ML20209G318
| ML20209G318 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 09/04/1986 |
| From: | Blake E, Jim Hickey GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| References | |
| CON-#386-657, CON-#386.657 86-534-01-OL, 86-534-1-OL, CIV-PEN, EA-84-137, NUDOCS 8609120423 | |
| Download: ML20209G318 (33) | |
Text
- .
dI DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 16 SD' 11 R2:07 BEFORE THE ADMINISTRATIVE LAW JUDG5FFICE 05 u t- IAW U0CMETING A SFPvict BRANCH In the Matter of )
) Docket No. 50-320 -CIF M N GPU NUCLEAR CORPORATION ) License No. DPR-73
) EA 84-137 (Three Mile Island Nuclear ) [ASLBP No. 86-534-01-OL]
Station, Unit No. 2) ) (Civil Penalty)
< GPU NUCLEAR CORPORATION'S FIRST SET OF INTERROGATORIES Pursuant to 10 C.F.R. 5 2.720, GPU Nuclear Corporation
("GPUN") requests that the Nuclear Regulatory Commission staff answer the following interrogatories in writing and under oath within 14 days.
) INSTRUCTIONS AND DEFINITIONS i
! The following instructions and definitions shall apply here-l in:
I A. The terms "NRC," "you" and "your" refer to the United States Nuclear Regulatory Commission and all of its officials, employees, representatives, attorneys, investigators, and others acting on its behalf.
1 B. The term "GPUN" refers to GPU Nuclear Corporation and its affiliates, and its and their officers, directors, i
i l 8609120423 860904 PDR ADOCK 05000320 Q PDR i
I 1
_ _ _ _ _ . . . _ . _ . _ ...- . ~ _ _ _ . _ _ . , _ _ . _c - _ _ _ . _ _ - . _ _ _ _ _ _ _ _ _ _ - - __ ,_ ..__ _ _ _ _.. .. _ .__ _ __. _ . . - . _ , - - . _ _ - _ _ _
s 5
i representatives and others acting or purporting to act on its or their behalf.
C. The term "Bechtel" refers to Bechtel North American Power Corporation and its affiliates, and its and their officers, directors, representatives and others acting or purporting to act on its or their behalf.
i D. The term " Parks" refers to Richard D. Parks.
E. The term "TMI" refers to Three Mile Island, Unit 2.
F. The term " DOL" refers to the United States Department of Labor and all of its officials, employees, representatives, i
attorneys, investigators and others acting on its behalf.
, G. " Person" as used herein refers to any individual, part-nership, firm, association, corporation or other government, l
legal or business entity.
H. " Document" includes any written, recorded or graphic
]
matter, however produced or reproduced, of every kind and regard-
- less of where located, including but not limited to any sum-4 mary, schedule, memorandum, note, statement, letter, telegram, i
i interoffice communication, report, diary, desk or pocket calendar
]
or notebook, daybook, appointment book, pamphlet, periodical, i work sheet, cost sheet, list, graph, chart, index, tape, record, partial or complete report of telephone or oral conversation, 1
compilation, tabulation, study, analysis, transcript, minutes, and all other memorials of any conversations, meetings and con- j
, I
{
ferences by telephone or otherwise, and any other writing or ;
j l i
1
___-,-~_m__. , - . . . . , _ , _ _ _ . _ , , , , . - , , , _ _ . _,.m-_ ---~.-__,r . - _ - _ _ - , . , - -
o recording which is in the possession, custody or control of the NRC.
I. These interrogatories, under the law, call not merely for your own personal and present knowledge, although in form they may appear to be so limited. They call also for the present knowledge of your attorneys, investigators and other agents, and for information available to you and to them.
J. If you cannot answer a particular interrogatory in full, after exercising due diligence to secure the information to do so, so state and answer to the extent possible, specifying and explaining your inability to answer the remainder and stating whatever information or knowledge you have concerning the unanswered portion.
K. Each interrogatory is a continuing one, and should be supplemented as required by 10 C.F.R. $ 2.740(e).
L. If you claim that any document or oral communication which is required to be identified by you in your response to any of thene interrogatories is privileged or immune from discovery:
- 1. Identify the portion of the interrogatory to which the document or communication is otherwise responsive;
- 2. Identify the document's title or the oral communi-cation and state the general subject matter of the document or oral communication;
- 3. State the date of the document or oral communica-tion.
3-
4
- 4. If a document, identify its author (s) and the per-son (s) for whom it was prepared or to whom it was sent, including all persons who received copies; i 5. If an oral communication, identify all persons
- present at the time of the oral communication;
! 6. State the nature of the privilege or immunity 1
claimed; and l
- 7. State in detail each and every fact upon which you baso your claim of privilege or immunity from discovery.
M. In each case where you are asked to identify or to
! state the identity of a document or where the answer to an inter-t rogatory refers to a document, state with respect to each such document:
- l. The identity of the person who prepared it;
- 2. The identity of all persons who reviewed or ap-
) proved it; n i
- 3. The identity of the person who signed it, or over I
i
- whose name it was issued; l 4. The identity of the addressee or addressees; >
4
- 5. The nature and substance of the document with suf-
- ficient particularity to enable the same to.be identified; l 6. The date of the document; and
- 7. The present location of the document and the i identity and address of each person who has custody of the document.
l i
4 I
. . - _ - _ - . . _ . - - _ -, , _ ..- - . ,_ - _ - - . - - , , - - - , , - _ - . . ~ - - - - - - - - - - . - - . . - . - . . . _ - - - - - . - - -
s i
l N. In each case where you are required to identify an oral j
i communication, or where the ansuer to the interrogatory refers to l an oral communication, state with respect thereto:
i
- 1. The date and place thereof; i
l 2. The identity of each person who participated in or l
? heard any part of the communication;
! 3. If the communication was by telephone, so indicate i
l and state who initiated the telephone call; i
- 4. The substance of what was said by each person who participated in the communication; and I
- 5. The location and the identity and address of the custodian of any document (including any mechanical, magnet-ic, electrical or electronic recording) that recorded, sum-l marized, reported or confirmed the oral communication.
1 O. In each instance where you are asked to identify or to i
stato the identity of a person, or where the answer to an inter-rogatory refers to a person, state with respect to each such per-l son:
! 1. His name; i,
i
- 2. His last known business and residence addresses and telephone numbers;
- 3. If an individual, his business affiliation or employment at the date of the transaction, event or matter l referred to; and i
1 i
1 !
i '
1 f
1 s
- 4. If a corporation or association, the business or activity in which it was engaged at the date of the transac-tion, event or matter referred to.
P. The phrases " state in detail" and " describe in detail" as used herein mean that you are requested to state, with specif-icity, each and every fact, ultimate fact, circumstance, inci-dent, act, omission, event and date, relating to or otherwise pertaining to the .aatters inquired of in said interrogatory.
INTERROGATORIES INTERROGATORY NO. 1:
With respect to each alleged " protected activity" engaged in by Parks which you contend resulted in discrimination against Parks at TMI, please:
(a) State the date of the protected activity; (b) Describe in detail the protected activity; (c) Identify each and every person who witnessed the protocted activity; (d) Identify each GPUN or Bechtel employee who you contend had knowledge of the protected activity on or before March 24, 1983, and as to each such employee state (1) the date on which that individual obtained knowledge of the protected ac-tivity and (ii) the manner in which that individual obtained such knowledge; L
(e) Identify each and every document evtdencing, re-ferring or relating to the protected activity; anc; (f) State in detail each and every reas.on why Parks' conduct constituted protected activity.
INTERROGATORY NO. 2:
Do you contend that any GPUN or Bechtel employee had a dis-criminatory motive in connection with Parks' removal as Alternate Startup and Test Supervisor?
INTERROGATORY NO. 3:
If your answer to Interrogatory No. 2 is anything other than an unqualified "no," then separately with respect to each GPUN or Bechtel employee who you contend had a discriminatory motive in connection with Parks' removal as Alternate Startup and Test Supervisor, please:
(a) Identify the GPUN or Bechtel employee; (b) State in detail each and every fact supporting your contention that said employee had a discriminatory motive; (c) Identify each and every document evidencing, re-ferring or relating to said employee's discriminatory motive; and (d) Identify each and every person having knowledge of the facts set forth in your answer to subparagraph (b) of this interrogatory.
-. . - . - ._~ - _, -
INTERROGATORY NO. 4:
Do you contend that Parks' removal as Alternate Startup and Test Supervisor was an adverse action relating to " compensation, terms, conditions, and privileges of employment" as those terms are used in the second sentence of 10 C.F.R. 5 50.7?
INTERROGATORY NO. 5:
If your answer to Interrogatory No. 4 is anything other than an unqualified "no," please:
(a) State in detail each and every fact upon which you base your contention that Parks' removal as Alternate Startup and Test Supervisor was an adverse action relating to " compensation, terms, conditions, and privileges of employment";
(b) Identify each and every document evidencing, re-ferring or relating to the facts set forth in your answer to sub-paragraph (a) of this interrogatory; and (c) Identify each and every person having knowledge of the facts set forth in your answer to subparagraph (a) of this interrogatory.
INTERROGATORY NO. 6:
To the extent not set forth in your answers to Interrogato-ries Nos. 1 through 5 above, please:
(a) State in detail each and every fact upon which you base your contention that Parks' removal as Alternate Startup and Test Supervisor constituted discrimination against Parks contrary to 10 C.F.R. 5 50.7; i
-S-l
(b) Identify each and every document evidencing, re-ferring or relating to the facts set forth in your answer to sub-paragraph (a) of this interrogatory; and 1 (c) Identify each and every person having knowledge of the facts set forth in your answer to subparagraph (a) of this interrogatory.
INTERROGATORY NO. 7:
Do you contend that any GPUN or Bechtel employee had a dis-criminatory motive in connection with Parks' interview by Messrs.
Hofmann and Wheeler on March 14, 1983?
INTERROGATORY NO. 8:
If your answer to Interrogatory No. 7 is anything other than
, an unqualified "no," then separately with respect to each GPUN or Bechtel employee who you contend had a discriminatory motive in connection with Parks' interview by Messrs. Hofmann and Wheeler on March 14, 1983, please:
(a) Identify the GPUN or Bechtel employee; (b) State in detail each and every fact supporting your contention that said employee had a discriminatory motive; and (c) Identify each and every document evidencing, re-ferring or relating to said employee's discriminatory motive.
R '
INTERROGATORY NO. 9:
Do you contend that Parks' interview by Messrs. Hofmann and Wheeler on March 14, 1983 was an adverse action relating to "com-pensation, terms, conditions, and privileges of employment" as those terms are used in the second sentence of 10 C.F.R. $ 50.7?
INTERROGATORY NO. 10:
If your answer to Interrogatory No. 9 is anything other than an unqualified "no," please:
(a) State in detail each and every fact upon which you base your contention that Parks' interview by Messrs. Hofmann and Wheeler on March 14, 1983 was an adverse action relating to "com-pensation, terms, conditions, and privileges of employment";
(b) Identify each and every document evidencing, re-ferring or relating to the facts set forth in your answer to sub-paragraph (a) of this interrogatory; and (c) Identify each and every person having knowledge of the facts set forth in your answer to subparagraph (a) of this interrogatory.
INTERROGATORY NO. 11:
To the extent not set forth in your answers to Interrogato-ries Nos. 1 and 7 through 10 above, please:
(a) State in detail each and every fact upon which you base your contention that Parks' interview by Messrs. Hofmann and Wheeler on March 14, 1983 constituted discrimination against Parks contrary to 10 C.F.R. S 50.7;
(b) Identify each and every document evidencing, re-ferring or relating to the facts set forth in your answer to sub-paragraph (a) of this interrogatory; and (c) Identifi each and every person having knowledge of the facts set forth in your answer to subparagraph (a) of this interrogatory.
INTERROGATORY NO. 12:
Do you contend that Parks was involuntarily removed as the primary Site Operations Department representative on the Test Working Group for the Polar Crane Project on March 17, 1983?
INTERROGATORY NO. 13:
If your answer to Interrogatory No. 12 is anything other than an unqualified "no," please:
(a) State in detail each and every fact supporting your contention that Parks was involuntarily removed; (b) Identify each and every person having knowledge of the facts set forth in your answer to subparagraph (a) of this interrogatory; and (c) Identify each and every document evidencing, re-ferring or relating to the facts set forth in your answer to sub-paragraph (a) of this interrogatory.
INTERROGATORY NO. 14:
Do you contend that any GPUN or Bechtel employee had a dis-criminatory motive in connection with Parks' removal as the pri-mary Site Operations Department representative on the Test Working Group for the Polar Crane Project on March 17, 1983?
INTERROGATORY NO. 15:
If your answer to Interrogatory No. 14 is anything other than an ut. qualified "no," then separately for each GPUN or Bechtel employee who you contend had a discriminatory motive in connection with Parks' removal as the primary Site Operations De-partment representative on the Test Working Group for the Polar Crane Project on March 17, 1983, please:
(a) Identify the GPUN or Bechtel employee; (b) State in detail each and every fact supporting your contention that said employee had a discriminatory motive; and (c) Identify each and every document evidencing, re-ferring or relating to said employee's discriminatory motive.
INTERROGATORY NO. 16:
Do you contend that Parks' removal as the primary Site Oper-ations Department representative on the Test Working Group for the Polar Crane Project on March 17, 1983 was an adverse action relating to " compensation, terms, conditions, and privileges of employment" as those terms are used in the second sentence of 10 C.F.R. 5 50.7?
INTERROGATORY NO. 17:
If your answer to Interrogatory No. 16 is anything other than an unqualified "no," please:
(a) State in detail each and every fact upon which you base your contention that Parks' removal as the primary Site
- _ - = _ - _ - - - _ _-
l Operations Department representative on the Test Working Group for the Polar Crane Project on March 17, 1983 was an adverse ac-tion relating to " compensation, terms, conditions, and privileges of employment";
(b) Identify each and every document evidencing, re-ferring or relating to the facts set forth in your answer to sub-paragraph (a) of this interrogatory; and (c) Identify each and every person having knowledge of the facts set forth in your answer to subparagraph (a) of this interrogatory.
INTERROGATORY NO. 18:
To the extent not set forth in your answers to Interrogato-ries Nos. 1 and 12 through 17 above, please:
(a) State in detail each and every fact upon which you base your contention that Parks' removal as the primary Site Operations Department representative on the Test Working Group for the Polar Crane Project on March 17, 1983 constituted dis-crimination against Parks contrary to 10 C.F.R. S 50.7; (b) Identify each and every document evidencing, re-ferring or relating to the facts set forth in your answer to sub-paragraph (a) of this interrogatory; and (c) Identify each and every person having knowledge of the facts set forth in your answer to subparagraph (a) of this interrogatory.
INTERROGATORY NO.19:
Do you contend that any GPUN or Bechtel employee had a dis-criminatory motive in connection with Parks' placement on leave of absence with pay on March 24, 1983?
INTERROGATORY NO. 20:
If your answer to Interrogatory No. 19 is anything other than an unqualified "no," then separately for each employee who you contend had a discriminatory motive in connection with Parks' placement on leave of absence with pay on March 24, 1983, please:
(a) Identify the GPUN or Bechtel employee; (b) State in detail each and every fact supporting your contention that said employee had a discriminatory motive; and (c) Identify each and every document evidencing, re-ferring or relating to said employee's discriminatory motive.
INTERROGATORY NO. 21:
Do you contend that Parks' placement on leave of absence with pay on March 24, 1983 was an adverse action relating to
" compensation, terms, conditions, and privileges of employment" as those terms are used in the second sentence of 10 C.F.R.
$ 50.7?
INTERROGATORY NO. 22:
If your answer to Interrogatory No. 21 is anything other than an unqualified "no," please:
(a) State in detail each and every fact upon which you base your contention that Parks' placement on leave of absence with pay on March 24, 1983 was an adverse action relating to
" compensation, terms, conditions, and privileges of employment";
(b) Identify each and every document evidencing, t. e -
ferring or relating to the facts set forth in your answer to sub-paragraph (a) of this interrogatory;. and (c) Identify each and every person having knowledge of the facts set forth in your answer to subparagraph (a) of this interrogatory.
INTERROGATORY NO. 23:
To the extent not set forth in your answers to Interrogato-ries Nos. 1 and 19 through 22 above, please:
(a) State in detail each and every fact upon which you base your contention that Parcs' placement on leave of absence with pay on March 24, 1983 constituted discrimination against Parks contrary to 10 C.F.R. S 50.7; (b) Identify each and every document evidencing, re-ferring or relating to the facts set forth in your answer to sub-paragraph (a) of this interrogatory; and (c) Identify each and every person having knowledge of the facts set forth in your answer to subparagraph (a) of this interrogatory.
INTERROGATORY NO. 24:
Reference is made to the description of Parks' communica-tions with Phil Grant and Joel Weibe of the NRC on Friday, February 18, 1983, at pages 20-21 of Parks' 56-page affidavit dated March 21, 1983. Is said portion of Parks' affidavit a com-plete and accurate description of Parks' communications with the NRC on February 18, 1983?
INTERROGATORY NO. 25:
If your answer to Interrogatory No. 24 is anything other than an unqualified "yes," please:
(a) State in detail each and every way in which said portion of Parks' affidavit is not a complete and accurate de-scription of Parks' communications with the NRC on l'ebruary 18, 1983; (b) Identify each and every document evidencing, re-ferring or relating to the facts set forth in your answer to sub-paragraph (a) of this interrogatory; and (c) Identify each and every person having knowledge of the facts set forth in your answer to subparagraph (a) of this interrogatory.
INTERROGATORY NO. 26:
Reference is made to the description of Parks' communica-tions with the NRC on March 10, 1983, at pages 45-46 of Parks' 56-page affidavit dated March 21, 1983. Is said portion of Parks' affidavit a complete and accurate descripticn of Parks' communications with the NRC on March 10, 1983?
INTERROGATORY NO. 27:
If your answer _to Interrogatory No. 26 is anything other than an unqualified "yes," please:
(a) State in detail each and every way in which said portion of Parks' affidavit is not a complete and accurate de-scription of Parks' communications with the NRC on March 10, 1983; (b) Identify each and every document evidencing, re-ferring or relating to the facts set forth in your answer to sub-paragraph (a) of this interrogatory; and (c) Identify each and every person having knowledge of
- the facts set forth in your answer to subparagraph (a) of this interrogatory.
INTERROGATORY NO. 28:
Reference is made to the statement at page 38 of Parks' 56-page affidavit dated March 21, 1983 to the effect that the NRC compromised Parks' confidentiality. Is said statement in Parks' affidavit true?
INTERROGATORY NO. 29:
If your answer to Interrogatory No. 28 is anything other than an unqualified "yes," please:
(a) State in detail each and every way in which said statement in Parks' affidavit is not true; (b) Identify each and every document evidencing, re-ferring or relating to the facts set forth in your answer to subparagraph (a) of this interrogatory; and
(c) Identify each and every person having knowledge of the facts cet forth in your answer to subparagraph (a) of this interrogatory.
INTERROGATORY NO. 30:
Reference is made to the statement at page 41 of Parks' 56-page affidavit dsted March 21, 1983 to the effect that "the NRC was also partially at fault, since it was reviewing draft procedures which had not completed the review and approval cycle." Is said statement in Parks' affidavit true?
INTERROGATORY NO. 31:
If your answer to Interrogatory No. 30 is anything other than an unqualified "yes," please:
(a) State in detail each and every way in which said statement in Parks' affidavit is not true; (b) Identify each and every document evidencing, re-ferring or relating to the facts set forth in your answer to sub-paragraph (a) of this interrogatory; and (c) Identify each and every person having knowledge of the facts set forth in your answer to subparagraph (a) of this interrogatory.
INTERROGATORY NO. 32:
Reference is made to the statement at page 41 of Parks' f
56-page affidavit dated March 21, 1983 to the effect that, "on February 25, Lake Barrett of the NRC had told me the draft review process was at Barrett's own
initiative, volunteered to B. Kanga. It was an attempt to help GPU shorten the review cycle and meet their schedule. But the shortcut backfired."
Is said statement in Parks' affidavit complete and accurate?
INTERROGATORY NO. 33:
If your answer to Interrogatory No. 32 is anything other than an unqualified "yes," please:
(a) State in detail each and every way in which said statement in Parks' affidavit is not complete and accurate; (b) Identify each and every document evidencing, re-ferring or relating to the facts set forth in your answer to sub-paragraph (a) of this interrogatory; and (c) Identify each and every person having knowledge of the facts set forth in your answer to subparagraph (a) of this interrogatory.
INTERROGATORY NO. 34:
Reference is made to the statement at page 56 of Parks' 56-page affidavit dated March 21, 1983 to the effect that "the l NRC has knowingly provided informal guidance and formal approval l
for this misconduct." Is said statement in Parks' affidavit true?
INTERROGATORY NO. 35:
If your answer to Interrogatory No. 34 is anything other than an unqualified "yes," please:
(a) State in detail each and every way in which said statement in Parks' affidavit is not true; (b) Identify each and every document evidencing, re-ferring or relating to the facts set forth in your answer to sub-paragraph (a) of this interrogatory; and (c) Identify each and every person having knowledge of the facts set forth in your answer to subparagraph (a) of this interrogatory.
INTERROGATORY NO. 36:
Has the NRC at any time investigated any of Parks' allega-tions of misconduct, misfeasance or malfeasance by the NRC at TMI?
INTERROGATORY NO. 37:
If your answer to Interrogatory No. 36 is anything other than an unqualified "no," please:
(a) State the dates of each such investigation; (b) Identify the NRC representatives involved in each such investigation; (c) Describe in detail the role (s) of each such repre-sentative(s);
(d) Identify all documents received by the NRC from any person in the course of each such investigation; (e) Identify all documents prepared by the NRC in the course of each such investigation; and
(f) Describe in detail each and every finding and con-clusion reached by the NRC concerning Parks' allegations of mis-conduct, misfeasance or malfeasance by the NRC at TMI.
INTERROGATORY NO. 38:
1 Identify each and every oral communication between Parks and any NRC representative during the period September 1, 1982 through and including March 23, 1983.
INTERROGATORY NO. 39:
Identify each and every document evidencing, recording, transcribing, summarizing, referring or relating to the oral com-munications referred to in Interrogatory No. 38 above.
INTERROGATORY NO. 40:
Identify each and every document constituting, comprising, referring or relating to written communications between Parks and any NRC representative during the period September 1, 1982 through and including March 23, 1983.
INTERROGATORY NO. 41:
Identify each and every oral communication between Parks and any NRC representative during the period March 24, 1983 through the date of your answers to these interrogatories, referring or relating in any way to Parks' allegations that he was discrimi-
{
) nated against for engaging in protected activity at TMI.
INTERROGATORY NO. 42:
Identify each and every document evidencing, recording, transcribing, summarizing, referring or relating to the oral com-munications referred to in Interrogatory No. 41 above.
INTERROGATORY NO. 43:
Identify each and every document constituting, comprising, referring or relating to written communications between Parks and any NRC representative during the period March 24, 1983 through the date of your answers to these interrogatories, referring or relating in any way to Parks' allegations that he was discrimi-nated against for engaging in protected activity at TMI.
. INTERROGATORY NO. 44:
Identify each and every oral communication between Parks and any NRC representative during the period March 24, 1983 through the date of your answers to these interrogatories, referring or relating in any way to any allegation by Parks of engineering, programmatic or other deficiencies at TMI.
I INTERROGATORY NO. 45:
Identify each and every document evidencing, recording, j transcribing, summarizing, referring or relating to the oral com-i munications referred to in Interrogatory No. 44 above.
INTERROGATORY NO. 46:
Identify each and every document constituting, comprising, referring or relating to written communications between Parks and any NRC representative during the period March 24, 1983 through 1 J l
the date of your answers to these interrogatories, referring or relating in any way to allegations by Parks of engineering, pro-grammatic.cn: other deficiencies at TMI.
INTERROGATORY NO. 47:
Identify each and every oral communication between any rep-resentatives of the NRC and any persons representing or pur-porting to represent Parks (including, but not limited to, repre-sentatives of the Government Accountability Project or the law offices of Hoberg, Finger, Brown, Cox & Molligan) during the period March 24, 1983 through the date of your answers to these interrogatories, referring or relating in any way to Parks' alle-gations that he was discriminated against for engaging in pro-tected conduct at TMI.
INTERROGATORY NO. 48:
Identify each and every document evidencing, recording, transcribing, summarizing, referring or relating to the oral com-munications referred to in Interrogatory No. 47 above.
INTERROGATORY NO. 49:
Identify each and every document constituting, comprising, referring or relating to written communications between any rep-resentatives of the NRC and any persons representing or pur-porting to represent Parks (including, but not limited to, repre-sentatives of the Government Accountability Project or the law offices of Hoberg, Finger, Brown, Cox & Molligan) during the period March 24, 1983 through the date of your answers to these 4
interrogatories, referring or relating in any way to Parks' alle-gations that he was discriminated against for engaging in pro-tected conduct at TMI.
INTERROGATORY NO. 50:
Identify each and every oral communication between any rep-resentatives of the NRC and any persons representing or pur-porting to represent Parks (including, but not limited to, repre-sentatives of the Government Accountability Project or the law offices of Hoberg, Finger, Brown, Cox & Molligan) during the period March 24, 1983 through the date of your answers to these interrogatories, referring or relating in any way to any allega-tion by Parks of engineering, programmatic or other deficiencies at TMI.
INTERROGATORY NO. 51:
Identify each and every document evidencing, recording, transcribing, summarizing, referring or relating to the oral com-munications referred to in Interrogatory No. 50 above.
INTERROGATORY NO. 52:
Identify each and every document constituting, comprising, referring or relating to written communications between any rep-resentatives of the NRC and any persons representing or pur-porting to represent Parks (including, but not limited to, repre-sentatives of the Government Accountability Project or the law offices of Hoberg, Finger, Brown, Cox & Molligan) during the period March 24, 1983 through the date of your answers to these 1
I
interrogatories, referring or relating in any way to allegations by Parks of engineering, programmatic or other deficiencies at TMI.
INTERROGATORY NO. 53:
Identify each and every oral communication between any rep-resentatives of the NRC and any persons representing or pur-porting to represent Parks (including, but not limited to, repre-sentatives of the Government Accountability Project) during the period September 1, 1982 through and including March 23, 1983, referring or relating in any way to Parks.
INTERROGATORY NO. 54:
Identify each and every document evidencing, recording, transcribing, summarizing, referring or relating to the oral com-munications referred to in Interrogatory No. 53 above.
- INTERROGATORY NO. 55:
Identify each and every document constituting, comprising, referring or relating to each and every written communication be-tween any representatives of the NRC and any persons representing or purporting to represent Parks (including, but not limited to, representatives of the Government Accountability Project) during the period September 1, 1982 through and including March 23, 1983, referring or relating in any way to Parks.
INTERROGATORY NO. 56:
Reference is made to the statement in the August 12, 1985 letter from James R. Taylor to P.R. Clark ("
Subject:
Notice of Violation and Proposed Imposition of Civil Penalty") to the effect that "OI also investigated Mr. Parks' allegation of dis-crimination." With respect to said statement, please:
(a) State the inclusive dates during which OI con-ducted the referenced investigation; (b) Identify all OI representatives who participated in the referenced investigation, and describe in detail the role of each participant; (c) Describe in detail all investigative activities by
! the OI representatives in the course of the referenced investiga-tions; (d) Identify all persons interviewed or interrogated by OI during the referenced investigation and state the dates of each such interview and interrogation; (e) Identify all documents received by OI in the course of the referenced investigation; (f) Identify all documents prepared by OI during the course of the referenced investigation; and (g) State in detail each and every finding and conclu-sion reached by OI as a result of the referenced investigation.
l 1
INTERROGATORY NO. 57:
Identify each and every oral communication between represen-tatives of the NRC and representatives of DOL during the period March 24, 1983 through the date of your answers to these inter-rogatories, referring or relating in any way to Parks' allega-tions that he was discriminated against for engaging in protected conduct at TMI.
INTERROGATORY NO. 58:
Identify each and every document evidencing, recording, transcribing, summarizing, referring or relating to the oral com-munications referred to in Interrogatory No. 57 above.
1 INTERROGATORY NO. 59:
Identify each and every document constituting, comprising, referring or relating to written communications between represen-tatives of the NRC and representatives of DOL during the period March 24, 1983 through the date of your answers to these inter-rogatories, referring or relating in any way to Parks' allega-tions that he was discriminated against for engaging in protected conduct at TMI.
I INTERROGATORY NO. 60:
f Has any person other than Parks stated to any representa-i tives of the NRC in words or substance, orally or in writing, l
! that Parks was discriminated against for engaging in protected activities at TMI?
i l
l INTERROGATORY NO. 61:
If your answer to Interrogatory No. 60 is anything other than an unqualified "no," please:
(a) Identify each person who has made such a state-ment; (b) State the date of each such statement; (c) Identify the NRC representative (s) to whom the statement was made; (d) Identify each and every document constituting, comprising, recording, transcribing, summarizing, referring or relating to each such statement; and (e) If the statement was oral, describe the statement in detail.
INTERROGATORY NO. 62:
Reference is made to Parks' purported safety concerns as de-1 i scribed in his 56-page affidavit dated March 21, 1983. Has the NRC or any representative thereof concluded that any of Parks' purported safety concerns were valid?
INTERROGATORY NO. 63:
If your answer to Interrogatory No. 62 is anything other than an unqualified "no," please:
(a) Describe in detail each of Parks' purported safety concerns that has been found valid; (b) Identify each NRC representative having knowledge i of whether said safety concern was valid; and 4
l
(c) Identify each and every document prepared by the NRC concerning said safety concern.
INTERROGATORY NO. 64:
Reference is made to Parks' purported safety concerns as de-scribed in his 56-page affidavit dated March 21, 1983. Has the NRC or any representative thereof concluded that any of Parks' purported safety concerns were invalid?
INTERROGATORY NO. 65:
If your answer to Interrogatory No. 64 is anything other than an unqualified "no," please:
(a) Describe in detail each and every such safety con-cern that has been found invalid; (b) Identify each representative of the NRC having knowledge of whether the purported safety concern was invalid; and (c) Identify each and every document prepared by the NRC referring or relating to the safety concern.
INTERROGATORY NO. 66:
Identify each and every written or oral statement (including but not limited to, depositions, affidavits, statements to gov-ernment employees or to the news media and tape recordings) by Parks, referring or relating to:
(a) Parks' allegations that he was discriminated against for engaging in protected activities at TMI; or
(b) Parks' allegations of engineering, programmatic or other deficiencies at'TMI.
INTERROGATORY NO. 67:
Excluding statements submitted to the NRC by GPUN, Bechtel and/or Edwin Stier, identify each and every written or oral wit-ness statement (including, but not limited to, depositions, affi-davits, and statements to government employees or the news media and tape recordings), referring or relating to:
(a) Parks' allegations that he was discriminated 4
against for engaging in protected activities at TMI; or (b) Parks' allegations of engineering, programmatic or other deficiencies at TMI.
INTERROGATORY No. 68:
Do you contend that any employee of GPUN or Bechtel has admitted facts constituting a violation of 10 C.F.R. S 50.7 with respect to Parks?
INTERROGATORY NO. 69:
If your answer to Interrogatory No. 68 is anything other than an unqualified "no," then separately with respect to each alleged admission please:
(a) Identify the GPUN or Bechtel employee who made the alleged omission; (b) Identify each and every person who witnessed and/or has knowledge of the alleged admission; i
(c) State the form of the admission (e.g., orally, in writing);
(d) State in detail the exact admis:, ion made; and (e) Identify each and every document constituting, re-cording, comprising, evidencing, referring or relating to the al-leged admission.
INTERROGATORY NO. 70:
List each person who provided information used in preparing your responses to these interrogatories, and for each person list the numbers of the interrogatory responses for which his in-formation was used.
INTERROGATORY NO. 71:
Identify each document used or referred to in preparing your responses to these interrogatories which have not been identified
- in any of your responses.
i i
I
{
1
)
INTERROGATORY NO. 72:
Identify the witnesses you intend to call at the hearing of this matter, and describe the issues on which each will testify and the substance of the testimony.
Dated:
UN September _,_, - 1986 SHAW, PITTMAN, POTTS & TROWBRIDGE By _.
E r n'e s t L . B1 ke, P.C.
J. atrick H ckey, P.
Counsel for GPU Nuclear Corporation 9
UNITED STATES OF AMERICA DOLKETED NUCLEAR REGULATORY COMMISSION usNPC Before the Administrative Law Judge 16 SEP 11 R2;18 In the Matter of )
) Docket No. 5 -),20,_ u,,. p GPU Nuclear Corporation ) License No. g*Wi :G vitf.
) EA 84-137 BRANCH (Three Mile Island, Unit 2) )
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing "GPU Nuclear Corporation's First Set of Interrogatories" were served by deposit in the United States Mail, First Class, postage prepaid, this 4th day of September, 1986, to the following persons:
Ivan Smith, Esquire Administrative Law Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Branch Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 George E. Johnson, Esquire Office of the General Counsel 9604 MNBB U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l P trick Higkey J.
9 h
i
- - - . - - . - - . . ---- - . _ - . . , - - -