ML20211E649

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Submits Gpu Nuclear Trial Plan.W/Certificate of Svc. Related Correspondence
ML20211E649
Person / Time
Site: Crane Constellation icon.png
Issue date: 06/11/1986
From: Bauser D
GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
Atomic Safety and Licensing Board Panel
References
CON-#286-559 CH, NUDOCS 8606160208
Download: ML20211E649 (8)


Text

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O t W Tt.DGORRESPONO N 3s June ll, 1 Pl] ~

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION t 3

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BEFORE THE ADMINISTRATIVE LAW JUD g

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In the Matter of

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General Public Utilities

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Dccket No. 50-289 (CH)

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(Three Mile Island Nuclear

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Station, Unit No. 1)

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GPU NUCLEAR TRIAL PLAN Solicitation on NRC Exam I.

William Ward and Peter Baci GPUN presumes prefiled testimony will recount events.of I&E interview of Janes on September 25, 1981.

1.

Questions concerning Baci's recollections of interview with Janes, including:

details of Janes' statements, I&E interview policies, I&E interview methods general-ly, and how this specific I&E interview was conducted, interview participants, details of Janes' conduct and attitude during interview.

2.

Questions concerning Ward's recollections, including:

details of Janes' statements, I&E interview policies, I&E interview methods generally, and how this specific I&E interview was conducted, interview participants, details of Janes' conduct and attitude during inter-view.

3.

Questions concerning Sept. 25, 1981 interview summary statement: process used to draft, basis for includ-ing/ excluding information, details of decision to ex-clude allegations re Husted.

4.

Questions concerning Janes interview vis-a-vis others conducted by Ward and/or Baci.

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5.

Questions concerning differences between Ward and Baci recollections, on the one hand, and Janes' recollec-tions, on the other.

6.

Questions concerning Baci " Memorandum For The Record" and Baci notes.

II.

David Janes GPUN will rely on Janes' prefiled testimony.

III. Charles Husted GPUN will rely on Husted's prefiled testimony.

IV.

Samuel Newton 1.

Questions concerning Newton's knowledge of and views about solicitation allegation.

IV.

Documents I&E Report summary of Janes Sept. 25, 1981 interview Baci " Memorandum For The Record" (Feb. 20, 1986 Draft)

Baci handwritten interview notes (Sept. 1981)

Attitude, Forthrightness and Cooperation with NRC i

i I.

Keith Christopher GPUN presumes prefiled testimony will recount Christopher's recollection of July 29, 1981 I&E interview of Husted.

1.

Questions concerning Christopher's recollections of July 29, 1981 interview of Husted:

details of Husted statements, I&E interview policies, general interview process being conducted at TMI, details of conduct of this interview, details re Husted's conduct and atti-tude during interview.

2.

Questions concerning July 29, 1981 Husted interview summary statement:

process used to draft, basis for record.

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3.

Questions concerning differences between Christopher and Christman statements of interview.

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II.

Paul Christman GPUN will rely on Christman's prefiled testimony.

III. John Wilson GPUN will rely on Wilson's prefiled testimony.

III. Richard Matakas GPUN presumes prefiled testimony will recount Matakas' rec-ollection of September 18, 1981 I&E interview of Husted.

1.

Questions concerning Matakas' recollections:

details of Husted statements, I&E interview policies, general interview process being conducted at TMI, details of conduct of this interview, details re Husted's conduct and attitude during interview.

2.

Questions concerning interview summary statement: pro-cess used to draft, basis for record.

3.

Questions concerning differences between Matakas inter-view statement and Husted prefiled testimony.

IV.

Samuel Newton 1.

Questions concerning Newton discussions with Husted and any others re Husted's attitude, forthrightness and co-operation with NRC.

V.

Charles Husted 1.

Questions concerning Husted's motive in appearing calm before Special Master.

2.

Questions concerning Husted demeanor before Special Master and his demeanor generally.

VI.

Documents NRC Reports of two Husted I&E interviews (July 29, 1981 and Sept. 18, 1981)

Matakas handwritten notes of Sept. 18, 1981 interview Christman typed notes of July 29, 1981 interview Excerpts from Husted testimony before Special Master -_.

Attitude, Integrity, Performance as a TMI Employee I.

Donald Haverkamp GPUN presumes Haverkamp prefiled testimony will summarize and attach Haverkamp report of investigation of Husted perfor-mance as a TMI employee.

1.

Questions concerning method used to prepare Haverkamp report.

2.

Questions concerning details of Haverkamp report.

3.

Questions concerning results of Haverkamp report.

4.

Questions concerning certain specific Husted perfor-mance evaluations.

II.

Nelson Brown 1.

Questions concerning the regular practices used by the Training Department to conduct performance evaluations and reviews generally and specifically with respect to Husted.

III. Samuel Newton 1.

Questions concerning Husted's performance as an in-structor.

2.

Questions concerning Husted's attitude towards his pro-fessional responsibilities.

3.

Questions concerning pressures on Training Department.

4.

Questions concerning Newton judgments about Husted.

5.

Questions concerning the regular practices used by the l

Training Department to conduct performance evaluations and reviews generally and specifically with respect to l

Husted.

IV.

Robert Long 1.

Questions concerning the regular practices used by the Training Department to conduct performance evaluations and reviews generally and specifically with respect to l

Husted.

V.

Charles Husted GPUN will rely on Husted's prefiled testimony. _ _.

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Documents Haverkamp Report (Inspection Report No. 50-289/86-04)

Husted performance evaluations:

10/85 evaluation by Goddard 6/84 evaluation by Leonard 10/84 evaluation by Goddard 3/84 evaluation by Brown 7/83 evaluation by Leonard 10/83 evaluation by Leonard 11/82 evaluation by Brown 6/82 evaluation by Brown 11/81 evaluation by Brown 10/80 evaluation by McCormick 10/79 evaluation by McCormick 8/79 evaluation by McCormick 10/78 evaluation by McCormick Additional Husted performance documents:

3/22/84 instructor evaluation by Leonard 3/20/84 instructor evaluation by Leonard 1/3/84 memo, B.P.

Leonard to C.E.

Husted 1/24/84 memo, B.P. Leonard to C.E.

Husted 5/10/84 instructor evaluation by Sheila McAllister 1/7/83 memo, M.J. Ross to H.D.

Hukill 4/13/83 evaluation, M.J. Ross to H.D.

Hukill 4/25/83 memo to file re C.E.

Husted by R.A. Knief 3/30/83 instructor evaluation by Newton 5/9/83 instructor evaluation by Newton 6/30/83 instructor evaluation by Leonard 6/3/83 memo, S.L.

Newton to Dr.

R.L.

Long 7/18/83 memo, M.J. Ross to H.D.

Hukill 7/19/83 instructor evaluation by Newton 11/30/83 instructor evaluation by Leonard 11/30/83 instructor evaluation by Knief 12/15/83 memo, M.J. Ross to H.D.

Hukill 12/20/83 memo, R.L. Long to H.D.

Hukill 10/8/82 memo, M.J. Ross to H.D. Hukill 10/27/82 memo, S.L. Newton to R.L. Long and H.D. Hukill 10/27/82 memo, R.A. Knief to R.L. Long and H.D.

Hukill 8/30/82 " Confidential Draft, C.

Husted Evaluation" i

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's 12/16/81 instructor evaluation by Knief 1/8/81 memo, R.A. Knief to C.E.

Husted Respectfully submitted, Mb Deborah B.

Bauser SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.

Washington, D.C.

20036 (202) 822-1215 Counsel for GPU Nuclear Corporation Dated:

June 11, 1986 _...

i

's June 11, 1986 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE In the Matter of

)

)

GENERAL PUBLIC UTILITIES

)

Docket No. 50-289 (CH)

)

(Three Mile Island Nuclear

)

Station, Unit No. 1)

)

CERTIFICATE OF SERVICE I hereby certify that copies of "GPU Nuclear Trial Plan,"

dated June 11, 1986, were served on the following parties by de-posit in the U.S. mail, first class, postage prepaid, with the exception of those parties indicated by an asterisk, who were served by Federal Express this lith day of June, 1986:

Morton B. Margulies, Esquire Administrative Law Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555 George E. Johnson, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D. C.

20555

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Ms. Louise Bradford Three Mile Island Alert 1011 Green Street Harrisburg, Pennsylvania 17102 Michael Maupin, Esq.

Hunton & Williams P.O. Box 1535 Richmond, VA 23212 hrlwvsh 0.

Deborah B.

Bauser i

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