ML20214L671
| ML20214L671 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/08/1986 |
| From: | Bradford L THREE MILE ISLAND ALERT |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#386-613 CH, NUDOCS 8609100322 | |
| Download: ML20214L671 (17) | |
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GENERAL PUBLIC UTILITIES NUCLEAR,
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Unit No.1)
TMIA's REPLY TO FINDINGS PROPOSED BY CHARLES HUSTED I.
Introduction 1.
TMIA hereby submits its reply to findings proposed by Charles Husted.
TMIA will not attempt to respond in its reply to each finding or conclusion proposed by another party with which TMIA disagrees but will address only those findings which in TMIA's view ignore record evidence or mischaracterize the record.
2.
TMIA has chosen to direct its response to Husted's findings since the findings of GPU and Staff track them closely.
TMIA's failure to respond here to points raised by other parties with which it disagrees should not be viewed as a concession of those points; rather TMIA relies upon its findings filed 18 Aug. 1986.
II.
TMIA's Reply to Husted's Findings A.
Husted's Attempt to Cheat.
In 1132-43 of his proposed findings, Husted has set forth his version of the incident involving David Janes and Husted during the 24 Apr.
1981, Senior Reactor Operator examination.
Husted correctly" observes that William Ward and Peter Baci, NRC investigators, testified before the Special Master that during his 25 Sept. 1981 interview Janes told them that Husted had asked him an ex=-related question during the exam.
(Husted PF 134).
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When Janes testified in 1981, he denied having told the-investigators that Husted had asked him a question. Husted also denied having made an attempt to cheat when he testified in the earlier prcceeding.
In the face of Ward's clear and forthright testimony that Husted had made a solicitation during the examination, the Special Master concluded that the denials of Janes and Husted were not credible.
Husted suggests that the summary of the Janes' interview is invalid since that interview was not recorded verbatim.
Furthermore, Husted claims that had Janes been given an opportunity to review and sign the investigators record of his interview, its accuracy would be more certain.
(Husted PF 144)
There is no evidence that Janes requested that he be allowed to review and sign the record of his interview, or that had he done so, the request would have been denied.
In fact Ward testified that sworn testimony is necessary only.under certain conditions, (a) when an individual has admitted an act-which is under investigation, or (b)' when the interviewer feels that the person being interviewed is providing substantive information on the subject under investigation and is likely to change that testimony later.
Tr. 194 (Ward)
Clearly the OIE investigators have no motive to incorrectly attribute testimony to interviewees.
Nor is it likely~that the issues which are currently in dispute were inaccurately recorded by OIE.
They were well aware of what constituted evidence on the issues they were investigating, f
They took extreme care not to make careless statements which might prove unnecessarily harmful to the person being interviewed. Tr.195 (Ward) (Baci).
The faithful conformance to Matakas' notes by the individual who wrote the
\\
summary is proof that all important facts recorded during interviews became j
part of the summary, without distortion or embellishment, regardless of who j i i
1.
actually wrote the summary.
ff. Tr. 501, attach. 2.
There is no evidence that the production of the other summaries of interviews which made up the OIE investigation reports, was any different than the Matakas interview.
With regard to the Janes interview, Ward testified that he wrote the summary based upon his "somewhat fragmentary notes and his clear memory of the interview." It is Ward's habit to take few notes, the Janes interview was no s
different in this regard and cannot be disparaged.
Husted feels that it is not necessary to decide which testimony is correct.
(Husted PF 138)
He is totally off the mark with this assumption.
The fact that Janes told Ward during his interview that Husted had asked him a question luring the examination, and later denied having made that assertion, undermines his credibility and renders his testimony unreliable.
Dur'ing the Husted hearing there was controversy over Ward's use of the word " solicitation" in his prior testimcny.
(Husted PF 140)
Husted cites.
Baci's testimony that he would not have used the word solicitation to describe the question asked by Husted, but ignores the testimony that Baci agreed to Ward's testimony before Special Master.
According to Ward's most recent testimony Janes did not use the term during his interview when discussing the question Husted asked.
Ward said it was he who used the word and that he (Ward) inappropriately originated the term. Ward also testified that the word
" solicitation" " carries more freight" than he had intended in fact when he used the word in prior testimony.
Baci said that he was comfortable with Ward's use of the word in 1981.
Tr. 272 (Baci).
Ward also repeated his prior testimony that investigators take great care not to impugn the integrity of the individuals they interview..
It is inconceivable that experienced investigators, who admittedly were mindful of the possibility that their testimony had the potential to jeopardize the reputation of individuals they had interviewed, would use the word " solicitation" carelessly when testifying about potential cheating.
Moreover, it is not likely that Ward and Baci would have pursued the Janes allegation had they felt that it was no more than a rhetorical question asked by Husted.
(Husted PF T41)
When the interview began Ward and Baci had told Janes that they were not interested in the exclamation of exam candidates.
ff. Tr. 240, attachment 2 at 25, 461.
The important thing here is Janes denial in the face of the clear testimony of Ward and Baci that Janes alleged that Husted asked him a question during the examination. This denial renders Janes testimony incredible.
The evidence regarding the attempted cheating is not altered by the additional testimony provided in this proceeding. 'In order to resolve this issue I must review the credibility of the witnesses. I have found below that Husted refused to cooperate in an NRC investigation, that he gave' incredible testimony and that he exhibited a remarkably poor attitude toward the hearing process. The clear weight of the evidence demonstrates that Husted attempted to cheat during the SRO examination.
B.
Husted's Refusal to Cooperate With NRC Investigators.
The issues examined by the Special Master in reaching his conclusion that Husted was not credible are as follows:
a) Husted's refusal to cooperate with an NRC investigation.
b) Husted's inconsistent testimony during his appearance before the Special Master.
c) Husted's poor attitude toward the hearing process as demonstrated during his 1981 testimony..
With regard to these issues Husted has concluded in 1160, 67 that he was not uncooperative during either of the two NRC interviews. That he was exceedingly nervous during his 1981 testimony, and that his " state of mind" led him to make numerous testimonial errors which might be viewed as inconsistencies, but he corrected those errors during his appearance before the Special Master.
(Husted 1151, 64, 69).
That this same " state of mind" caused him to respond to questions put to him during the 1981 proceeding, in an apparent " flippant" or "less than serious" manner.
(Husted 168, 85, 86).
I will examine each issue below.
~
C.
Husted's Refusal to Cooperate With an NRC Investigation (Husted PF 11 48-67).
- The First OIE Report In 11 54-60 of his proposed findings, Husted claims that because no notes cf the interview were produced and because the witness called by the Staff testified that he had no memory of the interview, the fourth paragraph of the first OIE report has not been shown to be accurate. Husted prefers to rely on the report of the interview prepared by Paul G. Christman, Manager, Plant Administrator, for the following propositions:
(a) Husted answered "no" when asked if he had knowledge of cheating on the Apr. 1981 NRC examination; (b) the term " unconfirmed hearsay" was not used during the interview; and (c) while Husted initially refused to answer when he was asked if he had heard rumors of cheating on the examination, he subsequently responded that he had no recollection of having heard such rumors.
(Husted PF 60)
Husted has ignored the fact that the notes which Christman took during the interview, and which formed the basis of his report, are not available, and that Christman had very little independent recollection of the interview.
ff. Tr. 351 at 2 and 3.
Furthermore, Christman had no L
pre-knowledge of what information would prove important to the investigation.
One of the reasons for his presence at the interview was to " learn about the subject under investigation."
Tr. 365 (Christman).
Consequently, he felt that everything that was said during the interview was important and he attempted to capture everything that occurred.
He recorded the interview by "using words and phrases that would jog my memory to complete a sentence. But my notes, I think for this interview, would have been rather extensive."
Tr. 367 (Christman).
Those notes are unavailable, thus there is no way to verify the accuracy of Christman's report.
The OIE report of Husted's 29 July 1981 interview is clearly more reliable than Christman's account. The investigators who interviewed Husted are trained professionals.
They knew before the interview began what information was important to the investigation.
It was not necessary for them to record the extraneous background information which made up much of the Christman report.
(See Husted Ex.1)
Furthermore, the investigators had no motive to attribute to Husted phrases he had not used. The way in which the OIE summary of Husted's first interview was written clearly indicates that the investigators were impressed with Husted's refusal to answer certain key questions posed to him.
That summary was based on notes taken by the investigators during the interview, and it speaks for itself.
The Second OIE Report Husted also quarrels with the OIE summary of his second interview.
He claims that that report is inaccurate on two counts.
First, he insists that he did not tell Matakas that the " passing papers" comment noted in the second summary is the " unconfirmed hearsay" recorded in the first summary.
(Husted PF 162)
Second, he claims that he did not tell Matakas that the _
comment that he heard at the water cooler referred to " passing papers in the exam."
To bolster these claims Husted points out that Matakas did not have a copy of the first OIE report with him when he interviewed Husted.
(Husted PF 162)
That Matakas' notes do not contain the questions which 4
prompted the answers recorded in the notes. And that certain margin notations might not have been made "right away."
(Husted PF 163) This is sufficient to convince Husted that the OIE summary of his second interview is inaccurate, despite Matakas' testimony that his notes are an accurate depiction of the interview.
Matakas' confidence in the accuracy of his notes stems from the style in which the notes are written. He testified that the legibility of his notes, coupled with the fact that he recorded Husted's responses in the first person, indicates that they are verbatim recordings of Husted's responses and that he read those responses back to Husted in order to verify their accuracy.
(Tr. 412 (Matakas)
Moreover, Matakas explained that Husted did not request that both questions and answers be recorded and that he (Husted) be allowed to review them. Matakas said that it is not his habit to record an interview in that manner, and had Husted made such a request he (Matakas) would have delayed the interview until a court report was present.
Tr. 408 (Matakas)
In the face of Matakas' clear and unequivocal testimony, Husted speculates that Matakas' questions may not have been precisely phrased, or that he (Husted) may have misunderstood the questions posed to him.
(Hustad PF 164)
Even assuming that Husted's speculation regarding his second interview is valid, he has yet to explain why he made no attempt to correct these errors in the five years since the issuance of the OIE reports.
Given the consequences to Husted arising from the decisions, which were based in
large part upon the OIE reports, his failure to correct the " mistakes" and
" inaccuracies" in these reports is the strongest evidence of their accuracy.
Husted believes that the notes taken by John Wilson, a company lawyer, of a telephone conversation between Wilson, Hus'ted and John G.
Herbein, former Vice President, Nuclear Assurance, GPUN, on 5 Oct. 1981, provides proof that he heard only two words " passing papers" when he passed the water cooler.
But the Wilson notes cannot reasonably be interpreted to contradict the fact that Husted told Matakas that he heard someone say
" passing papers in the exam."
In fact the Wilson notes indicate that Husted had far more information than he gave Matakas.
(See TMIA PF 1155-58)
One of the purposes of the meeting with Herbein was to make sure Husted recognized his responsibility to the company to tell them what he knew about cheating at TMI.
Tr.927 (Herbein)
However, Husted had not formally provided that.
information to anyone in the company.
(See ff. Tr. 502 attach. 2 at 2)
Thus it was in his interest to lessen the import or what he had overhead, he did so by omitting the last part of the phrase, i.e.,
"in the exam. " It is obvious from the information Husted had provided to Matakas in Sept. that he was not fully forthcoming with Herbein and Wilson in the 5 Oct. discussion.
What is also clear from the Wilson notes is that as a result of his conversation with Herbein, Husted recognized the seriousness of having withheld information from the NRC.
He was concerned about. the possibility of
" criminal penalties" (Husted Ex. 11 at 3) and he wanted Wilson to call "I and E" to make sure that they understood that Husted had heard two words at the water fountain, " passing papers."
(Id. at 2)
It is not plausible that during the 5 Oct, meetings with Herbein Husted could not recall whether he had told Matakas about the " passing papers" incident, according to Matakas' notes the discussion of that incident occupied a significant portion of the thirty t
s minute interview.
When Wilson told Husted that he must call the NRC himself to verify what he had told Matakas, Husted said he did not want to make the call or have anyone from the company call the NRC.
(Husted Ex. 2)
Samuel Newton, former group superior, Licensed Operator Training, testified that during a conversation he had with Husted between the two interviews Husted told him that during the first interview he had been asked by the investigators if he had " heard any rumors about passing papers" (ff.
Tr. 836 at 4) Newton also recalls their having discussed the " passing papers" comment during this same conversation.
Id. at 3-6.
Although Husted says he has no memory of this conversation with Newton (ff. Tr. 330 at 19), he is nevertheless convinced that Newton is wrong about its content, claiming that Newton's testimony in this regard is inconsistent with his own memory of his first interview.
(Husted PF 166)
However, Newton's recollection is consistent with the general thrust of the first phase of the investigation.
(See Husted Ex. 26 generally)
Husted relies on Wilson's notes for the proposition that the conversation with Newton took place after the second interview (Husted PF 165).
But there is no evidence that Husted believed that an informal conversation with Newton fulfilled the company requirement to report information. Husted told Matakas that he had not been " formally" interviewed by GPU concerning his knowledge of cheating.
(ff. Tr. 501 attach. 2 at 2).
Husted's proposed conclusion that he was not uncooperative with the-NRC investigators during his two interviews is dependent upon a belief in a series of incredible events.
a) The investigators who conducted the first interview reported incorrectly that Husted admitted having heard rumors about cheating but refused to reveal the nature of those rumors. _ _ _ _. -. _
b) The same investigators incorrectly attributed 'to Husted the phrase " unconfirmed hearsay."
c) Husted did not know until very recently that the term
" unconfirmed hearsay" is a definition of the word " rumor."
d) Matakas' questions during the second interview were so imprecise that Husted mistakenly agreed that the " passing papers in the exam" comment and the " unconfirmed hearsay" were the same incident.
e) Husted testified incorrectly aefore the Special Master that the two OIE reports were accurate.
f) Husted made no attempt to correct these " mistakes" despite the fact that they resulted in the loss of his operating license and had a negative effect on his career.
/
D.
Husted's Lack of Forthrightness and His Incredible Testimony in 1981.
A repeated theme in Husted's proposed findings concerns the--
sequestration order in effect during the prior hearing.
(Husted PF 13 68, 83)
It is Husted's contention that the sequestration order prevented him and other witnesses who testified before the Special Master from receiving adequate preparation by counsel, and contributed to his anxiety, thus affecting the quality of his testimony. This is a total mischaracterization of the facts.
The sequestration order prevented. GPU witnesses from discussing their testimony with other GPU witnesses. There was no restriction on preparation by counsel.
(See Staff Ex. 2 at 26, 980 (Milhollin))
Furthermore, counsel for GPU felt free to inform GPU witnesses about testimony given by Staff witnesses during the hearing.
(Tr. 601 Husted)
Husted admits that he was not the only witness who experienced anxiety about testifying in the 1981 proceeding, but he claims that upon learning of' Ward's testimony regarding his attempt to cheat, his anxiety.
changed to "cutright fear."
(Husted PF 168)
A: cording to Husted his " fear" caused him to be so confused during cross examination by counsel for the Commonwealth of Pennsylvania that he incorrectly conceded the accuracy of the First and Second (OIE) Reports."
(Husted PF at 169)
Furthermore, his l
" outright fear" led him to " incorrectly (testify) that the ' passing papers' comment was the ' unconfirmed hearsay' referred to in the First Report." M.
Ward testified for the first time concerning the attempted cheating issue on 1 Dec. 1981.
Husted learned of Ward's testimony on the morning of the following day.
Tr. 601 (Husted)
Eight days elapsed from the time that Husted first learned of Ward's testiinony and the time that he himself testified.
During that time Husted made no attempt to protect himself.
He did not seek representation by counsel, nor did he consult with the company attorneys although they were available to him.
Tr. 602-603 (Husted)
Absent any attempt by Husted to protect himself, I cannot find his claim that his
" outright fear" upon learning of Ward's testimony, led him to testify incorrectly.
Nor do I find that his state of mind at the time that he testified, excused the " flippant" attitude which he displayed.
j In prefiled testimony Husted asserted that the word "During" which appears at Tr. 26, 930, line 6 (Staff Ex. 2) should be changed to read "Between."
(Husted PF at 151)
With this change, Husted asserts that his response contradicts his earlier testimony that the OIE summary of his first interview was accurate and that the " unconfirmed hearsay" and the " passing papers" comment are the same incident. Husted's testimony on this point would be more convincing if he had made an attempt to correct this " mistake" earlier.
It is inconceivable that Husted would have remained silent for four years if he were able to demonstrate that the conclusions reached by the Special Master and the Licensing Board were inaccurate.
I find that Husted's r t
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testimony that the two OIE reports accurately recorded his interviews was truthful and that his recent testimony recanting his earlier statements is not credible.
Husted concedes that he was not "a model witness" during his appearance before the Special Master.
(Husted PF 181)
He attributes this to -
stress and overwork.
(Id. 182)
During the hearing Husted reviewed his prior testimony and corrected those responses which he felt gave the impression that he had a " flippant" or "less than serious" attitude toward the hearing process.
He also conceded that his behavior at his 1981 deposition was " undesirable."
(Husted PF 190)
Husted faults both the Special Master and the Licensing Board for having
~
" based their findings about Husted's attitude on inferences drawn from his conductatthehearingkndhistestimonyonothersubjects."
(Husted PF 178)
Husted goes on to complain that during his earlier appearance he was not 3
s questioned about his " attitude toward the cheating hearing."
Id.
Of course it was not necessary to question him about his attitude, it was apparent from observing his behavior at the hearing and from reading the transcript of his i
testimony that his attitude was poor. See Staff Ex. 2.
Furthermore, even if one were to believe that there were legitimate reasons to explain Husted's behavior, he made no effort to bring those reasons to the attention of either i
e the Special Master or the Licensing Board although he had every motive to do so.
Under these circumstances I cannot find that Husted's behavior can be excused based on his " state of mind" at the time that he testified. My review of his earlier testimony, the OIE reports and the transcript of his 1981 deposition leads me to conclude that Husted exhibited a bad attitude during his appearance before the Special Master, that this attitude was apparently
]
caused by a deep seated resentment toward the regulatory process which he,
demonstrated repeatedly during the investigation and cheating hearing process.
E.
What does Husted's performance of his job related responsibilities reflect about his attitude and integrity.
Husted has devoted considerable time to discussion of the various evaluations of his job performance (Husted PF 11105-140) and concludes that his performance reflects favorably on his attitude and integrity.
(Husted 1
PF 1140)
He also finds that he is qualified technically to serve as a licensed operator and instructor.
(Husted PF 1108)
In reaching this finding Husted has ignored the evaluation of Husted's ability as an instructor provided by David Boyd of Data Design Laboratories.
In that evaluation Boyd found Husted to be an ineffective instructor.
(Husted Ex. 13)
Boyd also felt that Husted's attitude was "not' damaging."
Id.
This falls far short of an endorsement of Husted's ability to communicate a sense of responsibility to his students.
In fact it appears that GPU is so devoid of concern about its instructors' ability to convey a sense of responsibility toward the regulatory i
l process to their students that no category to evaluate this ability appears on the evaluation form.
(Tr. 677 (Haverkamp)
As Husted has noted, the " draft evaluation" authorized by Nelson Brown contains both favorable and unfavorable evaluations of Husted's job performance.
(Husted PF 1122)
Husted would dismiss this evaluation as a
" snap-shot" of Husted's performance, and grants it little weight.
Id.
But I cannot ignore Brown's comment in the category " Development of Subordinates."
Brown has noted that Husted "does not develop a positive attitude."
(Husted Ex. 3) Given the Appeal Board's concern about Husted's ability to communicate a sense of responsibility and respect toward the regulatory process, to his students, Brown's comment assumes great significance and cannot be dismissed lightly.,
When viewed in combination with Husted's refusal to cooperate and the poor attitude he exhibited toward the hearing process, I must draw a conclusion that Husted does communicate his resentment of regulation related to his job performance to the individuals he instructs.
The Reliability of the NRC Investigative Reports.
A persistent theme throughout Husted's findings is the notion that absent a verbatim transcript, summaries of interviews conducted by NRC investigators are invalid and therefore unjust.
(Husted PF 1144; 59; 103; 104)
I must note however that where Husted's testimony was recorded verbatim, i.e., at the hearing before the special Master, Husted found it necessary to
. make numerous corrections and changes to the transcript in order that his testimony conform to his current version of the facts.
Husted appears to believe that NRC investigators have a sinister motive to misrepresent and misrecord the testimony of honest employees.
(Husted PF 1104)
- However, i
Husted's own testimony belies this absurd notion. When asked what motive the t
investigators would have to " trick" him with overly broad questions, Husted responded that he thought that their motive was to " ferret out the truth."
Tr. S66 (Husted)
He goes on to propose numerous options which, had he exercised them might have jeopardized his livelihood.
_Id.
Such speculation is frivolous and without support.
In fact the record supports the opposite view. Matakas testified that had there been a problem about the accuracy of the record he would have delayed his interview of Husted until a court reporter was available.
Tr. 408-409 (Matakas)
There is no evidence that Husted or Janes requested a verbatim recording of their interviews, or that 1
With the recent revelation that the catastrcphe at Chernobyl was due entirely to human failure, the Appeal Board's concern in this regard is clearly appropriate.. _ _ _.,.._
-~ _
they ever requested that they be allowed to review and sign the investigators notes of their interviews.
In light of Husted's failure to make any attempt to check the accuracy of the interviewers' notes at the time of his interview and his admission that the investigators were motivated by a desire to uncover 4
the truth, I find that his complaints on this score are unworthy of consideration.
The Appeal Board's Standard Finally, I must address Husted's complaint about the standard
^
applied by the Appeals Board.
Husted claims that the Appeals Board did not relate Husted's failures to a statutory or regulatory requirement. However, the Commission has a responsibility to the safety of the public spelled out in 10 C.F.R. 550.57 (a) (3) r There is reasonable assurance (i) that the activities authorized oy the operating license can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the regulations...
s The Appeals Board was faced with a situation in which both the Licensing Board and the Special Master had determined that Husted had demonstrated a bad attitude toward the NRC process.
The Commonwealth of 1
Pennsylvania objected to the Licensing Board decision to allow Husted to continue in his position as instructor where he had the potential to influence licensed operators and trainees.
As a result of objections raised by the 4
Commonwealth, GPU entered into a stipulated agreement whereby they promised not to utilize Husted to operate the* plan, or to instruct those who do operate the plant.
In entering this agreement, GPU tacitly conceded the facts which formed the basis of the Commonwealth's objections.
Faced with this acknowledynent of Husted's potential negative impact on the safety of the plant in his position as instructor, the Appeals Board questioned GPU's judgment in promoting husted to a supervisory position within 1 y
the training department.
The Appeals Board reasoned that in his supervisory position he had the potential to influence an even greater number of individuals, and that his influence could have a negative impact on -le safety of the plant, as conceded by GPU in its agreement with the Commonwealth of Pennsylvania.
Under these circumstances the Appeals Board had no alternatives to ensure the safety of the public it required that Husted be removed from his supervisory position in the training department.
Hust.ed is suggesting that the Commission does not have the right to enforce its regulation.
Such a notion is absurd and Husted's argument to the contrary has no merit. He is attempting to present the issue as if it were a Civil Rights case, and that only his right to employment is at issue. Clearly this is not the case, the issue to be decided by the Commission is the public's right to an assurance of safety. The record demonstrates that Husted attempted to cheat during an NRC licensing examination, that he refused to cooperate with an NRC investigation and that he has demonstrated a 1
fundamentally poor attitude toward the NRC.
The Appeals Board's condition was i
appropriate when it was imposed and remains appropriate in light of the evidence in this record.
Respectfully submitted, p tW.-%
P Louise Bradford for Three Mile Island Alert I
i l
e 1
DC(,KE T El' N
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE In the Matter of
)
pp;c[CFElchtyjij-
)
CKElinu & SEP J GENERAL PUBLIC UTILITIES NUCLEAR,
)
Docket No. 50-189 (CH)
)
(Three Mile Island Nuclear Station,
)
Unit No. 1)
CERTIFICATE OF SERVICE I hereby certify that copies of "TMIA's REPLY TO FINDINGS PROPOSED BY CHARLES HUSTED" in the above captioned proceeding have been served by deposit in the U.S. Mail, first class postage prepaid, on the persons listed below, or, as indicated by an asterisk by express mail, this 4th day of Sept. 1,986.
- Morton B. Margulies Atomic Safety and Licensing Board Administrative Law Judge U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, DC 20555 U. S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission
- Michael W. Maupin, Esq.
Washington, DC 20555 Maria C. Hensley, Esq.
Hunton & Williams Docketing and Service Section P. O. Box 1535 Office of the Secretary Richmond, VA 23212 U. S. Nuclear Regulatory Commission Washington, DC 20555
- Deborah B. Bauser, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M Street, NW Washington, DC 20036
- George E. Johnson, Esq.
Office of Executive Legal Director U. S. Nuclear Regulatory Commission Washington, DC 20555 L C ^A e
Louise Bradford'j