ML20212K389
| ML20212K389 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 03/03/1987 |
| From: | Barth C NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | GENERAL PUBLIC UTILITIES CORP. |
| References | |
| CON-#187-2712 ALAB-613, CIV-PEN, EA-84-137, NUDOCS 8703090293 | |
| Download: ML20212K389 (19) | |
Text
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[ 03/03/87 0f RELAThD CORRESPONDtJt64 .- I 80CMETE0 USNRC UNITED STATES OF AT.1 ERICA gg 6
NUCLEAR. REGULATORY COMMISSION ,
BEFORE TIIE ADMINISTRATIVE LAW JUDGE QFFICE QF Sgtpty.gy 80CKETit G 4 SEgysct BRANCH
.In the Matter of )
) ' Docket No. 50-320 CPU NUCLEAR CORPORATION ) (Civil Penalty)
) License No. DPR-73 (Three Mile Island Nuclear Station, ) EA 84-137 Unit No. 2) )
NRC STAFF RESPONSE TO GPU NUCLEAR CORPORA TION'S THIRD REQUEST FOR PRODUCTION OF DOCUMENTS On January 27, 1987, GPU Nuclear Corporation (GPUN) served upon the NRC Staff a Third Request For The Production Of Documents. The discovery of documents frora the NRC Staff is controlled by 10 C.F.R. 852.744, and 2.790 and .10 C.F.R. Part 2, Appendix A,Section IV(d).
Pennsylvania Povrer and Light Company (Susquehanna Steam Electric Station , Units 1 and 2). ALAB-613, 12 NRC 317, 321 ff. (1980) is the lending NRC case upon the subject. In its previous responses to discovery by GPUN and in its response to GPUN's Motion to Compel, the Staff has set forth its position with respect to conduct of discovery against the NRC Staff. O However, it should be noted that under 10 C.F.P. I 2.744(a) GPUN is required to describe with reasonable particularity the document it seeks and state why it is relevant to the
-1/ See, NRC Staff Response to GPU Nuclear Corporation'c First Set of T6terrogatories and NPC Ftaff Partial Response to GPUN's First Request for Production of Documents, September 23, 1986, at 1-8.
Release of documents herein (or in any other Staff response) should not be interpreted as waiver by the Staff of any applicable priviledge.
DP C!U.TED ORIGINAL
~
8703090293 870303 T gDR ADOCK 05000320 PDR Certified ,Mg,hal
2
. proceeding.. ;GPUN has failed to do so in its Third Request. In addition, ,
documents reasonably obtainable from other sources or already in the k
possession of GPUN need not be produced by the Staff - (10 C.F.R.
I 2."90(b). GPUN's Third Request requests many documents already produced formally or informally by the Staff, already in the Commission's
. Public Document Room (PDR), generally avellable in the public domain, or which were generated by or received by GPUN or Bechtel employees. In addition, a number of the requests are duplicative. For example, Request 1, in substance, requests every document in NRC's control which deals with Messrs. King or Gischel. Requests number 10, 11 and 12 request the same information, in greater specificity, than Request number 1 seeks. Under what Request a particitlar document should be placed is doubtful. Some documents mry be within the ambit of several Requests.
Where by words or inference there should be attachments or exhibits to a document and there are none, none were found with the document in the files. In some instances names, telephone numbers and addresses were
- deleted so as to avoid an unwarranted invasion of personal privacy as proscribed by 5 USC I 552b(c)(6) and 10 C.F.R. I 2.790(a)(6) cnd (7)(111) . Where a document falls within one of the categories exempt from mandatory disclosure under 10 C.F.R. I 2.790(a), the reason for non-disclosure is stated, together with the description of the document.
The Staff's response follows.
Documents being provided directly to CPUN pursuant to this reauest are being forwarded under separate cover.
Pequest 1 All documents received or prenared by the NRC, including employees of the Office of Inspector & Auditor (OIA) and the Office of Investigations
- ,_ , . . .-_.---...,,..__.._.,._,_-._.,__.,.,,--_m ....,__,_m_,..,._____, _ . _ _ , . _ - . _ _ - - _ . . - . - - . _ _
(OI), in the course of the . investigation of the 1983 allegations of ,
Lawrence'P. King and Edwin II. Gischel concerning procedural and safety violations and harassment at ' TMI-2.
Pcquest 2 All documents received or prepared by the OIA or other NRC employees in the ecurse of any investigations of the activities of Lawrence P. King, including but not limited to the investigation being conducted in July 1985 by Messrs. Resner and Ward of OIA.
Objection The allegations of ~ Messrs. King and Gischel, and 'any OI or OIA investigations pertaining thereto are irrelevant to the issues in this proceeding. The issues in this case relate to acts of discrimination against Richard Parks for engaging in protected activity. Similarly, NRC investigations into activities of Mr. King are irrelevant to the issues in this case. In addition, for reasons enumerated in its response to GPUN's February 4, 1987 Motion to Compel, the Staff objects to this request insofar as it requests notes and drafts of investigative materials.
Ifowever, without waiving such objection, the Staff below identifies responsive documents in its possession. In addition to those documents so identified, the Staff will make available to GPUU for inspection and copying, the O! files pertaining to its investigations of allegations made by Messrs. King and Olschel, except insofar as such files may contain information not required to be disclosed pursuant to 10 C.F.R.
I 2.790(a)(5), (a)(6), and (a)7(iii). These documents will be separately identitled.
Response
Requests 1 and 2 are potentially overlapping in scope and are treated by the Staff as one Request. Mr. King's personnel records and his background search resultinr from his seeking employment with the NRC
_ . _ . _ _ _ . _ = _ _ _ . _ _ . .
are excluded by agreement of counsel. However, Mr. King was ,
intersiewed by Mr. Resner of NRC's OIA on June 7, 1985 regarding involvement with Quiltec. That interview is included. Mr. King made an FOIA request of NRC on December 17, 1985 regarding how the NRC Staff
, concluded that he had not been harassed. That letter and the numerous NRC responses are in the PDR. However, they are identified here, i
without exhibits, to assist GPUN in ascertaining what documents are in the NRC's PDR that it may wish to examine.
DOCn efIS Requests 1 and 2 Documents DA7E PIO! p SUBJECT February 10 Lawrence King & Case File Record of Telephone and 17, 1984 Ronald Fleeks H-83-002 Conversation (Participants)
, Februery 9, 1984 Gloria King a Case File Record of Telephone Penald theks H-83-002 Conversation
- (Participants)
January 23, 1984 Robert Arnold & Case File Record of Telephone Ronald Pheks H-83-002 Conversation (Participants)
Novmber 11, 1983 Iswrence King & Case File Record of Telephone Ronald Meeks II-83-002 Oonversation (Partic'ipants)
Novmber 7,1983 Ekeks/ King Conversation Record
- Septenber 28, 1983 R.Meeks & Case File Record of Telephone -
l A. Kanner H-83-002 Conversation June 2, 1983 R.Meeks, Case File Record of Telephone
- J.Vorse, G. King H-83-002 Conversation
& T.Devine (Participants)
May 11, 1983 J.Vorse. R.Meelm Case File Record of Telephone B.Uryc & E.Gischel H-83-002 Conversation (Participants) s l
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. April 18, 1983 R.Meeks & Case File Record of Telephone ,
E.Gischel H-83-002 Conversation (Participants)
April 28, 1983 Meeks/Gischel File Note February 25, 1983 Lake Barrett Rick Keimig Cover note transmitting memos Ray Shepherd prepared by L. King & E.Gischel a mano . fr R.Freememan responding to King's &
Gischel's concerns.
(ATTNB1ENIE ARE Por WI1H THIS 'IRAt311TIAL ICIE)
February 25, 1982 R. Clark Notes from 2/25/83 meeting w/P. King litarch 2,1983 Ben B. Hayes maiman & Memo 'IMI, I. hit 2, Allega-Conmissioners tions by Director of Site Operations with Parks' Affidavit July 25, 1983 March 9, 1984 Ben Hayes Harold Denton Memo - King / Parks Testimony on Alleged Missing DH-2 Start-up and Test Doctanen-1 tation P1 arch 10, 1983 R. K. Christoper William Ward Memo - Infomation Received from Site Operations Director, 371-2 00 ENCLOSURE)
March 11, 1983 R.Gristoper Report of Inquiry / Interview L. King - 311-2 Interview of Site l (Participar.ts) Operations Director Regarding Safety Concerns March 10, 1083 J.Wiebe R.Oristopher Meno - Allegation From Rick Parks Dated February 18, 1983 March 18, 1983 J.Wiebe L.Barrett Memo - Letters Associated With Larry King's Concerns at 311-2 March 22, 1983 William Ward Hollis Bowers Meno - Infomation Received Regarding EfI-2 March 24, 1983 Lake Barrett Bernard Snyder Memo - Stamary of EflPO Site Actions Related to the Polar i Crane / Parks' Issues -
1 i
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March 30, 1983 , -Lake Barrett B.Snyder/ Note transmitting rough draft T.Poindexter version T.Fasano's notes of x meeting on 2/24/83 April 4, 1983 Lake Barrett Ben Hayes Tran mitting H.Gischel's meno and affidavit of safety concerns (!Ur ATDGED)
April 5, 1983 Lake Barrett Bill Ward Note - Re: Info fr Robert Arnold re Gischel April 6, 1983 Lake Barrett Bill Ward Note - transnitting L. King's response to R. Arnold's Itr of 3/4/83 April 14, 1983 T.Retun Qialman a Note - transmitting copy of Canmissioners Dff Advisory Panel Canments on the Gischel Issue
- April 22, 1983 Barrett Dircks TII Advisory Panel ,
Conments on Gische1 issue April 22, 1983 'Ihanas Devine R. Donovan Ltr tranmitting prepared
- statenent a affidavit of Joyce Wenger -- with at tactinent s
- 1. Note to file (3/11/83) re Wenger Interview of
- 3/10/83
- 2. Mano to T.? b ra, J.Troebliger, a H.Masini fr J.Wenger (3/22/83) re: response to inter-office memo of 3/11/83
- 3. Ltr of temination to J.Wenger fr J.Troebliger
- (3/23/83) ,
April 26, 1983 Roger Fortuna King / Park / Record of Telephone Gischel File Coriversation May 18, 1983 J.Vorse/R hteks Statement of Lake Barrett (Participants)
B"ay 27, 1983 William Ward Hollis Bowers Transmitting - Statement By
%flPO Deputy Director (Lake Borrett) i June 14 ara 20, 1983 R.Meeks/T.Devine Case File Record of Telephone L. King H-83-002 Conversation l (Participants)
- June 24, 1983' R.Meeks Wi11iun Ward Memo - Conversation w/'Ihemas Devine on 31I-2 Safety Review Group Septenber 1,1983 Ben llayes Chainnan Memo - Dil Nns, m it 2 Alle-Palladino gations Re Safety Related Modifications a CyL Procedures (H-83-002)
(lat PAGE OF DOCIM!NT CNLY) mdated E.Gallagher Ben Hayes Memo - Review of Results of 3f1-2 Investigation on Alleged Procedural and Managerial Issues January 25, 1984 William Dircks Conmissioners Policy Statenent - Negative Consent SECY-84-33 (Notice of Violation) withheld decisional docunent mdated & Wsigned P.C1 ark (GPU) R.DeYoung Tranamitting Notice of Violation hhy 18, 1984 J.Fitzgerald Cannission Policy Issue (Notation Vote)
SBCY-84-205 - Public Release of OI's 'IMI Investigative Reports (Keaten a Parks /
King /Gischel)
June 7, 1985 LKing/M.Resner/A. Ward Transcript of (Participants) Interview of L. King Decenber 17, 1985 L. King NRC Letter MIA Request (mIA-85-838)
January 29, 1986 D.Grimsley L. King Ltr - 1st Partial Reponse to ICIA Request (MIA-85-838)
Appendix A - List of docu-ments being released Appendix B - List of docu-ment available in PIR i thrch 25,1986 D.Grimsley L. King Ltr - 2nd Partial Reponse to ICIA Request (101A-85-838)
Appendix C - List of docu-ments being released May 1, 1986 D.Grimsley L. King Ltr - 2nd Partial Reponse to FOIA Fequest (IDIA-85-838)
L
Appendix B ' List of docu ,
ments being released January 29, 1986 D.Grimsley L. King Ltr - 1st Partial Response to MIA Pequest (mIA-85-838)
Appendix A - List of docu-ments being released August 6, 1986 D.Grimsley L. King Ltr - 3rd Partial Reponse to MIA Regeust (EIA-85-838)
Appendix C - List of docu-ments being released Septat>er 23, 1986 D.Grimsley L. King Ltr - 4th Partial Response to FOIA Request (POIA-85-838)
Appendix D - List of docu-ments being released Appendix E - List doctnent portion being withheld Appendix F - List doctment portions being deleted Appendix G - List doctnents withheld in entirety October 8, 1986 D,Grimsley L. King Ltr - 5th Partial Response to IOIA Request (MIA-85-838)
Appendix H - List of docu-ments being released Appendix I - List doctments portions deleted Appendix J - List decanents withold in entirety October 24, 1986 D.Grimsley L. King Ltr - Final Partial Response to mIA Request ( MIA-85-838)
Appendix K - List doctments already available in PIR Appendix L - List doctments !
being released
m __ .
- ~ _ - . _ _ _ . _ _
., April 18, 1983 '
Meeks/Jenkins/ File Note .
Glasier April 18, 1983 Meeks/Wenger File Note April 22, 1983 h eks/ Richardson File Note
'May 23/24,'1983 Meeks/ Richardson / File Note Lake July 25, 1983 Meeks Receipt-Divine Papers i Septenber 22, 1983 Meeks/ Lake /Kanga File Note Richardson May 26, 1983 Ward Barrett OI Investigation-Site -
Activities May 27, 1983 Hays /Vorse/ File Note Barrett/etc.
June 29, 1983 Clanenson Fortuna Report on Technical AlIegations May 28, 1983 Vorse, et. al. File Note I.hdated List of Polar Crane Considerations March 1, 1983 Wiebe Report of Allegation March 11, 1983 O ristopher Interview with King P.eouest 3 .
All documents reflecting or relating to the investigation of the King allegations by the Department of Labor (DOL) including the DOL Report l with all attachments, exhibits and supporting documents; witness i
statements; and notes of interviews.
l Objection:
When Mr. King applied to the NRC for employment much of the DOL file I was reviewed by NRC's Personnel Security. The DOL papers were not j retained by Personnel Security. We have enclosed a letter from
! Mr. Ilayes, OI, to Mr. Craven, DOL, dated February 22, 1984, which may suggest that OI looked at DOL files. If so, these DOL documents i
l
l l
, were not , retained by OI. - GPUN will have to go to DOL for the requested .
documents. :
IXXnFNIS Request 3 Docunents TWIE PEGI p SLBJECT February 22, 1984 B. Hayes Craven King-DOL Docunents Reauest 4 All documents reflecting or relating to any analysis, review or evaluation by the NRC of the King Tini, Report, or of Mr. King's conduct while employed by CPUN.
Objection The NRC analysis is contained in NUREG-0680 Supplement No. 5, TMI-1 Restart , July 1984, a copy of which GPUN has. The second part of the Request duplicates Requests 1 and 2. Any other documents responsive to this request are included in response to those requests.
Request 5 All transcripts of Commission meetings discussing the allegations of f.lessrs. Parks, King or Gischel, Request 6 The complete transcript of the Commission meeting held starting at 10:08 a.m. on May 23, 1984.
Response
Objection to the transcript of the Commission morning meeting of May 23, 1984, on the ground that the subject matter is not relevant to any issues ,
in this proceeding. Only pages 2 and 3, attached, are remotely related to the Parks-King-Gischel allegations. Transcripts, in so far as possibly relevant, of other closed Commission meetings, are enclosed.
DOCU@NIS -
s Requeat 5 and 6 Doctments IKIE P! O f p StBJECT April 15, 1983 Camission meeting (closed)
Tr. pp. 2, 3, 5-9
, April 22, 1983 Cannission meeting (closed)
Tr. pp.16-33 June 6, 1983 Cmmission meeting (closed)
Tr. pp. 1, 2, 26-43, 49 October 6, 1983 Camission meeting (closed)
Tr. pp. 1-3, 22, 23 i- January 10, 1984 Cm mission meeting (closed)
Tr. pp. 15-16, 43, 45-48, 62 March 23, 1984 Cm mission meeting (closed)
Tr. pp. 39-42, 72, 73 May 23, 1984 Cmmission meeting (closed)
Tr. pp.98-100 Request 7 All documents reflecting or relating to any analysis, review or evaluation by the NRC of the DOL Report on Mr. Parks, including all documents considered in the NRC's " review of this [ Parks'] matter" referred to in NUREG-0680, Supp. 5, p.10-18.
Objection The Staff's analysis of Parks' harassment allegation is contained in i Chapter 10, NUREG-0680, Supp. 5. Other materials relating to the allegation were contained in OI's investigation report and its attachments,
- which were sent to GPUN's attorneys (see Memorandum , Clements to George Fox Trowbridge, dated June 11, 1984, copy attached), in the Parks documents previously provided to GPUN, in the Commission's PDR and in the responses to the Zuras FOIA 85-700. A copy of the Staff l
e-responses, to.FOIA-85-700 is included to assist GPUN in ascertaining which ,
s- papers it seeks may be in the PDR.
DOCXhENIS Recuest 7 Docunents DGE MEN p StBJECT June 11, 1984 Clements Trowbridge Exhibits to OI Report H-83-002 Septenber 19, 1984 Transcript cover page -
Proposed Agency Advisory Panel for the Decontamination of 'Dff-2 February 7, 1985 L. King II.Denton Re l'R1 REG-0680, Supp. 5 February 25, 1985 II.Denton L. King Re NURBG-0680, Supp. 5 July 3, 1985 S.Gilk mairman Carments on SBCY-85-177 Palladino withheld decisional docunent July 23, 1985 S. Oilk Canm. Bernthal Caments on SECY-85-177 withheld decisional docunent August 7, 1985 Hayes Dircks Proposed Enforcenent Action August 9, 1985 S.Gilk mainnan & Akmorandun from OI Concerning Conmissioners Enforceent Action - GPU lbelear Corporation October 8, 1985 B.Zuras FOIA Office Req docunents re O! has on R. Parks October 23, 1985 L.Cuoco C. Reed Note - 701A-85-700 - trans-mitting docunents - Attactinent
- list of docunents Noventer 21, 1985 D.Grimsley B.Zuras Ltr - Partial response to ICIA Recuest 85-700 Appendix A - List of docu-ments available in PIR June 11, 1984 Clements Trowbridge Of Report H-83-002 Exhibits
, October 1985 '
Grimsley Zuras ICIA-85-700 .
Identiffes Doctanenta January 14, 1985 Orimsley Zuras ICIA-85-700 Doctanent Lists January 31, 1985- Grimsley Zuras 10!A-85-700 Doctanent Lists May 1, 1986 Orimsley Zuras ICIA-85-700 Doctanent Lists May 21, 1986 Orimsley Zuras 10IA-85-700 Doctanent Lists Shy 27, 1986 Ortrasley Zuras IOIA-85-700 Doctanent Lists June 24, 1986 Grimsley Zuras ICIA-85-700 Doctanent Lists January 14, 1985 D.Grimsley B.Zuras Ltr - Partfal response to IOIA Request 85-700 Appendix D - List of docu-ments being placed in PIR Appendix B - List of docu-ments available in PIR ,
l January 31, 1985 D.Orimsley B.Zuras ltr - Partial response to ICIA Pequest A5-700 I
Appendix F - List doctanent being witheid May 1, 1985 D.Grimsley B.Zuras Ltr - Partial response to ICIA Request 85-700 Appendix 0 - List docunents i available in PIR Appendix H - List doctanents being placed in PIR Appendix I - lint docunents being witheld
, May 21, 1985 D.Orimsley D.Zuras Ltr - Partial response to ICIA-85-700
, Appendix J - list douanents being placed in M R l
i
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l
. - - - - - ~ - - . , - , ~ _ . - , - - ~ . , _ _ . . - - - _ . - - . ~ . - - - - _ - - _ _ _ -. r--,_. . - . _ . - _ , . , , . - - --____ -
, 14 -
Appendix K - list douanents being withheld May 27, 1985 D.Orimsley B.Zuras Lir - Partial Reponse to FOIA-85-700 Appendix L - list of docu-monts being withheld June 24, 1985 D.Grimsley B.2uras Ltr - Partial Response to MIA-85-700 Appendix M - list of docu-ments being withheld Decarber 26, 1985 D.Grimsley B.2uras Ltr - Partial Response to NIA-85-700 Appendix B - list of docu-ments being placed in PUR Appendix C - list of docu-ments available in PIR Request 8 All documents reflecting or relating to any evaluation, analysis or consideration by the NRC of Mr. Parks' " mystery man" allegations, including Parks' claims expressed in his meeting with NRR on November 20, 1983, and including all documents relating to the "on-going" O! investigation of the " mystery man" issue referred to in Ben R. Hayes' memorandum to Ilarold R. Denton of October 28, 1983.
1100MNIS Request 8 Doctments TWIE FID1 p StBJECT February 26, 1987 R. Sheks Pile Af fidavit May 27, 1983 R.Fortuna File Mano - Telecon w/ Henry hkyers, 5/20/83 re:
1MI 2 Clean-up Noverber 7,1983 Robert Capra Roger Mattson Meeting w/Dr. Henry Myers w/attactrnent Request 9 All documents reflecting or relating to any evaluation, analysis or consideration of Mr. Thomas A. Devine's Sept. 17,1984 " Rebuttal of NRC L
- staff conclusions on retallation during the Three Mile Island-2 cleanup," .
(produced in the NRC Staff's January 5, 1987 Third Supplemental Response to GPU Nuclear's First Documents Request), including any response to Mr. Devine.
Objection Handwritten notes and drafts of documents are not required to be relca' sed under 10 C.F.R. I 2.790. Without waiving that objection, the Staff provides the materials as identified below.
DOCu fNIS Pequest 9 Doctanents DNTE fB3f p SUBJECT Septaber 17, 1984 T.Devine Memo - Rebuttal of NRC staff conclusions on retaliation during the 'IMI-2 cleanup (handwritten notations made by Carl Mohminkel, PRC Staff)
Request 10 The " reports" prepared by the " technical team composed of members of the EDO staff" on the Parks and Gischel allegations, and any reports or documents reflecting or relating to the OPE " analysis and review" of those reports, referred to by Ben R. !! ayes in his remarks to the Commissioners at the Commission meeting of June 6, 1983, p. 26 (copy attached) .
Responso This material has previously been provided to GPUN.
Request 11 The following memoranda identified in exhibit D-10 to the September 1, 1983 O! Report: (a) Memorandum from H. Denton to B. Ilayes (July 18, 1983): (b) Memorandum from D. Hayes to II. Denton (ffay 11, 1983); (c)
Memoranduta from H. Denton to D. !! ayes (June 8,1083) with enclosures and (d) Memorandum from B. Hayes to !!, Denton (June 23, 1983).
D0aPM ,
Request 11 Doctanents IWIE FIDf p EtBJECT May 11, 1983 B. Hayes H.Denton Memo - Investigation DII-2 engineers
' June 8, 1983 !!.Denton B.llayes IWsno - I:xisting Reguatory Framework for 'IMI-2
' June 23, 1983 B. Hayes II.Denton Mano - 3f1-2 Recovery Project July 18, 1983 II. Denton B.IIayes Memo - Regulatory Criteria for Oversight of the DII-2 Cleante Request 12 l
All notes taken by Joel Wiebe or any other person, and all other documents not previously produced, that record, discuss, memorialise or refer to the interviews of any witnesses including Lawrence King, Edwin Of schel, Charles Hansen, James Thiesing, and Ed Kitler conducted by TMIPO in February or March,1983.
Objection Handwritten notes and draftr, ere not required to be released pursuant to 10 C.F.R. I 2.790(a). Without waiving such objection, the Staff provides I
responsive documents as set forth below.
Response
Material relating to ?tr. Wiebe's interviews referred to has already been
- produced. Some additional documents are enclosed.
D00 M NIE Recuest 12 Doctanents t
DME Ff0f p StBJECT Ihdated List - Open issues from
- Gischel's affidavit i thdated 'Ihamas Snithgall NRC 311-2 Cleanup i
i
- i 6
. . . , . . - - - _ , . . , _ , , , , _ _ , _ _ _ . _ - , _ , - - _ _ . . ,__,,_,m. . , , , , , , . , _ . . . _ . , _ , - _ , . . _ , - _ _.__,,_,-,_.___m,
__ ,,m-,...__m-
B
, March 1, 1983 ,
L. King Record of Allegation .
J.Wiebe (Participants) 5terch 10, 1985 A.Fasano/JM ehe R.Oristopher Memo - Additional infonnation provided by Mr. L. King, Site Operations Director, 3/9/83 March 10, 1983 R.O ristopher Willian Ward Mano - Infonnation Received from Site Operatins Director, Bil 2 March 11, 1983 A.Fasano/J.Wiebe R.Oristopher Memo - Additional Followup on the Rick Parls' Allegation dtd 2/18/83 March 10, 1983 L.Barrett J.Larson Memo 'IMI thit 2 Recovery Operations Polar Crane Operation March 11,, 1983 J.Wiebe/A.Fasano L.Rarret t Meno - Letters Associated w/L. King's Concerns at Bf!-2 hkrch 11,1983 R.Gristopher Peport of Inquiry / Interview on L. King
, March 24, 1985 L.Barrett B.Snyder Memo - Surmary of T!!IO Site Actions Related to the Polar Crane / Park's Issues March 25, 1983 J.Wiebe Log notes March 28, 1983 J.Wiebe Log notes March 29, 1983 J.Wiebe Log notes March 8, 1983 J.Wiebe Log notes March 9, 1983 J.Wiebe Log notes March 23, 1983 J.Wiebe Log notes March 24, 1983 J.Wiebe Log notes Request 13 l All documents, other than those already produced, gathered, compiled, submitted to, received by, or authored by the Compliance Officer in the
, DOL investigation of Parks' claims of harassment.
l
1 l
s Response, . .
i The Staff has no documents responsive to this request not already '!
produced.
Request 14 All documents concerning Park's involvement with Outltec. .
Objection The Request is overly broad and vague. Staff counsel unsuccessfully inquired as to whether GPUN's counsel could be more specific as to what they sought so that the Staff's search might be productive.
Response
To the best of the Staff's knowledge, the Staff has already provided all responsive documents, not already in the possession of GPUN.
Request 15 All documents reflecting or relating to any evaluation, analysis, or considc1= lion of the Stier Report and Bechtel Report (as defined in Responses of GPU Nuclear Corporation to NRC Staff's First Set of Interrogatories (Oct. 28,1986) at 1).
Responso .
The Staff's evaluation of the Stier Report was factored into NUREG-0680, Supp. 5. The Staff responded to Bechtel with its views of the Bechtel Report. GPUN should have th6t Staff response.
Respectfully submitted, Charles A. Barth mW '
Counsel for NRC Staff l Dated at Bethesda, Maryland this 3rd day of March,1987 I
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, CONtyC
. UNITED STATES ,OF AMERICb gg -6 P2 NI ,
NUCLEAR REGULATORY :r COMMISEION
~
DEFORE TJfE ADMINISTRATIVE LA4F#UpfgyhN[cf.
uy.n W kHCH f
In the Matter of )
) Docket No. 50-320 GPU NUCLEAR CORPORATION ), (Civil Penalty) 1 License No. DPR-73 (Three Mile Island Nuclear Station )
EA'84-137 ' '
Unit No. 2) ) -
i
> .s c CERTIFICATE bl6 4ERVICE $
I hereby certify that copies of "NRC STAFF RESPONSE TO GPU NUCLEAR CORPORATION'S THIRD REQUEST FOR PRODUCTION OF DOCUMENT 8" in the above-captioned proceeding have been served i on the followhig by deposit in the United States mall, first class ,
or, as indicated by an asterisk, by deposit .in the . Nuclear Regulatory ' Commission's internal mail system ,' this 3rd day of March 1987.
- ! van' W. Smith, Esq. Ernest L. 31ake, Jr.
, Adminh trative Law Judge Shaw, Pittman, Potts a Trowbridge Atomie Safety and Licensing Board 2300 N Street, NW U.S. Nuclear Regulatory Commission . Washington, DC 20037 Washington,, DC 20555 ,
- Atomic Safety and Licensing Steven L. 'llock, Esq.
Appeal Poard Thelen, Marrin, Johnson, Bridges U.S. Nuclear Regulatory Commission 2 Embarcadero Center
-?Waahington, DC 20555- San Francisco, CA 94111
- *Dccheting and Service Section Office of the Secretary , !
U.S. Nuclear Regulatory Commission Wahfpgton, DC 20555
~
^ 44 '
, Charles A. Barth '
Counsel for NRC Staft v - - - - - - . .+ pr, ---------~----mw -w-e- -rn-----n, - > - , , - - ,,,n --,~~,,.n --,,-,-,,-*---e,--, ..-,wv. , , -,- ,-.~n ---