ML20211K224
| ML20211K224 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/10/1986 |
| From: | Woodhead C NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Jim Hickey SHAW, PITTMAN, POTTS & TROWBRIDGE |
| References | |
| CON-#486-1499 CIV-PEN, EA-84-137, NUDOCS 8611170102 | |
| Download: ML20211K224 (2) | |
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WASHINGTON, D. C. 20555 November 10, 1986
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J. Patrick Hickey, Esq.
Shaw, Pittman, Potts and Trowbridge 2300 N Street, N.W.
Washington, DC 20037
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In the Matter of GPU NUCLEAR CORPORATION (Three Mile Island Nuclear Station, Unit No. 2)
Docket No. 50-320 (Civil Penalty)
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Dear Mr. Hickey:
This letter contains the items we discussed on November 7,1986 concerning GPUN's incomplete responses to the NRC Staff's October 9," 1986 interroga-tories.
Several other related matters are also included.
As I
- indicated by telephone, it is the Staff's hope that GPUN will fully
- respond to the interrogatories voluntarily and cooperatively, making a motion to compel unnecessary.
The unanswered interrogatories are as follows:
Interrogatory 1:
For the members of TWG, SRG, and PORC, provide the members' positions in the TMI-2 subdivisions, e.g.,
" Recovery Operations, Site Engineering".
Interrogatory 2(b):
Explain the method of communications indicated in this response, i.e., whether written or oral.
How was the information received from William Austin?
How was the information about resume typing by Ms.
Rittle conveyed to Mr. Sandford by H. Bruner, B. Kanga and "others"? Who were the "others"?
By what means did Mr. Sandford direct referral of the resume typing matter to Bechtel's internal audit department? By what means did Mr. Sandford inform Mr. Arnold of his decision to interview Mr. Parks?
Interrogatory 3:
Part (a) is not answered as asked.
The question asks for the names and positions of all. GPUN or Bechtel employees interrogated by Messrs. Wheeler and Hofmann concerning the Quiltec Company and the date of each interrogation, whereas your answer states the employees interviewed concerning Mr. Parks alleged involvement in the Quiltec Company.
In addi-tion, you did not provide the positions within the TMI-2 divisions and subdi- -
visions of those interviewed.
(If the organizational positions are provided in response to Interrogatory 1, they need not be repeated).
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e Parts (b) and (c) have not been fully answered because you limited your replies to interviews before March 24, 1983.
Your objection is insupport-able, particularly since you did not limit your interrogatories and document requests to NRC by this date.
Please complete your response by providing the names and positions of all persons interviewed by GPUN or Bechtel con-cerning the Quiltec Company at any time, and any and all documents pertain '
ing to all such interviews.
We similarly take issue with the limiting of your responses to Interrogatories 4, 5, and 6 to the period before March 24, 1983.
Interrogatory 7 Part c.
No response has been provided.
Identify each and every person you contend would have been adversely affected by Parks' presence at TMI-2 after March 22, 1983 and explain the basis for such an assertion.
Contrary to your response, Part 7a. does not provide this infor-mation.
If you do not contend that any specific persons were so adversely affected, please so indicate.
Interrogatory 10[B}
Please respond.
Why are Kitler, Chwastyk, lirbac and Larson no longer employed by GPUN or Bechtel? Why have the following per-sons been transferred away from TMI-2: Arnold, Kanga, Barton, Thiesing, Gischel, Kobi?
Interrogatory 12:
This response is incomplete because you failed to provide for your witness list, the current employer, business hours, business ad-dress, telephone number and professional qualifications of the persons listed (for those not previously so identified in response to other interrogatories.)
Interrogatories 13 and 14: No responses were provided.
Please respond. In-asmuch as the requested communications bear on the reasons, motives, or purposes for which Mr. Parks was removed from the TMI site, we find your objection not supportable.
4 In addition to these matters, you have not provided the addresses and phone numbers of identified persons as requested in the " instructions and defini-tions" section of the Staff interrogatories.
We are especially interested in this information for all interrogatories after Interrogatory No.1.
Thanking you for your cooperation in advance, I am, Sincerely, Colleen P. Woodhead Counsel for NRC Staff
.