive to this interrogatory. (Dick) . INTERROGATORY 55 During his testimony before the Special Plaster, William J. Ward stat-ed that it was his opinion and the opinion of the investigator (s) who in-terviewed Husted, that Husted was not being truthful when he stated that he did not recall who made the statement about " passing papers in the exam." Is Ward's statement an accurate recounting of the investigator (s)' opinion (s)?
RESPONSE
The investigator, Mr. Matakas, does not recall expressing his opin-fon about Mr. Ilusted's veracity to Pir. Ward and does not at this time have an opinion relating to Mr. Husted's veracity. (Matakas) .
INTERROGATORY 56 If the investigator (s) share IVard's opinion regarding the veracity of Husted's statement, state the basis for their opinion.
RESPONSE
See response to Interrogatory 55. (Matakas) . INTERROGATORY 57 Did the investigator (s) indicate to Husted the fact that they did not believe his statement?
RESPONSE
The investigator, Mr. Matakas, does not specifically recall telling Mr. Husted that he believed or disbelieved the information he provided on September 18, 1981. (Matakas). INTERROGATORY 58 Did the investigator (s) advise Husted at any time that his lack of cooperation with the NRC investigation might affect his operating license?
RESPONSE
Mr. Matakas did not advise ilusted that his lack of cooperation with the NRC investigation might affect his operating license. (Matakas) See response to Interrogatory 2. (Smith) . The Staff has no further informa-tion responsive to this interrogatory. (Dick) .
r INTERROGATORY 59 Describe Husted's demeanor during the September 18, 1981 interview.
RESPONSE
Due to the passage of time since the September 18, 1981 interview, Mr. Matakas cannot recall Mr. Husted's demeanor during the interview. (Matakas) . INTERROGATORY 60 During testimony before the Special Master, Mr. Ward revealed that investigators had received testimony from Mr. P in which Mr. P alleged that Ilusted had made an unsuccessful attempt to cheat during the SRO portion of the April 1981 NRC licensing exam.
- a. Explain why this allegation does not appear in Staff Exhibit 27,
- b. Identify all persons who were involved in the decision to omit the allegation from Staff Exhibit 27.
RESPONSE
- a. See attached Draft Memorandum for Record, prepared February 20, 1986, by Peter F. Baci. See also, testimony of William Ward Tr. 25320, 25417-18 where Mr. Ward explains why the allegation was not included in the report. Mr. Ward has informed the Staff that he has nothing to add to his testimony. (Dick)
- b. See response to Interrogatory 60s. (Dick)
INTERROGATORY 61 Identify all persons present during the September 25, 1981 interview of Mr. P.
RESPONSE
According to the hearing transcript of December 2 1981, William Ward testified that Messrs. Baci and Smith, were at the September 25, 1981 interview of Mr. P, in addition to Mr. Ward. Tr. 25459. (Dick) . Raymond Smith has no recollection of attending or participating in the interview with Mr. P. (Smith) . INTERROGATORY 62 Did the investigators take notes of the interview of Mr. P.
RESPONSE
Mr. Ward testified , " took only fragmentary notes...I do not
...I believe anyone else took notes during that particular interview."
Tr. 25,464. Mr. Ward has informed the Staff that he has nothing to add to his testimony. See also, attached draft Memorandum for the Record, and attached notes of Peter Daci. See response to Interrogatory 61. (Dick ) . INTERROGATORY 63 Was the interview of Mr. P taped?
RESPONSE
The Staff has no information to indicate the interview was taped. See response to Interrogatories 61, 62. (Dick) .
INTERROGATORY 64 State specifically the questions which led to Mr. P's revelation of Husted's attempt to cheat.
RESPONSE
See attached draft Memorandum for the Record of Peter E. Haci, prepared January 20, 1986 in connection with the proceeding; testimony of Mr. "P," Tr. 26,754-757; Interrogatory 61 and testimony of Mr. Ward, Tr. 25,462-465, 25,316-317. Pir. Ward has informed the Staff that he has nothing to add to his testimony. (Dick) . INTERROGATORY 65 State specifically Mr. P's responses to the questions concerning Husted's attempt to cheat.
RESPONSE
See, Staff Exhibit 27, referenced above, at 40-41, draft Memorandum for the Record and notes of Peter Daci, referenced above, testimony of William Ward, .Tr. 25,462-465, 25,316-317 testimony of Mr. "P ," Tr. 26,754-757. See also response to Interrogatory 61. (Dick), i INTERROGATORY 66 Did Mr. P appear confused by the questions? i RESPONSE \ i See response to Interrogatory 61 and 65. The above Interrogatory i was provided to Mr. William Ward, of the Office of Investigations for any i l i
/
s t - responsive information. He han informed the Staff that he believes Mr. P was not confused. (Dick) . s INTERROGATORY 67 Did Mr. P request clarification of the questions? t
RESPONSE
See response to Interrogatories 61. Based on the draft Memorandum for the Record of Peter E. Baci, the testimony of Mr. Ward, Tr. 25,462-65, 25,316-17, and the testimony of fir. "P," Tr. 26,754-57, 1 j there are no statements indicating that Mr. "P" requested clarification of { the questions. (Dick) .
- INTERROGATORY 68 Ilow long did the interview with Mr. P last?
l RESPONSE , i See response to Interrogatory 61. The Staff has provided this in-terrogatory to Mr. Ward, who has informed the Staff that he has no ree-ollection of the length of the interview with P. (Dick) INTERROGATORY 69 , Did any of the investigators indicate to Mr. P. that they were not interested in whether Husted had attempted to cheat? j , i
RESPONSE
See response- to Interrogatory 61. Mr. Ward testified as to what he indicated to Mr . "P" in this regard at Tr. 25,461-62. Mr. Ward has in-formed the Staff that he has nothing to add to his testimony at Tr. 25,461-2. (Dich) . 1 INTERROGATORY 70 1 Did all of the investigators remain in the room continuously through-out the interview of Mr. P? i
- RESPONSE 4
See response to Interrogatory 61; draft Memorandum for the Record by Peter E. Baci, referenced above; testimony of Mr. "P ," Tr. 26,725-726; and testimony of William Ward, Jr. 25,459-60. (Dick) . t INTERROGATORY 71 If the answer to Interrogntory No. 70 is no, identify the investiga-tors who left the' interview room and the duration of their absence.
RESPONSE
Sec response to Interrogatory 70 and documents and transcripts ref-
- crenced therein. (Dick) .
i l INTERROGATORY 72 l Identify any and all investigators who remained in the interview room i continuously throughout the interview of Mr. P. 4
- . - . - --<.,_,-n.-, - , - - , . . , - . - - - - --.--n- - , - - - . . . - , . ,-.....--,c,,,, -
RESPONSE
See response to Interrogatory 70 and documents and transcripts ref-erenced therein. (Dick) . INTERROGATORY 73 Did all 'of the investigators take notes of the interview of Mr. P?
RESPONSE
See responses to Interrogatories 61 and 62, attached draft Memoran-dum for the Record by Peter B aci, and attached notes of Mr. Baci. (Dick) . INTERROGATORY 74 Did all of the investigators who participated in the interview of f',_ Mr. P have input into the final report?
RESPONSE
See draft Memorandum for the Record by Peter Daci, referenced above, response to Interrogatories 61, and testimony of Mr. Ward, Tr. 25,417, indicating that Mr. Ward solely prepared the report of the inter-view of P. (Dick) . INTERROGATORY 75 Did all of the investigators who participated in the interview of Mr.P agree that the final report accurately reflected the actual interview? I y w-- .c e - v- <,
9
RESPONSE
See responses to Interrogatory 74. (Dick) . INTERROGATORY 76 Identify any and all investigators who participated in the interview of Mr. P and who did not agree that the final report was an accurate representatio~n of the interview.
RESPONSE
See draft of Memorandum for the Record by Mr. Baci, and testimony of Mr. Ward, Tr. 25.464-65, indicating their agreement as to the reasons for excluding the alleged solicitation from the report. The Staff has no other information responsive to this interrogatory. (Dick) . III. RESPONSE TO REOUEST FOR DOCUMENTS REQUEST Please provide any and all documents of whatever description, identified in your answers to the above TMIA interrogratories. If you maintain that some documents should not be made available for inspec-tion , you should identify the document as to date , title, author, recipient , and subject matter, and explain why such documents are not being made available.
RESPONSE
All documents identified in the foregoing responses to Interrogatories are either attac.hed or are available as part of the public record on Dock-et No. 50-289 (Restart) or Docket No. 50-289(CH). FO 1E NRC STAFF Y orge . Jo so Couns for C Staff Dated at Bethesda, Maryland this 08th day of April,1986
/ '
A {L) w &
~
g >y
~
o p ?g5pD J
%,1h% Ch' v
g pt ..uV{r J e , e r e Ws' e-d ' ,w ly y*
- l
%q HW f V7p fl & }pln'"'<s ) es#9
/ x A/SaA4x d z % , G&
\G
\
*-ADvh _ ..
x wa-n7r%4kKh n ~ _.
~
1 sd xwyna
- )\
< e- _n . , , ~ -
- t. /
\_}N o an AM-._ _n_e.(Anh+s a)
_R L'M .. A}._7._4 r-o Q.,y-m m. i Y _.0 % 0F2* .
/~4.d.f.Yf Of0 --
M- sn fig -.-;7w sawubids,-
% .&4 ..._y pa iw W r-- . . .
g J w/ ? ppa._6f7 g f F.sw% . f' f .y& sw-u . ad u_Z _,.J \ - W _-7 1 L ._ s M 41,1&...- dQf - A. 1+ w uv d -6 7 .
./q ek4% NA:.
&A. c -A9 w khtd p ._.
.. &f-~L..-M d_A_n s L/w - -. -
7p v/t w d v_ .a.i _..M ' t<=....
- .S .. .
.9-y. ' -b.f-l/&i/;7h.69/%.. -
, ~~ ,~ r . .
we fel , etf su e H : fkw3 y
. w t M 5 d:x wr wyh f ;L /) a f),
A2 /n A -Am., ' , 70 a s-
'I lAt h e a/w& . [ &sdd ? JAsinff,rpn 9 d'c'A
- hst a H sp~ 4 ~ ~r s -
i-+9,e n .a6 7 9
/ we, 6c w suu e/f $ ;d. seq
~
4ww- - i lL~J . m' L pw W ~) BP 0644 ( p / !
~
M(v h&u.) luku/de/l.-u%9.ss- h ' msl!rl? y
'J- Q 1I C(rpw~ /goa+. -
'<g . . . . - . . . . . _ . _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ -- m
- m es. %>
l
~ ?k l ..'
.g ,
35.' ; -_ ,
^
S-
.N
,M b - , , ,
,) .h .
/W 4
;i - y/lAdi DWV
~
f4 / z on p er.w 'g-2 gw* en
- y TV 8 dns
/j *
* <l
- v,h
'I 'E *
#1 -
N % ' 2; , y,
~
s s
, /O -
d
'1 C f . .a -
Euft M
~ ~~ ' f. s_
v r"
~
g----$pt-Ctf M-J+-
-e -.e -e_
b O ea 0 8 e N eip - 6 O
z CHARLES E. HUSTED h/ INSTRUCTOR FOR LICENSE OPERATOR TRAINING RE- I HUSTED WAS INTERVIEWED DUE TO HIS RELUCTANCE to IIyrrTrY ANSWER ALL QUESTIONS 4 DIRECTED AT HIM DURING A PREVIOUS INTERVIEW (SEE FIRST REPORT, PP 39) MR. IP1STED STATED THAT THE REASON KIDbtDUQUDDODUDOLR FOR HIS RESPENSF TO QUESTIONS ASKED 01 HIM BY THE NRC ON AN EARLIER DATE WAS BECAUSE HE FELT THAT THE QUESTIONS AD.EIAEEX DIRECTED AT HIM WERE SO BROAD THAT HE JUST COULD NOT GIVE A SPECIFIC ANS~ RTE. MR. HUSTED STATED THAT HE DID NOT OBSERVE ANYONE CHEATING ON THE NRC EXAMS, - KIDCRXIT 7To6%UJ00DODOD00002XKXIIXE AND NO ONE TOLD HIM IHAT THEY TXXX PERSONALLY) HAD CHEATED ON THE EXAMS. MR. HUSTED WAS ASKED TO CLARIFY WHAT HE MEANT BY " UNCONFIRMED HERESAY" IN H'IS 1 PREVIOUd STATEMEIT. HE STATED THAT HE DID HEAR ONE COMMEfG MADE DURING THE TIME PEir?OD OF THE NRC RO/SRO EXAMS WHERE SOMEONE (HE DID NOT RECALL WHO) SAID THEY SAh SOMEONE b bh [ h h$bbG PAPERS IN THE EXAM. HUSTED STATED , , HE HEARD THE COMMENT IN THE AREA NEAR THE COFFEE POT AND MEN'S ROOM IN THE TRAILER THAT WAS LOCATED BETWEEN THE 'IWO CLASSROOMS. HE SAID HE PERSONALLY DID NOT HAVE ANY IXIEDDOLIIEM KNOWLEDGE REGARDING EITHER REFERENCE MATERIAL OR CRIB SHEE[BEINGTAKENINTOTHENRCEXAMS.[HESAID HE DID NOT KNOW IF THE ABOVE MENTIONED ; COMMENT RELATING TO " PASSING PAPERS" WAS BEING DIRECTED AT HIM OR NOTy NWITru 100000DOLIXX AND HE DID NOT KNOW IF THE PERSON WAS REFERRING TO THE NRC EXAMS ! OR SOME OTHER EXAM. HUSTED CONCLUDED STATING THAT HE DID NOT HAVE ANY OTHER INFORMATION WHATSOEVER RELATING TO CHEATING ON THE NRC, RO/SRO, EXAMS.. I -
~
l . 1 e
- .- . < e 3 o .
1 Oute
. - ROUTING AND TRANSMITTAL SUP FB 2 01986 TO: (Name. o# ice sytr. tot, room number, faltets Dete building, Agency /g
- 3. 0&-qc N w u
3. 2.
~a 4.
5. Action File Ipfte and Retum Approval For Cleerence /Per Converset6on As Requested For Correction Propero Reply Circulate For Your Infosmetion See Me . Comment lavestigste Signature Coordination Justify RD4 ARKS
.AA/d
& " ' 4 9 ~ 1'%.
~ ~ _
mad -tL; a e - 4' n.
'5A DO NOT use this form es a RECORD of approvels, concurrences, disposats, clearances, and simskr actions
~
FROM:( ['mbol, Agency / Post) Room No.-Blds.
. Phone No.
8048-102 j OFDONAL FORM 41 (Rev. 7-76) usc.e..us.ssi.sn m. Pres c N -11Jos l
t -
"?. r ~ ~e i
NY? $ MEMORANDUM FOR THE RECORD
SUBJECT:
Interview with Shift Supervisor David C. Janes , Reference is made to NRC Report of Investigation HOS-81-004, dated October 13, 1981, which addresses alleged improprieties on operator licensin:. examinations at the Three Mile Island Nuclear Generating Statio- (Unit 1). During the course of the latter investigation, Mr. David C. Janes, a shif t supervisor at TMI-1, was interviewed by NRC Investigators William J. Ward and Peter E. Baci. The information provided by Janes was reported, in substance, on pages 40 and 41 of the referenced report. The g purpose of this memorandum is to expand upon what was reported e earlier. As previously reported, Janes denied providing assistance to anyone during the course of the RO/SRO examinations conducted on April 23 and 24, 1981. Beyond his denial however, Janes vociferously protested the alleged absence of NRC Proctor Bruce Wilson from the examination room. Jane's concern was that Wilson's alleged absence made him vulnerable to any allegation of cheating. While this concern was certainly understandable, the vehemence of Jane's protest struck both interviewing
] investigators as being somewhat unusual. .
It came out during the interview that Janes was alone in the examination room with Charles E. Husted, an instructor for licensed operator training.- Because of his excessive reaction to Wilson's alleged absence, Janes was told by Mr. Ward that we knew 'd Husted had asked him a question during the examination. In fact we knew no such thing; we merely wanted to see how Janes would react. Janes then acknowledged that Husted had indeed asked'a question, but stated that he, Janes, did not answer Husted and that the question may very well have been rhetorical in nature. Subsequent to returning to NRC HQ, Mr. Ward wrote up the results of the interview as they appear in the referenced report. Prior to writing the report and after a discussion with Victor Stello, then Director, OIE, it was decided that the Husted-Janes matter described above would not be included in the results of the fact interview. This decision was based on the following: that Janes asserted he provided no information to Husted and was not even sure of the nature of the latter's question; that there was no witness to this alleged event; and that, in the opinion of the investigators, the continuation of the probe would have had a more negative impact on the public health and safety than any benefits which might have been derived from it. 3 7 DRAFT ,NO w
,.q- , .
DRAFT with the benefit et hindsight, I would now have included the Husted-Janes matter in the original report; however, I must state for the record that I was not then, not am I now, aware of any f acts which wouldon assistance establish that Husted the RO/SRO cheatedinor examinations otherwise April 1981.' sought t Peter E. Baci w , en
~
e.' ' a c..
^f. . . , -9
'7 ~
. DRAFT :..- - e.,e, d
?. wg
.: .
- Se ,
- e e,b _
*b. e
. y-Q ~ r* 3
.- - - ---n_. .n.__---~ : _. : ::_~127? ' ~ *
.. I b ?EQf. .. .. . $..be,97 .:
Y B .dR(
^
Ml ' n-
~ . -
R" a i c
-{1
/w. cru _Q_ u.. .: .. - -
. ., .. ,7:; _.
.M*d?'/,[ ^ .. y .; .,
=
Wi n__t- _ - :; =. c ^' ' f e . . . 4 I b / [ a = f2 L f l [ [ p h *.*/ f
.(
s r, y Id ... . ._ i.
.L_ . .,f:,.;5QQ + >
.I _ _,
.i :' ' Q s
?q$h)~
f __ _ - s. [j.fNN lj. f*-Q'st fh5 yp.% y'; m ._ , , , . q
~ f93 --- y ;
j.}'1
,3 ?*WT:M. '- '
'C 1+7? e,.,
-N?%l[$? _
gpjvre;m:v... ' ' 4
._ c.
.7,o -~
1 4, A s / -
.-~.-.-
.a 1 s ' ** '* ; .:h Y a
..i
'~*
. . n . .
?.O;.*.:k-.;, I iGf;g "
Q^~Y&;h,* m,Q Q i - ..
)
h $k Vef,ff hffh~ -
$ _'{@' h hk.. '
e .. . _ 5fl7.UfQA[..['W2W4$
... ; - .w.a . .u.:co . 4.y .s fk .,
x 't ', 3 Y 'f pf@@ , j _ -Ef~$h- 5$Yhh'5ij$ _ , fh-N. " Y h h h h . n re l gg'
' " ' ' ' ~ ,,
l ,g.,
.k h
=
=
i a xn
... - - c . , .. ; p.& -
[ .. k-.A '2 T- Tcl n Mr f]cie m a .
~ ~~
- m,.v. ., u..
7 es + . , :. , g=n.
-=
,. . =
n 2 ., - 9 1 .: ,>.. .T n J c.s
- p. s.. , - . . r
- / .: -- - .
_ _ 4.
. 2.. ._
. _. .i ..
.. . . h (, [j] r) $
?
QOf ' 'b ' ' ) ~ j
.i ..
l (t ads . !*Li LII i ' 7< xtoqo
- 3
< a. .
ie-V ' ...,c.. .>.r. _ , . ..'k's. ,
*e**==*
1 .. ., 1 E*DM - ik44sidigijE
?S$h ll22%i69 fi$n8ikau w m. mas F .r m f.&anzatau;eeunku.e'sC LW92%)4@2EWN EM ggg .,,.p.
- m. ,
,t, I
. .._14 % ~hd.O _ _
n?: -
.. e ,
~'
f i[ ' ", '.-j
- w,. . C h'i_ ' ' s -
_s$$Yh?$5$$N5k$$?r??;hk
- xe .. ' W .
0% M BR..,% %. Qgium ...
;k._. ,
7 m l l . _ m r
UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE , In the matter of )
)
GENERAL PUBLIC UTILITIES NUCLEAR ) Docket No. 50-289 (CH)
)
(Three Mile Island Nuclear Station, ) Unit No. 1) ) AFFIDAVIT OF RAYMOND H. SMITH I, Raymond H. Smith, being duly sworn, depose and state that:
- 1. I am an employee of the U. S. Nuclear Regulatory Commission (NRC).
My present position is Emergency Preparedness Specialist in the Emergency Preparedness and Radiological Protection Branch, Division of Radiation Safety and Safeguards within Region I. My current address and telephone number are: 631 Park Avenue, King of Prussia, Pa,19406,(215)-337-5392. In 1981 I was an Investigation Specialist in the Security and Investigation Section of the Safeguards Branch. A copy of my professional qualifications is attached.
- 2. I am duly authorized to participate in answering TMIA's First Request for Production of Documents and First Interrogatories to the Nuclear Regulatory Commission Staff, and I hereby certify that my answers given to Interrogatories 1 through 37, 58 and 61 are true to the best of my knowledge.
$')tfe"?n&wr s ,
Subscribed and sworn to before me i this fd d day of April, 1986.
'?C f.a/ A. lx b =
Notary Public My Commission Expires: M f4 /F8f t l
PROFESSIONAL QUALIFICATIONS 0F RAYMOND H. SMITH
. ; f OCTOBER 1981 - Present: I am assigned to the U. S. Nuclear Regulatory .' ' ,
Commission, Region I, King of Prussia, Pennsylvania. 19406. My.currenti ,. assignment is Emergency Preparedness Specialist, Emergency Prepared ' Section,EmergencyPreparednessandRadiologicalProtectionBranch,t Division ~g cf Radiation Safety and Safeguards. Ny responsibilities include the review and . inspection of emergency response plans and exercises.
~
DECEMBER 1968 - OCTOBER 1981: I was assigned as an Investigations Specialist in the Security and Investigation Section of the Safeguards Branch in May, 1973. Prior to that I performed as a Radiation Specialist and as an Acting Chief of the Materials Radiological Protection'Section.and the Radiation Support Section in the Fuel Facility and Materials Safety Branch. . Prior to joining the AEC, I was employed at the AEC Hanford Works, Richland, Washington, for 21 years. The following specific duties and assignments were performed during the periods
' indicated: ,
NOVEMBER 1947 - OCTOBER 1949: I was assigned as a safety inspector on the construction of nuclear plants. My responsibilities included the inspectioh of construction activities, investigation of personnel and vehicle accidents, loss of materials and settlement of insurance claims. OCTOBER 1949 - MAY 1964: I was assigned to the Health Physics Division and performed the duties of a Radiation Monitor, Analyst, and Supervisor. These assignments were in Fuel Fabrication Facilities, Reprocessing Plants, , Laboratories, and Reactors.
. t MAY 1964 - OCTOBER 1968: I was assigned to!the.. Radiological Engineering Department as a Health Physics Engineer. My duties included the investigation of radiological incidents, establishing inspection programs, their cri.teria and guides for program appraisal. I wrot'e procedures, standards and training programs.
1 EDUCATION AND TRAINING: High School Graduate, Houstonia, Missourt - 1940 l Central Business College, Sedalia, Missouri - 1941 Attended school courses conducted by the General Electric Company in Health Physics, Professional Business Management, Technical Report Writing and Human Relations - 1952 to 1962. ) i
gFR 23 '06 14r19 NRC KING OF PRUSSIA P02 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
-]~ BEFURb IHE ADM.NISTRATIVE LAW JUDGE In the matter of )
)
GENERAL PUBLIC UTILITIES NUCLEAR ) Docket No. 50-289 (CH)
)
(Three Mile Island Nuclear Station, ) Unit No. 1) ) AFFIDAVIT OF RICHARD A. MATA GS I, Richard A. Matakas, being duly sworn, depose and state that:
- 1. I am an employee of the U. 5. Nuclear Regulatory Commission (NRC).
My present position is Ser cr Investigator within the Office of Investigations within Reg on 1. My current address and telephone number are: 631 Park Avenue, King of Prussia, Pa, 19406, (215)-337-5305. In 1991 I was an Investigator within the Office of Inspection and Enforcerent Region I. A copy of my professional qualifications is attached
- 2. I am duly authorized to participate in answering TMIA's First Request for Production of Document:. and First Interrogatories to the Nuclear Regulatory Commission Staff, and I hereby certify that my answers given to Interrogatories 37 through 59 are true to the best of my knowledge.
f~ f js/
; &_ L (* %
Subscribed and sworn to before me this 7) J day of April, 1986.
,w z t a . / A U.ary Public My Commission Expires: M &, /ftr
o RICHARD A. MATAKAS Organization: Office of Investigations. 01 Field Office Region I
Title:
Investigator Grade: GS-N //[J-Birth Date: Septe%ber 10, 1946 Education: B. S. Political Science, Eastern Michigan University t Completed nine hours graduate work in Public Administration, Golden Gate University Experience: . 1981 - Present Investigator, Office of Investigations US NRC - Assignments include directing and planning as well as conducting sensitive and complex investigations of allegations, incidents or accidents at or related to NRC licensed facilities or activities. 1980 - 1981 Special Agent, Naval Investigative Service (NIS) - Assistant Special Agent in charge of the NIS Of fice, Master Jet Base, Oceana, VA. Assigned and conducted major criminal investigations, security violation investigations and counter espionage investigations as they related to the Department of the Navy. 1978 - 1980 Special Agent, NIS - Representational Special Agent in charge of the NIS Of fice, Fleet Combat Training Center, Atlantic. Maintained one man Naval investigative Service office. 1977 - 1978 Special Agent, NIS - Resident Agent on board the USS Nimitz (CVN-68). Provided investigative service to the U. S. Navy Sixth Fleet (deployed). 1975 - 1977 Special Agent, NIS - Provided investigative service to the Naval Construction Battalion Center, Gul fport, MS. 1973 - 1975 Special Agent, Florida Department of Law Enforcement - Conducted criminal investigations involving organized crime, public official corruption and major felonies outside the expertise and jurisdic-tional limits of local law enforcement. 1969 - 1973 Patrolman,
Dearborn,
MI Police Department - Provided general police patrol duties for two years and was a member of the cities Special Operations Unit (Plain Clothes Felony Squad) for two years. 1966 - 1969 US Army - First Lieutenant, Artillary L
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE TIIE ADMINISTRATIVE LAW JUDGE In the Matter of . )
)
GENERAL PUBLIC UTILITIES NUCLEAR ) Docket No. 50-289 (CH)
)
(Three Mile Island Nuclear Station, ) Unit No.1) ) AFFIDAVIT OF GEORGE F. DICK, JR I, George F. Dick, Jr. , being duly sworn, depose and state that:
- 1. I am an employee of the U.S. Nuclear Regulatory Commission (NRC). My present position is Project Manager in PWR Project Directorate
#6, Division of PWR Licensing-B within the Office of Nuclear Reactor Regu-lation. My current address and telephone are: 7920 Norfolk Ave, Bethesda, MD 20814, (301) 492-8101. A copy of my professional qualifications is attached.
- 2. I am duly authorized to participate in answering TMIA's First Request for Production of Documents and First Interrogatories to the Nuclear Regulatory Commission Staff, and I hereby. certify that my answers given to Interrogatories 2 thru 22, 25 thru 30, 34, 37, 44, 45, 46, 54, 58, and 60 thru 76 are true to the best of my knowledge.
. it'4K A g George F. Dick, JY.
Subscribed and sworn to before me this 28th day of April,1986.
*Y<I L ~ je<re)
/ Notary Public My Commission Expires: [:/,/((6
/
U
r-e PROFESSIONAL QUALIFICATIONS OF _. GEORGE F. DICK JR. I am employed at the United States Nuclear Regulatory Commission as a Project Manager. In that capacity, I manage and participate in the review and evaluation of safety and environmental considerations associated with the design and operation of nuclear power facilities, particularly those licensed for operation. I joined the Nuclear Regulatory Commission in June,1982. From 1974 to 1982, I was employed by the United States Department of Energy and it predecessor agencies as both a Project and Program Manager for several coal liquefication pilot plants. The plants were used to assess the applicability of coal liquefication processes for commercialization. From 1968 to 1974, I was employed by Exxon Research and Engineering Company as a Research Engineer. I participated in the development of Exxon's coal liquefication technology and improvement of selected petroleum refining processes. From 1962 to 1964, I was employed by the United States Naval Oceanographic Offices as a Physical Oceanographer. I was a member of a section which was tasked with the responsibility of defining basic oceanographic characteristics in specific ocean areas. I received B.S. and PhD degrees in Chemical Engineering from the University of Maryland in 1962 and 1969, respectively. Additionally, I have taken NRC training courses in the safety analysis, design and operation of commercial nuclear power reactors.
.s ' '
a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE k In the Matter of )
)
GENERAL PUBLIC UTILITIES ) Docket No. 50-289 (CH) NUCLEAR )
)
(Three Mile Island Nuclear Station, ) Unit No.1) ) CERTIFICATE OF SERVICE I hereby certify that copics of "NRC STAFF RESPONSES TO TMIA'S FIIIST REQUEST FOR PRODUCTION OF DOCUMENTS AND FIRST INTERROGATORIES TO THE NUCLEAR REGULATORY COMMISSION STAFF" 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 Commission's internal mail system, this 28th day of April,1986:
*Morton B. Margulies
- 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 Harrisburg, PA 17120 Office of the Secretary U.S. Nuclear Regulatory Commission Michael W. Maupin, Esq. Washington, DC 20555 Maria C. Hensley, Esq.
Hunton & Williams P.O. Box 1535 Richmond, VA 23212 Deborah B. Bauser, Esq. Shaw, Pittman, Potts & Trowbridge 1800 M Street, NW Washington, DC 20036 , (Beot<geFffJo
&/ en
. Counsel Jor .- C Staff
. . .}}