ML20211E690
| ML20211E690 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/11/1986 |
| From: | Maupin M HUNTON & WILLIAMS, HUSTED, C.A. |
| To: | |
| Shared Package | |
| ML20211E693 | List: |
| References | |
| CON-#286-561 CH, NUDOCS 8606160219 | |
| Download: ML20211E690 (7) | |
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'9 UNITED STATES OF AMERICA k JUN131986* :-p NUCLEAR REGULATORY COMMISSION T( M U
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Before the Administrative Law Judge j y (,/
In the Matter of
)
)
GENERAL PUBLIC UTILITIES NUCLEAR ) Docket No. 50-2 89 (CH)
)
(Three Mile Island Nuc' lear Station, Unit No. 1)
)
MR. HUSTED'S TRIAL PLAN Mr. Husted will testify as to each factual issue admitted for resolution in this proceeding.
He will, in addition, call the witnesses listed in Section A, below.
The subject area, or areas, on which each witness is expected to testify is also set forth in Section A.
The documents Mr. Husted intends to have introduced into evidence in this proceeding, and the sponsors of those documents, are set forth in Section B.
A.
Witnesses 1.
Mr. David Janes will testify regarding Mr. Husted's alleged solicitation of an answer to an 8606160219 860611 PDR ADOCK 05000289 T
PDR 3)So3
s.
examination question during the April 24, 1981 SRO written examination.
2.
Mr. Paul Christman will testify regarding Mr. Husted's July 29, 1981 interview with NRC.
3.
Mr. Samuel Newton will testify regarding:
(a) A conversation he had with Mr. Husted concerning Mr. Husted's alleged solicitation of an answer to an examination question during the April 24, 1981 SRO written examination.
(b) A conversation he had with Mr. Husted concerning the July 29, 1981 interview with NRC.
(c) A conversation he had with Mr. Husted about Mr. Husted's perceived attitude toward the regulatory process.
(d) A conversation he had with Mr. Husted concerning answers Mr. Husted gave during his October 23, 1981 deposition and his approaching appearance before the Special Master.
(e) Mr. Husted's job performance, attitude and integrity.
4.
Mr. John Wilson will testify regarding an October 5, 1981 conversation he had with Mr. Husted
. l concerning the " passing papers" comment and Mr. Husted's September 18, 1981 interview with NRC.
5.
Mr. Nelson Brown will testify regarding the post-accident and post-cheating environments at TMI.
He will testify regarding the effect the cheating episode had on the training department in general and Mr. Husted in particular.
Mr. Brown will also testify on Mr. Husted's performance as an instructor, his attitudes toward nuclear safety and the regulatory process and his integrity.
6.
Mr. Robert Long will testify on Mr. Husted's performance of his responsibilities at GPU and what they reflect about Mr. Husted's attitude and integrity.
B.
Documents Mr. Husted will seek to have the following witnesses sponsor into evidence the documents set forth below.
Counsel may wish to ask one or more of i
the sponsoring witnesses certain additional questions, not answered in their pre-filed testimony, in order to establish a basis for the introduction of documents into evidence.
i a 1.
Mr. Paul Christman will sponsor his typed notes of Mr. Husted's July 29, 1981 NRC interview.
2.
Mr. John Wilson will sponsor his handwritten notes of an October 5, 1981 conversation with Mr. Husted.
3.
Mr. Nelson Brown will sponsor the following documents:
(a) 1981 Annual Employee Performance Evaluation of Mr. Husted, signed by Mr. Brown on November 4, 1981.
(b) Undated draft of (a).
(c) 1982 Annual Employee Performance Review, signed by Mr. Brown on November 2, 1982.
(d) 1983 Promotion (Reassign / Reclassify)
Employee Performance Review, signed by Mr. Brown on March 11, 1983.
4.
Mr. Samuel Newton will sponsor the following documents:
(a) 1980 Annual Employee Performance Evaluation of Mr. Husted, signed by Mr. Newton on October 24, 1980.
s 1 *
(b) 1982 Promotion (Review) Employee Perfor-mance Evaluation of Mr. Husted, signed by Mr. Newton on June 29, 1982.
(c) 1983 Merit Employee Performance Review, signed by Mr. Newton on July 13, 1983.
(d) 1983 Annual Employee Performance Review, signed by Mr. Newton on October 28, 1983.
(e) 1984 Employee Performance Review, signed by Mr. Newton on June 26, 1984.
(f) Guide for Evaluation of Instruction, Lesson on Plant Heatup, signed by Mr. Newton on 9/15/82.
(g) Evaluation of Instruction (Subject i
Matter Proficiency), Lesson on Annual Requal Exam Review, signed by Mr. Newton on 3/30/83.
(h) Evaluation of Instruction (Subject Matter Proficiency), Lesson on CRO-Mechanical, signed by Mr. Newton on 5/9/83.
(i) Guide for Evaluation of Instruction, Lesson on ESAS-AO Requal, signed by Mr. Newton, dated 7/19/83.
(j) Inter-office memorandum dated October 27, 1982 from S. L. Newton to R. L.
Long
\\ 6 and H. D. Hukill,
Subject:
Evaluation of C. E.
Husted.
(k) Inter-office memorandum dated June 3, 1983 from S.
L. Newton to Dr.
R. L. Long,
Subject:
C.
E. Evaluation.
5.
Dr. Robert Long may sponsor his handwritten notes of (i) an October 5, 1981 telephone conference with John Herbein and (ii) a May 27, 1982 meeting with Samuel Newton.
Mr. Long may, in addition, sponsor one or more of the following documents:
(a) Inter-office memorandum dated October 27, 1982 from R.
A.
Knief to R.
L.
Long and H.
D.
Hukill,
Subject:
Evaluation of C.
E.
Husted.
(b) Inter-office memorandum dated December 20, 1983 from R.
L.
Long to H.
D.
Hukill,
Subject:
Special Performance Monitoring of C.
E.
Husted.
(c) 1984 Annual Employee Performance Review signed by Charles Husted on 10/30/84.
(d) 1985 Annual Employee Performance Review, signed by Charles Husted on 10/14/85.
l 'A 0 Respectfully submitted, CHARLES HUSTED By Michael W. Maupin, Counsel of Counsel Michael W. Maupin Maria C. Hensley Hunton & Williams P.O. Box 1535 Richmond, Virginia 23212 Dated:
June 11, 1986
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