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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20148P2031988-04-0404 April 1988 NRC Staff Response to Supplemental Interrogatories from TMI Alert/Susquehanna Valley Alliance.* Related Correspondence ML20150F8851988-03-30030 March 1988 Answers to Sva/Tmi Alert Second Set of Interrogatories to Util.* Submits Responses to Sva/Tmi Alert 880315 Interrogatories.W/Certificate of Svc.Related Correspondence ML20150D0561988-03-21021 March 1988 Valley Alliance/Tmi Alert Second Set of Interrogatories & Request for Production of Documents to NRC Staff.* Certificate of Svc Encl.Related Correspondence ML20150D0441988-03-21021 March 1988 Valley Alliance/Tmi Alert Second Set of Interrogatories & Request for Production of Documents to Gpu Nuclear.* Related Correspondence ML20149N0461988-02-22022 February 1988 NRC Staff Response to Interrogatories from TMI Alert/Sva.* Responds to Interrogatories Filed by TMI Alert/Sva on 880207.NRC Waived Requirement for Order from Presiding Officer Directing Discovery.Related Correspondence ML20196F1181988-02-22022 February 1988 Responses to NRC Interrogatories.* All Responses Re Disposal of Accident Generated Water by Intervenor F Skolnick. Certificate of Svc Encl.Related Correspondence ML20149M8671988-02-22022 February 1988 Licensee Response to Sva/Tmi Alert Request for Production of Documents.* Documents Re Disposal of accident-generated Water Will Be Made Available for Insp & Copying as Listed. Certificate of Svc Encl.Related Correspondence ML20149M8621988-02-19019 February 1988 Licensee Answers to Sva/Tmi Alert Interrogatories to Gpu Nuclear Corp.* Responds to Sva/Tmi Alert Interrogatories Re Disposal of accident-generated Water.Related Correspondence ML20149K8801988-02-15015 February 1988 Valley Alliance/Tmi Alert Responses to Licensee Interrogatories & Request for Documents.* Info Will Be Provided Upon Availability & Listed Documents Being Sent to Licensee.W/Certificate of Svc ML20196D3731988-02-0303 February 1988 Valley Alliance/Tmi Alert Interrogatories & Request for Production of Documents to Util.* Original Documents Identified in Answers to Listed Interrogatories Requested.W/Certificate of Svc.Related Correspondence ML20196D3921988-01-31031 January 1988 Valley Alliance/Tmi Alert Interrogatories & Request for Production of Documents to Nrc.* NRC Must Produce Any Addl Documents Responsive to Request.Certificate of Svc Encl.Related Correspondence ML20148U5331988-01-29029 January 1988 Licensee Interrogatories & Request for Production of Documents to TMI Alert & Susquehanna Valley Alliance.* Joint Intervenors Should Produce Original Documents Noted in Interrogatories.W/Certificate of Svc.Related Correspondence ML20235B6151987-09-18018 September 1987 NRC Staff Sixth Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories.* Staff Intends to Call C Barus as Rebuttal Witness.W/Certificate of Svc.Related Correspondence ML20214S0551987-06-0202 June 1987 Gpu Nuclear Response to NRC Staff Request for Production of Documents.* Request 1 Overly Broad,Burdensome & of Limited Relevance.Request 2 Vague.Related Correspondence ML20207S5861987-03-18018 March 1987 NRC Staff Response to Gpu Nuclear Corp Second Set of Interrogatories to NRC Staff & Fourth Request for Production of Documents.* W/Certificate of Svc.Related Correspondence ML20212N4831987-03-0505 March 1987 Gpu Nuclear Corp Response to NRC Staff Second Request for Documents.* Notes of Interviews Conducted by Stier or Associates & Certificate of Svc Encl.Related Correspondence ML20212K3891987-03-0303 March 1987 NRC Response to Gpu Nuclear Corp Third Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20212F9481987-03-0202 March 1987 Gpu Nuclear Corp Second Set of Interrogatories to NRC Staff & Fourth Request for Production of Documents.* NRC Should Produce All Documents Required to Be Identified by Listed Interrogatories.W/Certificate of Svc.Related Correspondence ML20211F5331987-02-19019 February 1987 Gpu Nuclear Corp Response to NRC Second Set of Interrogatories.* Persons Attending 830323 Meeting Re R Parks Public Statement Listed.Certificate of Svc Encl. Related Correspondence ML20211D6811987-02-19019 February 1987 NRC Fifth Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories & Request for Production of Documents.* Affidavit of MT Masnik Encl.Related Correspondence ML20212R6771987-01-29029 January 1987 NRC Staff Second Set of Interrogatories & Request for Documents to Gpu Nuclear Corporation.* Requests Info on 830323 Meeting W/Bechtel & Transfer or Removal of R Parks. W/Certificate of Svc.Related Correspondence ML20212R6501987-01-27027 January 1987 Gpu Nuclear Corp Third Request for Production of Documents.* W/Certificate of Svc.Related Correspondence ML20207P7141987-01-13013 January 1987 Gpu Second Request for Production of Documents.* Gpu Requests That NRC Identify Title,General Subj Matter,Date, Author & Reason Why Documents Requested Being Withheld. Related Correspondence ML20207N6721987-01-0909 January 1987 NRC Staff Fourth Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories & Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20207N7081987-01-0909 January 1987 Second Supplemental Response of Gpu Nuclear Corp to NRC Staff First Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20207N6911987-01-0909 January 1987 Third Supplemental Response of Gpu Nuclear Corp to NRC Staff First Set of Interrogatories.* Related Correspondence ML20207L9041987-01-0505 January 1987 NRC Staff Third Supplemental Response to Gpu First Set of Interrogatories & Request for Production of Documents.* MT Masnik & Me Resner 870105 Affidavits & Certificate of Svc Encl.Related Correspondence ML20207C4711986-12-22022 December 1986 Second Supplemental Response to NRC First Set of Interrogatories Re Util Organization & Witnesses.Certificate of Svc Encl.Related Correspondence ML20212D6651986-12-15015 December 1986 NRC Staff Second Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories & Request for Production of Documents.* Unexecuted Affidavit of RA Meeks & Certificate of Svc Encl.Related Correspondence ML20211K2771986-11-13013 November 1986 Response to First Request for Production of Documents Re Basis for R Parks Removal from Test Working Group on 830223 & Parks Involvement W/Quiltech Co.Certificate of Svc Encl. Related Correspondence ML20215M9901986-10-29029 October 1986 First Supplemental Response to NRC First Set of Interrogatories Re Suspension of R Parks Employment at Facility Site.W/Certificate of Svc.Related Correspondence ML20211G5101986-10-28028 October 1986 Response to Interrogatories Re Bechtel Oct 1984 Rept, Rept of Bechtel North American Power Corp Re Allegations of Rd Parks & Eh Stier 831116 Rept, TMI-2 Rept-Mgt & Safety Allegations. Related Correspondence ML20215D8681986-10-0909 October 1986 First Request for Production of Seven Categories of Documents Re Basis for R Parks Removal from Testing Working Group on 830223 & Investigation of Parks Involvement W/ Quiltech Co.Related Correspondence ML20215D8781986-10-0909 October 1986 First Set of Interrogatories for Documents Re Identification of Util Employees Providing or Receiving Info Leading to Interrogation of Rd Parks Re Quiltech Co.Related Correspondence ML20215D8821986-10-0909 October 1986 Supplemental Response to Gpu First Set of Interrogatories & First Request for Documents Re Enforcement Action EA-84-137. Supporting Documentation & Certificate of Svc Encl.Related Correspondence ML20214R6291986-09-23023 September 1986 Response to Util First Set of Interrogatories & Partial Response to First Request for Production of Documents. Affidavits Encl.Related Correspondence ML20209G1681986-09-0404 September 1986 First Request for Production of Documents Identified in NRC Responses to Listed Interrogatories,Including Interrogatory 1(e) Re Protected Activity Engaged in by Parks Resulting in Alleged Discrimination Against Parks.W/Certificate of Svc ML20209G3181986-09-0404 September 1986 First Set of Interrogatories Re Removal of Rd Parks from Employment.W/Certificate of Svc ML20211E6311986-06-11011 June 1986 First Supplemental Answer to NRC First Interrogatories & Request for Production of Documents to C Husted.Rl Long Notes Produced Indicating Husted Met W/J Herbein on 811005. Related Correspondence ML20211E6601986-06-11011 June 1986 First Supplemental Answers to TMI Alert First Request for Production of Documents & First Interrogatories to C Husted. Rl Long Notes of 820527 Conversation W/Newton Encl.W/ Certificate of Svc. Related Correspondence ML20197C1931986-05-0808 May 1986 Answers to TMI Alert,Inc 860501 Supplemental Interrogatories.Certificate of Svc Encl.Related Correspondence ML20203L6011986-04-28028 April 1986 Responses to TMI Alert First Request for Production of Documents & First Interrogatories.Certificate of Svc Encl. Related Correspondence ML20141J3171986-04-23023 April 1986 Response to Util First Interrogatories & Request for Production of Documents Re Senior Reactor Operator Licensing Exams.Certificate of Svc Encl.Related Correspondence ML20141J4071986-04-23023 April 1986 Response to Husted First Interrogatories & Request for Production of Documents Re Alleged Cheating During Apr 1981 OL Exams.Certificate of Svc Encl.Related Correspondence ML20155F5471986-04-18018 April 1986 Supplemental Response to NRC Interrogatories 3 & 4 & Request for Production of Documents to Util.Certificate of Svc Encl. Related Correspondence ML20203B4121986-04-15015 April 1986 Response to First Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20203B6311986-04-14014 April 1986 Answers to Staff First Interrogatories & Request for Production of Documents.Related Correspondence ML20202G5381986-04-0909 April 1986 First Interrogatories & Request for Production of Documents to TMI Alert Re Apr 1981 Senior Reactor Operator Exam. Certificate of Svc Encl.Related Correspondence ML20202G7361986-04-0909 April 1986 Response to TMI Alert,Inc First Request for Production of Documents & First Interrogatories.Certificate of Svc Encl. Related Correspondence ML20202G6651986-04-0808 April 1986 C Husted Answers to NRC First Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence 1988-04-04
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20210B8491999-07-21021 July 1999 Exemption from Certain Requirements of 10CFR50.54(w),for Three Mile Island Nuclear Station Unit 2 to Reduce Amount of Insurance for Unit to $50 Million for Onsite Property Damage Coverage ML20206D4141999-04-20020 April 1999 Exemption from Requirements of 10CFR50,App R,Section III.G.2 Re Enclosure of Cable & Equipment & Associated non-safety Related Circuits of One Redundant Train in Fire Barrier Having 1-hour Rating ML20206T7211999-02-11011 February 1999 Memorandum & Order (CLI-99-02).* Denies C George Request for Intervention & Dismisses Subpart M License Transfer Proceeding.With Certificate of Svc.Served on 990211 ML20198A5111998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50.65 Re Requirements for Monitoring Effectiveness of Maintenance at Nuclear Power Plants.Proposed Rulemaking Details Collaborative Efforts in That Rule Interjects Change ML20154G2941998-09-17017 September 1998 Transcript of 980917 Public Meeting in Rockville,Md Re License Transfer of TMI-1 from Gpu Nuclear,Inc to Amergen. Pp 1-41 ML20199J0121997-11-20020 November 1997 Comment on Pr 10CFR50 Re Financial Assurance Requirements for Decommisioning Nuclear Power Reactors.Three Mile Island Alert Invokes Comments of P Bradford,Former NRC Member ML20148R7581997-06-30030 June 1997 Comment on NRC Proposed Bulletin 96-001,suppl 1, Control Rod Insertion Problems. Licensee References Proposed Generic Communication, Control Rod Insertion, & Ltrs & 961022 from B&W Owners Group ML20078H0431995-02-0101 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Lowpower Operations for Nuclear Reactors ML20077E8231994-12-0808 December 1994 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re Rev to NRC NPP License Renewal Rule ML20149E2021994-04-20020 April 1994 R Gary Statement Re 10 Mile Rule Under Director'S Decision DD-94-03,dtd 940331 for Tmi.Urges Commissioners to Engage in Reconsideration of Author Petition ML20065Q0671994-04-0707 April 1994 Principal Deficiencies in Director'S Decision 94-03 Re Pica Request Under 10CFR2.206 ML20058A5491993-11-17017 November 1993 Exemption from Requirements in 10CFR50.120 to Establish, Implement & Maintain Training Programs,Using Sys Approach to Training,For Catorgories of Personnel Listed in 10CFR50.120 ML20059J5171993-09-30030 September 1993 Transcript of 930923 Meeting of Advisory Panel for Decontamination of TMI-2 in Harrisburg,Pa.Pp 1-130.Related Documentation Encl ML20065J3461992-12-30030 December 1992 Responds to Petition of R Gary Alleging Discrepancies in RERP for Dauphin County,Pa ML20065J3731992-12-18018 December 1992 Affidavit of Gj Giangi Responding to of R Gary Requesting Action by NRC Per 10CFR2.206 ML20198E5581992-12-0101 December 1992 Transcript of Briefing by TMI-2 Advisory Panel on 921201 in Rockville,Md ML20210D7291992-06-15015 June 1992 Exemption from Requirements of 10CFR70.24 Re Criticality Accident Requirements for SNM Storage Areas at Facility Containing U Enriched to Less than 3% in U-235 Isotope ML20079E2181991-09-30030 September 1991 Submits Comments on NRC Proposed Resolution of Generic Issue 23, Reactor Coolant Pump Seal Failure. Informs That Util Endorses Comments Submitted by NUMARC ML20066J3031991-01-28028 January 1991 Comment Supporting SECY-90-347, Regulatory Impact Survey Rept ML20059P0531990-10-15015 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N5941990-10-0404 October 1990 Transcript of 900928 Public Meeting in Rockville,Md Re Studies of Cancer in Populations Near Nuclear Facilities, Including TMI ML20055F4411990-06-28028 June 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR ML20248J1891989-10-0606 October 1989 Order.* Grants Intervenors 891004 Motion for Permission for Opportunity to Respond to Staff Correspondence.Response Requested No Later That 891020.W/Certificate of Svc.Served on 891006 ML20248J1881989-10-0303 October 1989 Motion for Permission for Opportunity to Respond to Staff Correspondence in Response to Board Order of 890913.* Svc List Encl ML20248J0301989-09-29029 September 1989 NRC Staff Response to Appeal Board Order.* Matters Evaluated in Environ Assessment Involved Subjs Known by Parties During Proceeding & Appear in Hearing Record & Reflect Board Final Initial Decision LBP-89-7.W/Certificate of Svc ML20247E9181989-09-13013 September 1989 Order.* Requests NRC to Explain Purpose of 890911 Fr Notice on Proposed Amend to Applicant License,Revising Tech Specs Re Disposal of Accident Generated Water & Effects on ASLB Findings,By 890929.W/Certificate of Svc.Served on 890913 ML20247G0361989-07-26026 July 1989 Transcript of Oral Argument on 890726 in Bethesda,Md Re Disposal of accident-generated Water.Pp 1-65.Supporting Info Encl ML20247B7781989-07-18018 July 1989 Certificate of Svc.* Certifies Svc of Encl Gpu 890607 & 0628 Ltrs to NRC & Commonwealth of Pa,Respectively.W/Svc List ML20245D3651989-06-20020 June 1989 Notice of Oral Argument.* Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from ASLB 890202 Initial Decision Authorizing OL Amend,Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890620 ML20245A5621989-06-14014 June 1989 Order.* Advises That Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from Board 890202 Initial Decision LBP-89-07 Authorizing OL Amend Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890614 ML20247F3151989-05-22022 May 1989 NRC Staff Response to Appeal by Joint Intervenors Susquehanna Valley Alliance/Tmi Alert.* Appeal Should Be Denied Based on Failure to Identify Errors in Fact & Law Subj to Appeal.W/Certificate of Svc ML20246Q2971989-05-15015 May 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20246J6081989-05-12012 May 1989 Licensee Brief in Reply to Joint Intervenors Appeal from Final Initial Decision.* ASLB 890203 Final Initial Decision LBP-89-07 Re Deleting Prohibition on Disposal of accident- Generated Water Should Be Affirmed.W/Certificate of Svc ML20247D2761989-04-20020 April 1989 Transcript of 890420 Briefing in Rockville,Md on Status of TMI-2 Cleanup Activities.Pp 1-51.Related Info Encl ML20244C0361989-04-13013 April 1989 Order.* Commission Finds That ASLB Decision Resolving All Relevant Matters in Favor of Licensee & Granting Application for OL Amend,Should Become Effective Immediately.Certificate of Svc Encl.Served on 890413 ML20245A8381989-04-13013 April 1989 Transcript of Advisory Panel for Decontamination of TMI-2 890413 Meeting in Harrisburg,Pa.Pp 1-79.Supporting Info Encl ML20245A2961989-04-13013 April 1989 Transcript of 890413 Meeting in Rockville,Md Re Affirmation/Discussion & Vote ML20248H1811989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* W/Certificate of Svc.Served on 890411.Granted for Aslab on 890410 ML20248G0151989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* Requests to File Appeal Brief 1 Day Late Due to Person Typing Document Having Schedule Problems ML20248G0261989-04-0606 April 1989 Susguehanna Valley Alliance/Tmi Alert Brief in Support of Notification to File Appeal & Request for Oral Argument Re Appeal.* Certificate of Svc Encl ML20248D7211989-04-0404 April 1989 Memorandum & Order.* Intervenors Application for Stay Denied Due to Failure to Lack of Demonstrated Irreparable Injury & Any Showing of Certainty That Intervenors Will Prevail on Merits of Appeal.W/Certificate of Svc.Served on 890404 ML20247A4671989-03-23023 March 1989 Correction Notice.* Advises That Date of 891203 Appearing in Text of Commission 890322 Order Incorrect.Date Should Be 871203.Certificate of Svc Encl.Served on 890323 ML20246M2611989-03-22022 March 1989 Order.* Advises That Commission Currently Considering Question of Effectiveness,Pending Appellate Review of Final Initial Decision in Case Issued by ASLB in LBP-89-07. Certificate of Svc Encl.Served on 890322 ML20236D3821989-03-16016 March 1989 Valley Alliance & TMI Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of 2.3 Million Gallons Of....* Certificate of Svc Encl.Served on 890316.Granted for Aslab on 890316 ML20236D3121989-03-15015 March 1989 Licensee Answer to Joint Intervenors Motion for Extension of Time to File Brief on Appeal.* Motion Opposed Based on Failure to Demonstrate Good Cause.W/Certificate of Svc ML20236D2901989-03-11011 March 1989 Valley Alliance/Tmi Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of Disposal of 2.3 Million Gallons of Radioactive Water at Tmi,Unit 2.* Svc List Encl ML20236A3761989-03-0808 March 1989 Licensee Answer Opposing Joint Intervenors Motion for Stay.* Stay of Licensing Board Decision Pending Appeal Unwarranted Under NRC Stds.Stay Could Delay Safe,Expeditious Cleanup of Facility.Certificate of Svc Encl ML20236C2441989-03-0808 March 1989 NRC Staff Response in Opposition to Application for Stay Filed by Joint Intervenors.* Application for Stay of Effectiveness of Final Initial Decision LBP-89-07,dtd 890202 Should Be Denied.W/Certificate of Svc ML20235V2641989-03-0202 March 1989 Notice of Aslab Reconstitution.* TS Moore,Chairman,Cn Kohl & Ha Wilber,Members.Served on 890303.W/Certificate of Svc ML20235V2161989-02-25025 February 1989 Changes & Corrections to Susquehanna Valley Alliance/Three Mile Island Alert Documents Submitted on 890221.* Certificate of Svc Encl 1999-07-21
[Table view] |
Text
e- su Aif.ocong %
M April 9, 1986
%$$[E0 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION jj ..
O '9 P4 :33 In the Matter of ) $pE ,
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)
GENERAL PUBLIC UTILITIES ) Docket No. 50-289'('CH).
NUCLEAR CORPORATION )
)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
)
RESPDNSE OF GPU NUCLEAR CORPORATION TO TMIA'S FIRST REQUEST FOR PRODUCTION OF !
DOCUMENTS AND FIRST INTERROGATORIES TO l GENERAL PUBLIC UTILITIES NUCLEAR INTERROGATORIES Pursuant to the provisions of 10 C.F.R. Section 2.740, 2.740b, and 2.741, GPU Nuclear Corporation hereby answers or objects to TMIA's First Request for Production of Documents and First Interrogatories to General Public Utilities Nuclear. GPU Nuclear Corporation ("GPUN") expressly reserves the rit at to i 1
add to or amend its response to each and every interrogatory l contained herein.
INTERROGATORY NO. 1: Did a member of GPU personnel or l agent of GPU accompany Charles Husted during his July 29, 1981 interview by Office of Inspection and Enforcement (OIE)? If you have answered yes, state:
- a. whether Husted requested that he be accompanied.
- b. the name and job title of the person who accompanied Husted.
8604140478 860409 C PDR ADOCK 05000289 Q
- w r
l c. whether or not that person took notes of the: interview.
- d. provide all notes taken during the in-
- terview.
ANSWER TO INTERROGATORY NO. 1: GPUN advised all of its employees who were to be interviewed by OIE that, upon the employee's request, a representative of GPUN management would
- accompany the employee during his or her interview. .Mr. Husted elected to be accompanied by a management representative during i
L Mr. Husted's July 29, 1981 interview, and Paul G. Christman, q
j Manager, Plant Administration TMI-1, attended the interview.
Mr. Christman took notes of the investigation interview, and these notes are being provided to TMIA by Mr. Husted's counsel.
t l
j INTERROGATORY NO. 2: After the July 29, 1981 interview j was completed, did GPU management or its agent discuss the sub-i stance of the interview with Husted? If-you have answered yes,
! state:
- a. the name'and job-title (s) of the per-son (s) who discussed'the interview with l Husted.
i
- b. the substance of the discussion.
I c. provide all documentation of the discus-I sion.
ANSWER TO INTERROGATORY NO. 2: Samuel Newton, then Opera-i tions Training Manager, recalls discussing'an NRC OIE-interview j with Mr. Husted sometime shortly after it took place. He re-calls that Mr. Husted told him that it was an interview at which Mr. Christman was present. The discussion. focused on Mr.
t Husted's responses during the interview. -Mr. Newton recalls I
J i 4 i
O that Mr. Husted stated that he was very nervous during the in-terview. Mr. Newton and Mr. Husted discussed how to try to ap-I pear more comfortable during this process.
After the Special Master's Report, Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1), Docket No. 50-289 (CH) (February 27, 1986), was issued, GPUN manage-ment personnel had conversaticns with Mr. Husted concerning his conduct at the July 29, 1981 interview and how such conduct re-lated to the conclusion contained in the Special Master's Report. The following GPUN management personnel participated in these discussions at various times:
Dr. Robert Long, Director of Training & Education Mr. Henry D. Hukill, VP/ Director TMI-l Mr. Samuel Newton, Operator Training Manager Dr. Ronald Knief, Manager, Plant Training TMI-1.
GPUN presently believes that no other discussions concerning the July 29, 1981 interview occurred between Mr. Husted and GPUN management.
GPUN will produce a document relating to these discus-sions. I I
l INTERROGATORY NO. 3: Did GPU management or its agent pro- .
vide Husted with a copy of the OIE report? If you have an- (
I swered yes, state:
- a. the name and job title (s) of the per-son (s) who provided Husted with a copy of the report. ,
OBJECTION TO INTERROGATORY NO._3: GPUN objects to this interrogatory on the grounds of irrelevancy. Whether GPUN management provided Mr. Husted with a copy of the OIE report is not relevant to any contention to be litigated in this proceed-ing. See 10 C.F.R. S 2.740(b), Fed. R. Civ. P. 26(b) and the Report and Order on Initial Prehearing Conference, General Public Utilities Corporation (Three Mile Island Nuclear Sta-tion, Unit No. 1), Docket No. 50-289 (CH) (February 27, 1986).
I Notwithstanding this objection, but without prejudice thereto, GPUN provides the following answer:
l ANSWER TO INTERROGATORY NO. 3: The individuals who were l in contact with Mr. Husted about this matter, see Answer to Interrogatory No. 2, do not recall providing this document to J Mr. Husted, although they believe it is probable that someone did. ;
INTERROGATORY NO. 4: Did GPU management or its agent dis-
~
l cuss the section of the OIE report which referred to Husted, with Husted? If you have answered yes, state:
- a. the name and job title (s) of the per- !
son (s) who discussed the section of the i OIE report which referred to Husted. i
- b. the names and job titles of all persons present during the discussion.
- c. the substance of the discussion.
- d. provide all documentation of the discus-sion.
ANSWER TO INTERROGATORY NO. 4: Mr. Husted discussed the section of the OIE report which referred to him with the GPUN management personnel listed in the Answer to Interrogatory No.
1
- 2. GPUN presently believes that on no occasion other than l
l
l those indicated in the Answer to Interrogatory No. 2 did Mr.
Husted discuss the OIE report with GPUN management personnel.
GPUN will provide a document relating to this discussion. I 1
INTERROGATORY NO. 5: Did GPU management or its agent dis-
- cuss that section of the Special Master's Report (SMR) which referred to Husted, with Husted? If you have answered yes, state:
- a. the name and job title (s) of the per-son (s) who discussed the section of the SMR which referred to Husted,
- b. the names and job titles of all persons present during the discussion.
- c. the substance of the discussion.
- d. provide all documentation of the discus-slon.
l ANSWER TO INTERROGATORY NO. 5: Mr. Husted discussed the section of the Special Master's Report with the GPUN management personnel listed in the Answer to Interrogatory No. 2. GPUN l presently believes that on no occasion other than those indi-cated in the Answer to Interrogatory No. 2 did GPUN management personnel and Mr. Husted discuss the Special Master's Report.
GPUN will provide a document relating to this discussion. l INTERROGATORY NO. 6: Did GPU management or its agent in-form Husted of his right to comment on the SMR7 If you have answered,yes, state:
- a. the name and job title (s) of the per-son (s) who informed Husted of his right to comment on the SMR.
- b. the names and job titles of all persons present during the discussion.
-s-
o
- c. the substance of the discussion.
- d. provide all documentation of the discus-s slon.
OBJECTION TO INTERROGATORY NO. 6: GPUN objects to this interrogatory on the grounds of irrelevancy. Whether GPUN man-agement personnel informed Mr. Husted of his right to comment on the SMR is not relevant to any contention to be litigated in this proceeding. See 10 C.F.R. S 2.740(b), Fed. R. Civ. P.
26(b), Report and Order on Initial Prehearing Conference, General Public Utilities Nuclear Corocration (Three Mile Island Nuclear Station, Unit No. 1), Docket No. 50-289 (CH) (February 27, 1986). Due to the irrelevancy of this interrogatory, GPUN is not required to answer.
l INTERROGATORY NO. 7: Did GPU management or its agent advise Husted to submit comments on the SMR? If you have an-swered yes, state:
- a. the name and job title (s) of the per-son (s) who advised Husted to submit com-ments on the SMR. j
- b. the names and job titles of all persons present during the discussion.
- c. the substance of the discussion.
- d. provide all documentation of the discus-sion.
OBJECTION TO INTERROGATORY NO, 7: GPUN incorporates here-a in by reference its objection to Interrogatory No. 6. Due to the irrelevancy of this interrogatory, GPUN is not required to answer.
INTERROGATORY NO. 8: Did GPU management or its agent -
advise Husted not to submit comments on the SMR? If you have answered yes, state:
- a. the name and job title (s) of the per-son (s) who advised Husted not to submit comments on the SMR.
- b. the names and job titles of all persons present during the discussion.
- c. the substance of the discussion.
- d. provide all documentation of the discus-sion.
- e. explain why he was so advised.
OBJECTION TO INTERROGATORY NO. 8: GPUN incorporates here-in by reference its objection to Interrogatory No. 6. Due to the irrelevancy of this interrogatory, GPUN is not required to answer.
INTERROGATORY NO. 9: Did GPU management or its agent pro- .
vide Husted with copies of the Commonwealth of Pennsylvania's !
r Exceptions to the July 27, 1982 Partial Initial Decision (PID) '
and the Commonwealth's Brief in Support of its Exceptions? If you have answered yes, state:
- a. the name and job title (s) of the per-son (s) who provided Husted copies of said documents.
- b. when Husted was provided copies of said documents.
OBJECTION TO INTERROGATORY NO. 9: GPUN incorporates here-in by reference its objection to Interrogatory No. 6. Notwith-1 standing this objection, but without prejudice thereto, GPUN provides the following answer:
O ANSWER TO INTERROGATORY NO. 9: Upon information and be-lief, Mr. Samuel Newton, Operator Training Manager, provided to Mr. Husted copies of the Commonwealth of Pennsylvania's Excep-tions to the July 27, 1982 Partial Initial Decision and the Commonwealth's Brief in Support of Its Exceptions shortly after their issuance.
INTERROGATORY NO. 10: Did GPU management or its agent discuss the documents referenced in No. 9 above with Husted?
If you have answered yes, state:
- a. the name(s) and job title (s) of the per-son (s) who had the discussion with Husted,
- b. the names and job titles of all persons present during the discussion,
- c. the substance of the discussion.
- d. provide all documentation of the discus-i slon.
OBJECTION TO INTERROGATORY NO. 10: GPUN incorporates herein by reference its objection to Interrogatory No. 6. Due l l
to the irrelevancy of this interrogatory, GPUN in not required to answer.
INTERROGATORY NO. 11: Did GPU management or its agent request Husted's input prior to making the agreement concerning Husted with the Commonwealth? If you have answered yes, state:
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- a. the name(s) and job title (s) of the per-son (s) who made the request,
- b. when the request was made.
- c. provide all documentation of any meeting with Husted at which the proposed agreement was discussed prior to the finalizing of the agreement.
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- d. provide all documentation of Husted's input.
OBJECTION TO INTERROGATORY NO. 11: GPUN incorporates herein by reference its objection to Interrogatory No. 6. Due to the irrelevancy of this interrogatory, GPUN is not required to answer.
INTERROGATORY NO. 12: Was Husted's promotion to Supervi-sor Non-Licensed Training in any way related to his concurrence with the stipulated agreement?
- a. If you have answered yes, describe the relationship.
- b. If. you have answered no, state the rea-son for Husted's promotion.
OBJECTION TO INTERROGATORY NO. 12: GPUN incorporates herein by reference its objection to Interrogatory No. 6. Not-j withstanding this objection, but without prejudice thereto, GPUN provides the following answer:
ANSWER TO INTERROGATORY NO. 12: Mr. Husted's assignment to Supervisor Non-Licensed Operator Training was not related in any way to his concurrence with the stipulated agreement. Mr. .
l Husted was assigned to Supervisor Non-Licensed Operator
- Training because he was qualified for that position. Further-
) more, an extensive program designed to observe Mr. Husted's performance and attitudes indicated that he was performing very satisfactorily and that there was no evidence of undesirable attitudes or lack of respect for the training and licensing process. Based on these observations,'both Dr. Long and the l
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Director of Training and Education, Dr. Coe, concurred in Mr.
Husted's appointment to Supervisor Non-Licensed Operator Training.
INTERROGATORY NO. 13: Did GPU management or its agent discuss the sections of the July 27, 1982 PID which referred to Husted, with Husted? If you have answered yes, state:
- a. the name(s) and job title (s) of the per-son (s) who discussed the sections of the PID which referred to Husted with him.
- b. when these discussions took place.
- c. the substance of the discussion.
- d. provide all documentation of the discus-sion.
OBJECTION TO INTERROGATORY NO. 13: GPUN incorporates herein by reference its objection to Interrogatory No. 6. Not-withstanding this objection, but without prejudice thereto, GPUN provides the following answer.
ANSWER TO INTERROGATORY NO. 13: The individuals who were in contact with Mr. Husted, see Answer to Interrogatory No. 2, i
do not recall discussing the July 27, 1982 PID with Mr. Husted, although they believe it is probable that someone did.
INTERROGATORY NO. 14: Did GPU management or its agent discuss with Husted the relevant portions of ALAB-772? If you have answered yes, state:
- a. the name(s) and job title (s) of the per-son (s) who discussed the relevant sec-tions of ALAB-772 with Husted.
- b. when these discussions took place.
- c. the substance of the discussion.
- d. provide all documentation of the discus-slon.
OBJECTION TO INTERROGATORY NO. 14: GPUN incorporates herein by reference its objection to Interrogatory No. 6. Not-withstanding this objection, but without prejudice thereto, GPUN offers the following answer:
! ANSWER TO INTERROGATORY NO. 14: Upon information and be-lief, Dr. Long and Mr. Newton discussed the relevant portion of ALAB-772 with Mr. Husted. Dr. Long and Mr. Newton informed Mr.
Husted that as a result of ALAB-772, Mr. Husted would be trans-ferred to the Nuclear Safety Assessment Department to work on the TMI-1 probabilistic risk assessment project.
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INTERROGATORY NO. 15: Did GPU management or its agent advise Husted to request a hearing? If you have answered yes, j state:
- a. the name(s) and job title (s) of the per-son (s) who advised Husted to request a hearing.
- b. when these discussions took place.
- c. the substance of the discussion.
- d. provide all documentation of the discus-sion.
OBJECTION TO INTERROGATORY NO. 15: GPUN incorporates herein by reference its objection to Interrogatory No. 6. Due to the irrelevancy of the interrogatory, GPUN is not required to answer.
INTERROGATORY NO. 16: Is GPU management or its agent pro-viding any part of Husted's legal fees, whether by direct pay-ment to Husted or to his counsel, or by any other arrangements?
l ANSWER TO INTERROGATORY NO. 16: GPUN is providing Mr.
Husted's legal fees.
- INTERROGATORY NO. 17
- Identify every witness who will testify at the hearing in this proceeding on your behalf or who has been requested to testify, will be requested to testify or is likely to be requested to testify, regardless of whether the nature of the appearance be by summons or voluntary, and fur-
! ther state the subject area and substance upon which each wit-ness is expected to testify.
ANSWER TO INTERROGATORY NO. 17: GPUN presently has not determined the witnesses who it will request to testify at the hearing in this proceeding. Such information will be provided f
to TMIA once it has been determined.
l PRODUCTION OF DOCUMENTS REQUEST NO. 1: Evaluations of Husted's job performance from the time of his employment at TMI through the time of his promotion to Supervisor Non-Licensed Training. ,
l RESPONSE TO REQUEST NO. 1: Counsel for Charles E. Husted is providing some of the documents sought in Request No. 1, and GPUN will provide additional documents relevant to this Re-quest.
REQUEST NO. 2: Documentation of GPU's promotional policy as it existed at the time of Husted's promotion to Supervisor Non-Licensed Training.
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RESPONSE TO REQUEST NO. 2: GPUN has not yet located any documentation responsive to Request No. 2. If such documenta-tion is available, it will be provided to TMIA upon its identi-fication.
REQUEST NO. 3: Copies of all of Husted's NRC and company-administered licensing examinations and quizzes since his employment at TMI.
OBJECTION TO REQUEST NO. 3: GPUN objects to this Request on the grounds of irrelevancy. The documents in the Request relate solely to Mr. Husted's competency, and Mr. Husted's com-petency is not an issue which is to be litigated in this pro-ceeding. Thus, the documents sought in this Request are irrel-evant. Because of this irrelevancy, GPUN is not required to produce the requested documents.
REQUEST NO. 4: All documents GPU intends to introduce during the course of the Husted hearing.
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l RESPONSE TO REQUEST NO. 4: GPU presently has not deter- ;
mined the documents it will introduce at the hearing. Such documents will be provided to TMIA as soon as they are identi-fied.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By: bM -
h Deborah B. Bauser Scott E. Barat Counsel for GPU Nuclear Corporation ~
1800 M Street, N.W.
Washington, D.C. 20036 (202) 822-1000 Dated: April 9, 1986 I
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1 April 9, 1986 UNITED STATES OF AMERICA
] NUCLEAR REGULATORY COMMISSION f
- BEFORE THE ADMINISTRATIVE LAW JUDGE l
In the Matter of )
)
i GENERAL PUBLIC UTILITIES ) Docket No. 50-289 (CH)
NUCLEAR CORPORATION )
)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
)
4 CERTIFICATE OF SERVICE l I hereby certify that copies of " Response of GPU Nuclear Corporation to TMIA's First Request for Production of Documents and First Interrogatories to General Public Utilities Nuclear,"
i dated April 9, 1986, were served on the following by deposit in the U.S. mail, first class, postage prepaid, or, as indicated I
- by one asterisk, by hand delivery, or as indicated by two as-l 5
terisks, by Federal Express, this 9th day of April, 1986.
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)
1
{
- Morton B. Margulies, Esquire i
. Administrative Law Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission l Washington, D.C. 20555 1
- George E. Johnson, Esquire i
Office of Executive Legal Director U.S. Nuclear Regulatory Commission l Washington, D.C. 20555'
Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Ms. Louis Bradford Three Mile Island Alert 1011 Green Street Harrisburg, PA 17102
- Michael Maupin, Esquire Hunton & Williams P. O. Box 1535 Richmond, VA 23212 su /3. bat.-
Deborah B. Bauser I