ML20211E774

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Testimony of Rl Long Re Alleged Cheating of C Husted on NRC Senior Reactor Licensing Exam.Related Correspondence
ML20211E774
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Issue date: 06/13/1986
From: Long R
GENERAL PUBLIC UTILITIES CORP.
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CH, NUDOCS 8606160235
Download: ML20211E774 (18)


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UNITED STATES OF AMERICA h[lg8198g -9 NUCLEAR REGULATORY COMMISSION b 7

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Before the Administrative Law JudcAe ' QNEEh

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GENERAL PUBLIC UTILITIES NUCLEAR ) Docket No. 50-289 (CH)

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(Three Mile Island Nuclear

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Station, Unit No. 1)

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TESTIMONY OF ROBERT L. LONG My name is Robert L.

Long.

I am Vice President of Nuclear Assurance for GPU Nuclear Corporation (GPUN).

A copy of my resume is attached to, and is a part of, this testimony.

I joined GPUN's predecessor in 1978 as Manager-Generation Productivity.

Following participa-tion in the TMI Unit 2 Accident Response Team, I served as Director-Reliability Engineering from July 1979 until January 1980, when I became Director-Training and Education.

In April 1982, I assumed my present posi-tion.'

As Vice President of Nuclear Assurance, I am responsible for the Training and Education Department, which includes the TMI Training Section where Charles 8606160235 860611 PDR ADOCK 05000289 T

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Husted worked from July 1978 until June 1984.

Since June 1984, Mr. Husted has been assigned to the~ Nuclear Safety Assessment Department, for which I am also responsible.

When Mr. Husted joined the Training Department in July 1978, he did so as an instructor of non-licensed operators.

In September 1980, he moved to instructing licensed operators, where he continued to improve his technical knowledge and instructional skills.

As a result of Mr. Husted's participation in the reopened hearings on cheating, we became concerned in late 1981 about whether Mr. Husted's attitude towards his work and his responsibilities was appropriate.

As a result of our concerns, meetings were held with Mr. Husted to discuss his attitude.

In June 1982 -- after issuance of the Special Master's Report but before the Licensing Board's deci-sion was issued -- I met with the Manager of Plant Training-TMI, Dr. Knief, and the operator Training Manager, Mr. Newton, to develop a formal plan of action for an ongoing assessment of Mr. Husted's attitude and performance as a licensed operator instructor.

This plan included an interview of Mr. Husted by myself and

Vice President / Director TMI-1, Mr. H. D.

Hukill.

In that interview, we stressed with Mr. Husted the seriousness with which we viewed his behavior in various phases of the NRC investigation and hearing process.

It should be noted that I had no first-hand know-ledge of Mr. Husted's interactions with the NRC Inspection and Enforcement investigators, the intervenors during his deposition or the Special Master and others during his appearance in the reopened hearings.

Furthermore, I do not recall discussing his conduct during his first I&E interview with anyone.

However, I did review the transcript of his October 1981 deposition by the intervenors, and I could see for myself that he had given a number of flippant answers during the deposition.

In addition, I was aware that counsel for the Company, who were in attendance when Mr. Husted appeared before the Special Master, had con-cluded that at times during that proceeding he appeared flippant and to consider the questions in a less than serious manner.

Based on this information, Mr. Hukill and I informed him that his conduct was inappropriate, and we advised Mr. Husted that his job performance and l

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O attitudes would be closely monitored for an extended period.

Based on its perceptions of his attitude, even-tually in its decision of July 27, 1982, the Licensing Board expressed " doubts.

. about his competence to instill a sense of seriousness about the important need for integrity, discipline and public confidence in the TMI training program" (LBP-82-56, 1 2168).

In fact the Board recommended in its decision ".

that the qualifications and delivery performance of Mr. Husted receive particular attention during the forthcoming review of the TMI training program."

Before I discuss the results of the Company's special monitoring program of Mr. Husted, I would like to make an observation about the Special Master hearing.

l I remember the 1981 cheating hearing well.

I was a witness before the Special Master.

I recall that although I had had a great deal of experience in public speaking, as a teacher, as a speech-maker and in other public hearings, I was as apprehensive as I've ever been about the hearing before Judge Milhollin.

I recall being uncharacteristically nervous.

A good deal l

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of this anxiety, I believe, resulted from the sequestration order and the resulting facts that (a) we at the Company were forbidden to discuss the matter with each other and (b) even our counsel could tell us next to nothing about what was going on in the hearing.

As a result there was an unusual air of mystery sur-rounding the proceeding.

Mr. Husted, of course, had far less experience than I in speaking publicly and under pressure.

I read Mr. Husted's testimony about the frame of mind that he brought to the cheating hearing, and, while I do not approve of the appearance he created at times during the hearing, I can under-I stand the stress he was under, because to some extent I shared it.

The monitoring program and special counseling with TMI Training Section management that had actua-lly begun prior to the June meeting continued on a regular documented basis through December 1983.

In addition to observations and evaluations by Training Section personnel, the TMI-1 Operations Department performed special observations and submitted written reports to Mr. Hukill on Mr. Husted's performance and attitudes.

I have reviewed these reports.

The reports indicate

W that Mr. Husted was performing satisfactorily and that there was no evidence of undesirable attitudes or lack of respect for the training or licensing processes.

In March 1983, when the supervisory position for Non-licensed Operator Training became available, Mr. Husted was considered as a candidate.

Based on the thorough and extensive recent observations of his per-formance and attitudes, the TMI Training Section recom-mended and the Director of Training & Education, Dr. Coe, and I concurred in his appointment as Supervisor Non-licensed Operator Training.

Subsequently, in June 1983, GPUN made a commitment to Governor Thurnburg to remove Mr. Ilusted's SRO license and to decline to use him as a TMI Unit 1 licensed operator or instructor of licensed operators.

However, GPUN did not consider the information of which it was aware concerning the conduct, performance, attitude, and integrity of Charles Husted to require it to take the action relative to Mr. Husted called for by the stipulation.

Nor did the stipulation require any change in Mr. Husted's assignment at that time.

Mr. Husted continued to perform very effectively 4

as Supervisor Non-licensed Operator Training until June

1984 when ALAB-772 directed that he be removed from this position.

Because of the attention I gave Mr. Husted's per-formance after his appearance before the Special Master, and because he has continued to work in my Division, I have continued to monitor his progress.

I have met with him en three or four occasions during the past two years to discuss his progress and his work and to form an updated opinion on his attitude toward his responsibilities.

I have also reviewed his performance evaluations.

Mr. Brown and Mr. Newton, in their testimony in this proceeding are testifying abouc the formal evaluations that were made of Mr. Husted's performance from 1980 through 1983.

I have reviewed his 1984 and 1985 evaluations, which deal with his work since leaving the Training Department.

They are entirely consistent with the favorable earlier assessments.

l Charles Husted is a good employee.

He has per-formed his training and other assignments conscien-tiously and well.

He rebounded promptly from the

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stresses of the cheating episode and the ensuing investigation and hearing.

I know of no occasion when l

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he has conveyed to his students or fellow workers an improper attitude toward safety, toward the regulatory process, or toward the Company or NRC training pro-cesses.

Mr. Husted is an important member of our nuclear team with a great deal to contribute, in experience and plant knowledge, especially in our training effort.

I know of nothing about his attitude or integrity that warrants any restrictions whatever on his future job opportunities.

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Attachmsnt 1

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REVISED 2/16/83 RESUME of

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ROBERT L. LONC 1.

Date of birth:

September 9, 1936 2.

Position 4/82 - Presenc:

Vice President - Nuclear Assurance Division CPU Nuclear Corporation, 100 Interpace Parkway New Jersey 07054.

3.

Deareas:

a.s., Electrical Engineering, Bucknell University, 1953 M.g., Nuclear Engineering, Purdue University,1959 Ph.D., Nuclear Engineering, Furdue University, 1962 4.

University of New Mexico service:

13 years 1965-1968:

Assistant Professor of Nuclear Engineering 1968-1973:

Associsco Professor of Nuclear Insincering 1973-1978:

Professor of Nuc10er Engineering 1972-1974:

Assistant Dean, College of Engineering 1974-1975:

Acting Chairman, Chemical & Nuclear Engineering Department 1975-1973:

Chairman, Chemical & Nuclear Engineering Department 5.

Other work experience - research. Industrial. etc.:

1982-Present:

Vice President - Nuclear Assurance Div., CPU Nuclear Corp.

1980-1982:

Director - Training & Education, CPU Nuclear Corp.

1979-1980: ' Director - Reliability Engineering, CPU Service Corp.,

Farsippany, N.J.

1973-1979:

Manager - Ceneration Productivity Department, GPU 8ervice Corp., Farsippany, N.J.

1976-1977:

S.bb t.h.1 leave - P ojaat Enginear, Elastrie Power Research Institute 1970-1971:

ASEs - Ford Foundation Resident Fellow, Associate Reactor Engineer, Indien Point Nuclear Power Station, con Edison of New York. Inc.

1965-1968:

Research Participant in the field of fast burst reactor

.i s.

Robert L. Long - Resume Page 2 reflector effects and high yield burst reactors, one-half time at Sandia Corporation 1966-1967:

Leave of absence from UNN - Research Associate Nuclear Research Division, Atomic Weapons Research Establishment.

Aldermaeton, Berkshire, England 1964-1965:

cs-14, Civil Service, Reactor specialist, Nuclear Effects Branch, White Sands Missile Range, New Mexico 1962-1964:

1st Lt., U.S. Army, Nuclear Effects Engineer. Reactor Specialist, Nuclear Effects Branch White Sands Missile Range, New Mexico 1960-1962:

Studect Research Associate, Argonne National Laboratory, Argonne, I111ncis Summer, 1960:

Instructor and technical reader, Furdue University.

Lafayette, Indiana 6.

Consultina:

1981-1984:

Argonne Universities Association Review C-mittee I

for Division of Educational Programs at Argonne Natic 1

ibcratory 1981:

National Research Council. Assembly of Enginee ns. Nu lear Manpower Committee 1979-1980:

National Science Foundation Review Committee for i

Engineering Chemistry and Energeeles 1977-1979:

Consultant to Nucisar Engineerins & Operations Depart-ment, Electric Power Research Institute, Palo Alto, California 1976:

Lecturer overseas (Southeast Asia) for U. 5. Information Agency 1973-1978:

Consultant to U. 5. Department of Energy (formerly ERDA and USAIC) on Citison's Workshops on Energy and the Invironment.

1971-1978:

Occasional consultant for utilities and other univer-sities on public iducation aspects of nuclear energy.

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1971-1973:

Consultant on Power Reactor Operator Training to Ceneral l

Physics Corporation, Columbia, Maryland 1965-1973:

Part-time consultant to Fast Burst Reactor Facility.

White Sands Missile Ranse, New Mexico 7.

Scientific and professional societies of which a member:

American Nuclear Society (have held numerous responsibilities on national and division committees) sigma Xi l

Atomic Industrial Forum American Association for the Advancement of Science l

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Robert !.. Long - Raouse Page 3 8.

Nonors and'avards:

1958-1959:

USAEC Nuclear Engineering Fellowship 197A-1975:

Chairman, Education Division American Nuclear Society 1975-1976:

Chairman, Nuclear Engineering Department Heads Committee 9.

Description of professional experience:

a.

April 1982 - Present Effective April 1, 1982 I was elected Vice Frosident and Director of the Nuclear Assurance Division which includes the Quality Assurance Department, the Nuclear Safety Assessment Department Training & Education Directorate, and the Emerasacy Preparedness Department.

I also served as Acting Director of this Division from February - September 1980.

b.

February 1980 - March 1982 Director - Training & Education, CPU Nuclear Corporation, parsippany, N.J.

I had responsibilty for the direction of Corporate, TMI-1, TMI-2, and Oyster Creek Training Departments, and the System Laboratory.

4 c.

August 1979 - January 1980 Director - Reliability Engineering CPU Service Corporation.

Farsippany, N. J.

I was responsible for the direction of five functions providing technical support to the TMI Ceneration Group l

and the three GPU operating companies.

These functions included Quality Assurance Department, the Systes Laboratory, the Information Management Department, the Nuclear Safety Assessment Department, and the Generation Operations Support staff.

d.

April 1979 - July 1979 Member of TMI-2 Recovery Tees.

Arriving on site March 29, 1979, I had varied responsibilities including organisation of the Data Reduction and Management Group, head of the Accident Assessment Documentation Tese and Supervisor of the Technical planning Group. I also was appointed to the CPU Accident Investigation Task Force.

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gobert L. Long - gesuas Fase 4 e.

June 1973 - March 1979 Manager-Generation Productivity, GPU Service Corporation, Parsippany, N. J.

I was responsible for the staffing and program development of the newly formed Generation Productivity Department.

Activities included the development of an availability improvement program for implementation throughout the GPU System.

The program was concerned with total plant performance for all fossil and nucisar units and included:

1) Developing an integrated generating unit reliability progres.
2) Developing a reliability / availability / maintainability data system.
3) Developing a failure root cause analysis system and procedures.

4)

Identifying critical controllable factors and develop-ing procedures for a thermal performance improvement progtas.

5)

Developing a generacing unit performance testing program.

6)

Developing procedures and management accounting methods for instrumentation maintenance, major outage work manage-ment, and preventive maintenance programs.

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1965-1973 l

Faculty member, Nuclear Engineering Department, University of New Mexico.

Except for the two leaves-of-absences in 1966-67 and 1970-71, and a sabbatical leave in 1976-77.

I was actively engaged in teaching and research, primarily in experimental reactor physics.

During 1965-66 1 was engaged in half-time research at Sandia Laboratories and served as Project Engineer for the design of the SPR-II, fast burst reactor.

During 1967-69, again half-time. I participated in the design and carrying out of experiments to characterire the dynamic behavior of SPR-II.

During 1969-70 I directed a campus fast reactor physics experimental facility and directed the Ph.D. thesis of C. C. Price on reflector effects on fast burst reactors.

I was a licensed Senior Reactor Operator on the UNM ACN-201M training reactor, 1967-1973, and served as chief Reactor Supervisor

Roberg L. Long - Resuma Fase 5 1968-70 and 1973-76.

In 1969-70 I supervised the move of the reactor into a new laboratory, the complete redesign and assembly of the nuclear instrumentation and control system, and an increase in maximum operating level from 0.1 to 5 watt.

I served as Director of the Nuclear Engineering Laboratories, 1971-76.

During 1972-74 I served as Assistant Dean (half-ties) of the College of Engineering.

During that time period I also served as principal investigator for a contract with Consolidated Edison Company of New York to analyse axial menon redistribution and power shaping in large pressurised water reactors.

Under contract with the USAEC, I also developed two " neighborhood TV short courses" on nuclear energy and energy and the environment for use in public education efforts.

gffective July 1,19'74 I was appointed Acting Chairman of the Department of Chemical and Nuclear Engineering and in February 1975 I was appointed to a four-year ters as Department Chairman to begin July 1, 1975.

i From 1974-76 I supervised the design, development and on-campus installation of a fossil power plant simulator (Ph.D. dissertation I

for R. Busch) under sponsorship of the New Mexico snergy Resources Board and Public service Company of New Mexico.

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From 1977-78 I served as principal investigator on a project, sponsored by the New Mexico Energy Institute, to determine generally accepted pre-activity background levels for redon in the very active uranium mining and milling Grants / Ambrosia Lake area of New Mexico.

Together with M. J. Chanian, University of Florida I worked as a representative of the Nuclear Engineering Department Heads Coe-mittee to increase the support of government sponsored energy R&D in university engineering colleges.

This activity included successful introduction through the U. S. Senate of education support amendments to the 1974 ERDA and 1977 DOE Authorization Acts.

It also included organlaation of university / government exchange meetings with USAEC, ERDA, and NRC, and an EPRI/ University exchange meeting.

Myteachingwascenteredaroundthbdevelopmentand presentation of effective laboratory courses. while also periodically teaching the following lecture courses:

Introduction to Nuclear Engineering, Applications of Nuclear Energy for Non-Engineers, Reactor Kinetics and Control, Nuclear Systems Design.

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Robert L. Less - Resume Page 6 3.,1976-77 t

On sabbatical leave with tha Electric Power Research Institute, Palo Alto, California.

During my twelve-month sabbatical I worked as a project engineer in the Nuclear Engineering and Operations Department with responsibility for managing projects in availability engineering and development of an "optimised" utility power systems data base.

I also supervised and worked with an EPRI contractor to complete a PWR staan-generator performance survey. These various projects provided an opportunity to visit and closely interact with many utility, manufteturer, and government agency personnel.

h.

1977-1979 Consultant. EPRI.

Upon return to the UNM campus, I continued, as an EPRI consultant, to monitor reliability data base and records management projects.

I also coordinated the conduct of an EPRI Availability Engineering Workshop held in Albuquerque October, i

1977.

While with CPUSC I have continued as consultant to EPRI on l

avail ability engineering programs.

i 1.

1971-72 Consultant, General Physics Corporation.

I rewrote the Reactor

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Engineering Volume of the General Physics Corporation " Academic Program for Nuclear Plant Personnel."

j.

1970-71 ASEE-Ford Foundation Resident Fellow, serving as Associate Reac-tor Engineer with Con Edison of New York, Inc.

During my thirteen-month assignment. I was involved primarily in the coordination and I

planning of the repairs to the Indian Point Unit No. I primary coolant system.

I also performed various tasks of the Unit No. I reactor engineer.

I was principal co-author with R. B. Hayman of the Company's initial Quality Assurance Program report for Unit No.

1.

On a few occasions, I also assisted in the training program for the Unic No. 2 operators and in the preparation of Unic No. 2 procedures.

j.

1966-67 Temporary Research Associate, Nuclear Research Division, Atomic Weapons Research Establishment.

During my fourteen-month assignment I prepared the commissioning schedule for VIPER, Mark I, a fast burst reactor, assisted in the safety analysis and evaluation of the reactor and served as a senior reactor physicist and shift

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l Robert L Long - 1eeves l

Fage 7 supervisor during the initial startup.

I also planned the training program and presented some of the it;ctures for the initial startup steft.

1 1.

1942-41 Reactor Specialist (08-14), WSMR Fast Burst Reacter Facility.

I served as,the facility supervisor during the final design, construction, startup, and first year' of operation of the F5RF, a fast burst reactor.

This included responsibility for training of the staff, monitoring of contractor performance, preparation of the i

Fins 1 Safety scalysis Report, preparation of the startup and operating procedures, and analysis of the reactor physics operational data.

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1960-62 Student Research Aaeociate, Artsnne National Labcratory.

I was trained and certified as a co-operator, operator, and supervisor on the Argonne Thermal Source Reactor (ATSR) while performing my l

doctoral dissertation research.

I designed and built a reactivity measuring system for determination of neutron absorption resonance integrals.

I also assisted in the training of replacement operators for the AT$R.

10. Princisal publications:

"An Electrical Analogy of Nuclear Reactor Neutron Fluz," with J. R. Eaton, Nuclear Science and Enaineerina, 12, 82-90 (1962).

" Precision-Limitations in the Measurement of Small Reactivity Chauses," with' E. F. Bennett, Nuclear Science and Enaineerina, 17, 425-432 (1963).

"" Operational Characteristics of the WiMR Test Buret Aeactor,"

Meutron %namics and Control, AEC Symposius Serf.eg, 1, CONT-6504,3 (May, 1966).

" Measurements of the physics Characteristics of the Fast Pulsed Reactor, VIPER," with M. N. Taggart et al., IAEA Symposius Series, Fast Resctor Physics and Related SafecY Probles, Earlsruhe, Germany, November 1967.

" Reactivity Contributions in the Glory Hole of the Sandia Pulsed Reactor-II," Trans. Am. Nucl. Soc., 37, I (1963).

11 Also published in Nuclear Applications, 6, 1 (1969

- Fast Burst Reactors, Editor with P. D. O'Brien, Proceedings of the ANS National Topical Meeting on Fasc Burst Reactors, The University of New Mexico, January 28-30, 1969, AEC Synposium Series, CONF-690102 (1969).

See

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Robert L. Long - Resume Page 8

" Reflector and Decoupling Experiments with Tast Burst Reactors "

with R. L. Coats. AIC Symposium Series, Fast Burst Reactors, CONF-690102 (1969).

" Prompt Neutron Decay Constants in a Reflected Fast Burst Reactor," with C. C. Price, Proceedinas of the Symposium on Dynamics of Nuclear Systems, University of Arisona, March 23-25, 1970.

" Repair of Thermal Sleeve and Primary Coolant Pipe at Indian Point Unit No.1," with D. J. McCormick, Trans. Am. Nuclear Soc., 14, Supplement 2 (1971).

" Environmental Problems Associated with the Repair of a Nuclear Power Reactor Primary Coolant System," with G. L. Liebler, Proceedings of the Institute of Environmental Sciences (May, 1972), pp. 388-392.

" Courses About the Environment for Non-Technical Students "

Proceedinas of the Institute of Environmental Sciences (May, 1972), pp. 398-399.

" Educational Aspects of the Energy Crisis," New Mexico Academy of Science Bulletin, 14

- Teatus of Nuclear EngEe No. 2, pp. 45-48, (December,1973).

~

e-ing Education," with M. J. Chanian, Proceedings of AEC/ANS Nuclear Enmineerios Department Heads Work-Shop on Research in_ Nuclear Power Systems, pp. 2-20. University of New Mexico, (January, 1975).

"A Nuclear Energy Electiva for ' Engineers"," with J. W. Lucey and R. L. Carter Enaineerina Education, 61. No. 7, pp. 752-754, (April, 1975).

" Axial Power Shaping in Large Pressurized Vater Reactors," with H. M. Jorge and S. N. Purohit, Proceedings of.the Second Power Plant Dynamics, control and Testing Symposium, pp. 25-1 to 25-11 Knoxville, (September 3-5, 1975).

" Proceedings of U.S./ Japan Seminar on Fast Pulse Reactors, Editor with S. An and H. Wakabayashi, University of Tokyo, (January, 1976).

" Enhancement of Electric Power Plant Reliability Data Systems "

with R. J. Duphily, Proceedinas of_ the Fourth Reliability Enmineerina Conference for the Electric Power Industry, EEI, New York, (June, 1977).

" Methods to Improve Electric Power Plant Availability "

Proceedings of the 1977 Power Ceneration Conference, ASME, Long Beach, California (September,1977).

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" Introduction to Availability Engineering." Proceedings of the EPET Availability Engineering Workshop, Editor, R. L. Long, et l

al, EPRI Report NP-759-wS (March,1978).

" Engineering for Availability," with E. B. Cleveland, Power Engi-neerina, 82, No. 7 (July, 1978).

" Survey of Electric Power Industry Data Needs," with E. 8.

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d Robert L. Imag - Resuma Fase 9 f

' Cleveland, Inservice Data Resortina and Analysis, PVP-PS-032, ASME (December, 1978).

"Three hile Island Accident Technical Support," with T. M.

Crimmine and W. W. Iawe, haclear Technolony, M pp. 155-173,

( August, 1981).

" Applications and Development of RAN Information Systema at CPU,"

with J. L. Weiser, Proceedings 1979 Reliability Conference to the Electric Fever Industry ( April,1979).

"A post TMI-2 Mew on the Easponsibilities of Nuclear Engineering Educators",1980 ASEE Annual Conference Proceedians.

Asgg, Amherst, MA (June, 1980).

"Use of Behavioral Learning Objectives for Simulator Training,"

with 1. A. Enief, Proceedings of the Society of Applied Imarning Technology, (September, 1981).

" Operator Training and Requalification at GPU Duclear," with R. J. Barrett and S. L. Newton, Proceedings of Cak1/CECP/NEA, Qiarlotte, N.C. (October,1981), NURIC/CP-0031, vol.1, pp.

299-313 (June,1982).

"lesclear Personnel Training Af ter Thl-2: The GPCh Response," with D. F. Gaines and R. A. Xaief, Proares s in Nuclear Enernv, l

Fergamon Press, Vol.10, Number 3 pp. 349-361, (1982).

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- Iteenty-three summaries in the Transactions of the American huclear Society,1962 present, on various topics including fast burst reactors, power reacto: experiences, nuclear engineering, educational methods, public education in energy and environment issues, and availability engineering.

- hunerous technical reports on research design and development projects.

11.

Enference_s :

J. A. Prestele, Euclear Engineering & Operations Department, Elec tric Power Research Institute, P. O. Box 10412, Falo Alto, California 94303 G. A. khan, College of Engineering, University of how Mexico, Albuquerque, New Mexico 87131 W. A. Gross, College of Engineering, University of New Mexico, Albuquerque, New Masico 87131 l

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Robert L. Long - Resume Page 10

12. Personals l

9esitzt utfe = Ann Daughter - Beth (Age 20)

Son - Jeff (Age 18)

Son - Mark (Age 14)

Other interests:

Church school teaching and choir, woodworking, athletics (spectator and participant). reading Home address:

104 Brooklawn Drive, Morris Plains, N. J.

07950 Telephone:

Home:

201-455-0087 office:

201-233-2484 l

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