ML20210E398
| ML20210E398 | |
| 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-#186-545 CH, NUDOCS 8603270333 | |
| Download: ML20210E398 (5) | |
Text
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March 24, 1986 f).
ItELATED CORRESPONDF No
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NUCLEAR REGULATORY COMMISSION, Rs/
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BEFORE TIIE ADMINISTRATIVE LAW JUDGEi 0D \\n 9
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i In the Matter of
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6 GENERAL PUBLIC UTILITIES NUCLEAR )
Docket No. 50-289 (CH)
)
(Three MHe Island Nuclear Station.
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Unit No.1)
)
NRC STAFF'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION OF
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DOCUMENTS TO THREE MILE ISLAND ALERT In accordance with 10 C.F.R. Sections 2.740, 2.740b and 2.741, the NFC staff hereby serves Three Mile Island Alert (TMIA), a party in the above-captioned proceeding, with NRC Staff's First Set of Interrogatories and Document Requests to Three Mile Island Alert. These interrogatories and document requests relate to the seven factual issues admitted for litigation in this proceeding by the Presiding Officer in his Report and Order On Initial Prehearing Conference
(" Order") dated February 27, 1980.
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. 5 2.740b and the Presiding Officer's Order, at 13.
You are requested to enswer each interrogatory separately and fully 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, DESIGNATED ORIGINAL h y 324 ccrt1rsea ny }.$ 0 y @ )
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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 TMIA; "TMIA" means intervenor Three Mile Island Alert or TMIA, its officers, agents, and employees, and all other persons who act or have acted on behalf of TMI A; " 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 repre-sentations; recordings and tapes, whether sound or visual; and data com-pilations 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) Give the name, address, occupation, and employ-er of the person or persons answering the interrogatory; (3) Identify each person, including his or her name, address, occupation and employ-er, whom you expect to call as a witness to testify as to the matter ad-dressed in the pertinent interrogatory, together 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.
1 You are also requested to supplement each interrogatory answer as l
necessary or appropriate in accordance with 10 C.F.R. I ?.740(e).
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- y. 4 Interrogatories 1.
Please fully state you position as to whether Charles Husted solicited i
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.
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2.
Please fully state your position as to whether the testimony of Charles Ilusted 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.
Pleas ~e 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 Ilusted i-failed to cooperate with NRC investigators in interviews of Mr. Ilusted conducted on July 29, 1981, and September 18, 1981, including each and every fact on which you base your
- position, i
i b.
With respect to each of the interviews referred to in 4.a.,
t please identify any note, memorandum, transcription, tape, or other record of said interviews which may be in your i
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. g possession, custody or control; and please identify any employee, advisor, agent, or. counsel of TMIA 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
'Ilusted in his responsibilities with GPU and Metropolitan Edison Com-pany reflects on Mr. Husted's attitude and integrity, including each and every fact on which vou 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 position is that remedial action is required with respect to Mr. Ilusted, please state the remedial action you believe to be neces-sary, and each and every fact on which you base your position.
8.
Please describe any other information with respect to Charles Husted's attitude, honesty, integrity, character, personality traits, activities, habits or reputation on which you intend to rely' in ad-dressing how considerations of Mr. liusted's attitude or integrity bear on his employment as an NRC-licensed
- operator,
i licensed-operator instructor or training supervisor, or eupervisor of training of non-licensed personnel.
I Documents Requests 4
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 the NRC Staff,
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George :. Jo son Counsel for NRC Staff Dated at Bethesda, B!aryland a
4 this 24th day of f.! arch,1986 i
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