ML20137B143

Suppl to Request for Leave to Intervene in Hearing Granted C Husted.Aslap Condition Barring Husted from Supervisory Role in Personnel Training Supported.Husted Should Be Licensed Operator

ML20137B143
Person / Time
Site:	Three Mile Island
Issue date:	01/09/1986
From:	Bradford L THREE MILE ISLAND ALERT
To:	Margulies M Atomic Safety and Licensing Board Panel
References
CON-#186-724 CH, NUDOCS 8601150124
Download: ML20137B143 (2)

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UNITED STATES OF' AMERICA NUCLEAR REGULATORY COMMISSION f3hIJD~

BEFORE ADMINISTRATIVE LAW JUDGE N JA// l3 MORTON B. MARGULIES AII !34 In'the Matter of ) Eikc[S$$(741;

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~ GENERAL PUBLIC UTILITIES NUCLEAR )

) Docket No.-50-289 (CH)

('Three Mile Island Nuclear Station, )

Unit No. 1) ) .

SUPPLEMENT TO TMIA'S REQUEST FOR LEAVE TO INTERVENE IN THE HEARING GRANTED CHARLES EUSTED ,

On December 6, 1985,~A[irdinistrative Law Judge Morton B. Margulies ordered petitioners to file contentions which they seek to have litigated. . Judge Margulies further ordered that filings are to be in the. hands of recipients on January 13, 1986. TMIA submits the.following contentions in compliance with that order.

I. The Appeal Board's condition barring Charles Husted from supervisory responsibilities insofar as the training of non-licensed personnel is concerned, should not be vacated.

II. Husted should be barred from serving as an NRC licensed operator by reason of his demonstrated bad attitude and lack of integrity.

TMIA offers the following facts and argument in support of its contentions:

The Special Master, the Licensing Board and the Appeal Board all concluded that Husted:

(a) provided incredible testimony at the cheating hearing; g Special Master's Report (SMR)p 110-111, PID 2165-66, ALAB-772 at p. 43.

(b) refused to cooperate with NRC investigators during their investigation of cheating at o TMI.

SMR' 109, PIDO 2165, ALAB-772 at p.

4 43.

(c) displayed a bad attitude toward the NRC hearing process.

ir SMR 110, PID ". , ALAB-772 at p. 43.

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. I In addition, the Licensing Board concluded that:

if Mr. Husted is representative of the TMI-l training department his attitude may be a partial explanation of why there was disrespect for the training program and examinations.

we question whether he is able, or if able, willing to impart a sense of seriousness and responsibility to the TMI-l operations.

G PID 2167.

Furthermore, the Special Master found that Husted made an unsuccessful attempt to cheat during an NRC licensing exam. Although the Licensing Board disagreed with the Special Master on ths issue, a final decision has yet to be rendered and the weight of the evidence supports the Special Master's finding.

f Husted's refusal to cooperate with the NRC investi-gators and the bad attitude he exhibited at the hearing, as well as his attempt to cheat, amount to a total disregard for the NRC regulatory process. If Husted is allowed to operate the plant and to supervise the training of personnel on the career path to operator status, the public will have no assurance that the plant will be operated safely.

Respectfully submitted, a

M6_.A _ e '

Louise Bradford -

for Three Mile Island Alert, Inc.

January 9, 1986 t

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