ML20210E383
| ML20210E383 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/24/1986 |
| From: | Johnson G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#186-546 CH, NUDOCS 8603270325 | |
| Download: ML20210E383 (6) | |
Text
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March 24,1986
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UNITED STATES OF AMERICA j
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NUCLEAR REGULATORY COMMISSION BEFORE TIIE ADMINISTRATIVE LAW JUDGE
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In the Matter of
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GENERAL PUBLIC UTILITIES NUCLEAR
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Docket No. 50-289 (CII)
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(Three Mile Island Nuclear Station,
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Unit No.1)
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NRC STAFF'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUflENTS TO GPU NUCLEAR CORPORATION In accordance with 10 C.F.R. Sections 2.740, 2.740b and 2.741, the NRC staff hereby serves GPU Nuclear Corporation, a party in the above-captioned proceeding, with NRC Staff's First Set of Interrogatories and Document Requests to GPU Nuclear Corporation.
These interrogato-ries and document requests relate to the seven factual issues admitted for litigation in this proceeding hv the Presiding Officer in his Report and Order On Initial Prehearing Conference
(" Order") dated February 27, 1986.
Answers to the interrogatories and production of documents re-quested below are due within 14 days after service, in accordance with 10 C.F.R. I 2.740b and the Presiding Officer's Order, at 13.
You are requested to answer each interrogatory separately and fully I
in writing under oath or affirmation, and to include all pertinent informa-tion available to you, your employees, agents, advisors, or counsel, based on the personal knowledge of the person answering.
By each request for production of documents, the NRC Staff seeks to inspect and copy pertinent documents which are in your possession, 8603270325 060324 ADOCK 0 % [
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I custody, or control, or in the possession, custody or control of your employees, advisors, agents, or counsel.
As used herein, "you" and "your" refers to GPU Nuclear Corpora-tion; "GPU Nuclear Corporation" means intervenor GPU Nuclear Corpora-tion, its officers, agents, and employees, and all other persons who act or have acted on behalf of GDU Nuclear Corporation; " documents" refers to and includes any writings, drawings, graphs, charts, and schedules wherever located and however prepared, produced, transmitted, or stored; photographs. or other pictorial representations; recordings and tapes, whether sound or visual; and data compilations of whatever form.
In answering each interrogatory:
(1) Fully identify any documents which form the basis for your answer, or which relate to the subject of the interrogatory and upon which you intend to rely in establishing your position at hearing; (2) Cive the name, address, occupation, and employ-er of the person or persons answering the interrogatory; (3) Identify each person, including his or her name, address, occupation and employ-cr, whom you expect to call as a witness to testify as to the matter ad-dressed in the pertinent interrogatory, together with the subject matter and substance of the testimony; (4) If the answer is based on oral or -
written communications with one or more individuals, identify each such individual, including his or her name, address, occupation, employer and professional background, describe the information received and its rela-tion to the answer, and fully identify each writing or record documenting such communication.
You are also requected to supplement each interrogatory answer as necessary or appropriate in accordance with 10. C.F.R. I 2.740(e).
. i Interrogatories 1.
Please fully state you position as. to whether Charles Husted solicited an answer to an exam question from another operator during the April 1981 NRC SRO examination at Three Mile Island Nuclear Sta-tion, including each and every fact on which you base your position.
2.
Please fully state your position as to whether the testimony of Charles Husted before the Special Master on December 10, 1981 in Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit
-No. 1), Docket No. 50-289, lacked forthrightness, including each and every fact on which you base your position.
3.
Please fully state your position as to whether Charles Ilusted exhib-ited a poor attitude toward the hearing before the Special Master on the cheating incidents, including each and every fact on which you base your position.
4.
a.
Please fully state your position as to whether Charles Husted failed to cooperate with NRC investigators in interviews of f.Ir. Ilusted conducted on July 29, 1981, and September 18, 1981, including each and every fact on which you base your position.
b.
With respect to each of the ' interviews referred to in 4.a.,
please identify any note, memorandum, transcription, tape, or other record of said interviews; and please identify any
employce, advisor, agent, or counsel of GPU Nuclear. Corpora-tion who was present at either interview, If any persons are identified in response to 4.b., above, please c.
describe the substance of such person or persons' recollection of said interview or interviews.
5.
Please fully state your position as to how the performance of Charles
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liusted in his responsibilities with GPU and Metropolitan Edison Com-
'pany reflects on Mr. Ilusted's attitude and integrity, including each and every fact on which you base your position.
6.
Please state your position as to whether any remedial action with respect to Charles Ilusted is required, including each and every fact on which you base your position.
7.
If your po.sition is that remedial action is required with respect to Mr. Husted, please state the -remedial action you believe to be neces-sary, and each and every fact on which you base your position.
8.
a.
Please identify any information concerning the conduct, perfor-mance, attitude, or integrity of Charles Ilusted, which was con-sidered in deciding whether 'to enter into the stipulation ' of July 23, 1983, with the Commonwealth of Pennsylvania.
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. i b.
Please identify any documents addressing the conduct, perfor-mance, attitude or integrity of Charles Husted which were prepared, transmitted, or received in connection with your de-cision whether to enter into the Stipulation referred to in 6a.
9.
Please describe any other information with respect to Charles Ilusted's attitude, honesty, integrity, character, personality traits, activities, habits or reputation on which you intend to rely in ad-dressing how considerations of ' ?.fr. Husted's attitude. or integrity
' bear on his employment as an NRC-licensed operator,
licensed-operator instructor or training supervisor, or supervisor of training of non-licensed personnel.
Documents Requests Please make available for inspection and copying at a time and loca-tion to be designated any and all documents of whatever description, identified in your answers to the above Staff interrogatories.
If you maintain that some documents should not be made available for inspection, you should identify the document as to date, title, author, recipient, and subject matter - and explain why such documents are not being made available.
For NRC* Staff, George E. Joh son Counsel for NRC Staff Dated at Bethesda, Maryland this 24th day of f.f arch,1986 l
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW ' JUDGE In the Matter of
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GENERAL PUBLIC UTILITIES Docket No. 50-)f(
NUCLEAR
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4' Et CERTIFICATE OF SERVICE
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v I hereby certify that copics of "NRC STAFF'S FIRST INTERRO 2A@ORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THREE MILE ISLAND ALERT" and "NRC STAFF'S FIRST INTERROGATORIES AND REQUEST FOR' PRODUCTION nF DOCUMENTS TO GPU NUCLEAR CORP-ORATIOM" in the above-captioned proceeding have been served on the follow-ing by deposit in the United States mail, first class, or, as indicated by an esterisk, by deposit in the Nuclear Regulatory Commission's internal mail system, this 24th day of March,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. IIensley, 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 C' Q
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,eorge EgJohrW6n Counsel f6r NRC Staff
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